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HomeMy WebLinkAbout00-02614 I.. FREDERICK L. YOUNG and DONNA M. YOUNG, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. CIVIL ACTION - LAW _ NO. c:o - C)(P)lf ~ CHERYL A. GRAY, Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND TO: Cheryl A. Gray 4618 Oxford Road Harrisburg, PA 17109-1614 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 reliefrequested 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 Document #: 173973.1 ..~~ b'--n! FREDERICK L. YOUNG and DONNA M. YOUNG, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. CIVIL ACTION - LAW NO. d7J, ;}J..I'-j' G.;;u ~ CHERYL A. GRAY, Defendant JURY TRIAL DEMANDED CIVIL COMPLAINT 1. Plaintiffs Frederick L. and Donna M. Young, husband and wife, are adult individuals residing at 728 South 80th Street, Harrisburg, Dauphin County, Pennsylvania 17111. 2. Defendant Cheryl A. Gray is an adult individual residing at 4618 Oxford Road, Harrisburg, Dauphin County, Pennsylvania 17109. 3. On March 18, 1999, Defendant was the ~wner and operator of a 1994 Buick Sedan, 4, On the aforesaid date, at approximately 11:40 a.m., Defendant backed up her vehicle in the Officers Club parking lot at the Naval Inventory Control Point in Mechanicsburg, Cumberland County, Pennsylvania 17055. 5. At the aforesaid time and date, Plaintiff Frederick Young was walking in the parking lot intending to enter the Officers Club when Defendant backed her vehicle into his left knee. 6. The aforesaid accident occurred solely as a result of the negligence, carelessness and recklessness of the Defendant and was due in no marmer to any act, or failure to act on the part of Plaintiff Frederick Young. Document #: 173973.1 ,~ . - , -~-i:_-! 7. Defendant owed a duty to operate her vehicle in such a way as to not cause harm or damage to said other persons and to Plaintiffs in particular. 8. The negligence, carelessness and recklessness of Defendant consisted of the following: (a) Moving a vehicle when it was not safe to do so in violation of 75 Pa.C.S.A. 93333 and applicable law; (b) Failing to yield the right-of-way to pedestrians in violation of 75 Pa.C.S.A. 93542 and applicable law; (c) Failing to yield the right-of-way to pedestrians in violation of 75 Pa.C.S.A. 93547 and applicable law; (d) Backing her vehicle when it was not safe to do so in violation of75 Pa.C.S.A. 93702 and applicable law; (e) Operating her vehicle in careless disregard for the safety of persons and property in violation of 75 Pa.C.S.A. 93714 and applicable law; (f) Operating her vehicle in reckless disregard for the safety of persons and property in violation of 75 Pa.C.S.A. 93736 and applicable law; (g) Moving or backing her vehicle when her vision may have been obstructed; (h) Moving or backing her vehicle without properly checking for the presence of pedestrians; (i) Leaving a parking spot or parking area without first making sure it was safe to back her vehicle; G) Failing to keep alert and maintain a proper lookout for the presence of pedestrians; (k) Operating her vehicle when she did not have a clear view or where her view may have been obstructed; - 2- DOCllment#: 173973.1 < , ~'''''o. (I) Failing to slow or stop the vehicle she was operating to avoid the collision with Plaintiff Frederick Young; (m) Failing to apply the brakes of the vehicle she was operating or take other evasive action to avoid a collision with Plaintiff Frederick Young; (n) Failing to maintain or control the vehicle she was operating to avoid a collision; (0) Failing to give warning to Plaintiff Frederick Young of her impending collision with him; (P) Failing to keep her vehicle under proper and adequate control so as not to expose Plaintiff Frederick Young to unreasonable risk of harm; and (q) Failing to heed warnings of the impending collision. 9. As a direct and proximate result of the collision and the negligent, careless and reckless conduct of Defendant, Plaintiff Frederick Young sustained personal injuries and damages as more fully set forth herein, 10. The Defendant violated Pennsylvania statutes in effect at the time of the accident and is negligent per se and as a matter oflaw. COUNT I - NEGLIGENCE Plaintiff Frederick Y Dun!!: v. Defendant 11. Paragraphs I through 10 hereof are incorporated herein by reference as if fully set forth. 12. As a direct and proximate result of the collision and the negligent, careless and reckless conduct of Defendant, Plaintiff Frederick Young sustained and in the future may sustain serious and debilitating injuries, some of which are or may be permanent and, which are or may - 3 - Document #: 173973.1 " ~~ , ,-; be an aggravation and/or exacerbation of pre-injury existing conditions, and which include, but are not limited to, the following: (a) Trauma and injury to his left knee; and (b) Trauma and injury to his left hip. 13. As a direct and proximate result of the aforesaid collision, negligence, carelessness and recklessness of Defendant, Plaintiff Frederick Young has underwent significant treatment including left knee surgery, physical therapy and several injections and was forced to incur medical bills and expenses for the injuries he has suffered and will continue to incur medical bills and expenses in the future. 14. As a direct and proximate result of the aforesaid collision, negligence, carelessness and recklessness of Defendant, Plaintiff Frederick Young has suffered and may suffer a loss of earnings, may suffer permanent disability, impairment and/or loss of earning capacity. 15. As a direct and proximate result of the aforesaid collision, negligence, carelessness and recklessness of Defendant, Plaintiff Frederick Young has undergone and in the future wiU undergo great physical pain, mental pain, discomfort, inconvenience, distress, embarrassment and humiliation, present, past and future loss of his ability to enjoy the pleasures oflife and limitations in pursuit of daily activities all to his great loss and detriment. 16. As a direct and proximate result of the aforesaid collision, negligence, carelessness and recklessness of Defendant, Plaintiff Frederick Young has been permanently scarred, deformed and disfigured. -4- Document #: 173973.1 ~ ~.~ '" ~"'i;. 17. As a direct and proximate result of the aforesaid collision, negligence, carelessness and recklessness of Defendant, Plaintiff Frederick Young has sustained incidental costs associated with his injuries including the use of medical appliances and medication expenses. WHEREFORE, Plaintiff Frederick Young demands judgment against Defendant Cheryl Gray for the aforesaid damages in an amount which exceeds the limits of compulsory arbitration in Cumberland County, Pennsylvania, plus interest and/or damages for delay and costs of prosecution. COUNT II - LOSS OF CONSORTIUM Plaintiff Donna M. Y oun!! v. Defendant 18. Paragraphs 1 through 17 hereof are incorporated herein by reference as if fully set forth. 19. During all relevant times, Plaintiff Frederick L. and Donna M. Young were husband and wife and solely as a result of the collision, the aforesaid negligence, carelessness and recklessness of Defendant as a result of the injuries to Plaintiff Frederick L. Young, the Plaintiff Donna M. Young has been deprived of the assistance, companionship, consortium and society of her husband and has lost his services to her all to her great loss and detriment which may continue indefinitely. - 5 - Document #: 173973.1 .illI_~i WHEREFORE, Plaintiff Donna M. Young demands judgment against Defendant Cheryl Gray, for the aforesaid damages in an amount which exceeds the limits of compulsory arbitration in Cumberland County, Pennsylvania, plus interest and/or damages for delay and costs of prosecution. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: ff"" L---" Clark DeVere, Esquire Attorney J.D. No. 68768 3 211 North Front Street P.O. Box 5300 Harrisburg, P A 1711 0-0300 (717) 238-8187 Attorney for Plaintiffs Dated: April n 2000 - 6- Document #: 173973.1 ~" ~ ........M' VERIFICATION I, Frederick L. Young, hereby certify that the following is correct: The facts set forth in the foregoing Civil Complaint are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Civil Complaint is that of counsel and not my own. I have read the Civil Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Civil Complaint is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Civil Complaint are made subject to the penalties of 18 Pa C.S.A, 94904 relating to unswom falsification to authorities. ~. /~ ~. - /: .... '}y' Dated: J.!4;r'j';;'IRWSI ~;,-:/ .' . (f: V Fred ick L. 0 Document #: 173973.1 " .-.. ~, VERIFICATION I, Donna M. Young, hereby certify that the following is correct: The facts set forth in the foregoing Civil Complaint are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Civil Complaint is that of counsel and not my own, I have read the Civil Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Civil Complaint is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Civil Complaint are made subject to the penalties of 18 Pa. C.S.A. 94904 relating to unsworn falsification to authorities. Dated: '-I/J.1/~l7Od j,'t-~m~ Donna M. Yo g Document #: 173973.1 - SHERIFF'S RETURN - OUT OF COUNTY > CASE NO: 2000-02614 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND YOUNG FREDERICK L ET AL VS GRAY CHERYL A 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 GRAY CHERYL A but was unable to locate Her deputized the sheriff of DAUPHIN , to wit: in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT & NOTICE On May 12th , 2000 , this office was in receipt of the 18.00 9.00 10.00 30.50 .00 67.50 05/12/2000 METZGER WICKERSHAM attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep. Dauphin Co County Sworn and subscribed to before me this dVfl:: day of ~ ~tJVi> A. D . 0~ () f1.u;P,~) ~~ Prothonotafy ~" -- ,= '- ~-~ @ffite of tqr ~4~:riff William T. Tully Solicitor Ralph G, McAllister Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin COllllty Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania YOUNG FREDERICK L vs County of Dauphin GRAY CHERYL A Sheriff's Return No. 1039-T - -2000 OTHER COUNTY NO. 00-2614-CIVIL AND NOW: May 5, 2000 at 6:08PM served the within NOTICE & COMPLAINT IN CIVIL ACTION upon GRAY CHERYL A by personally handing to DEFT 1 true attested copy(ies) of the original NOTICE & COMPLAINT IN CIVIL ACTION and making known to him/her the contents thereof at 4079 W TILDEN RD FORREST HILL HBG, PA 00000-0000 Sworn and subscribed to So Answers, JR~ ~.; ~=~~oo PROTHONOTARY By a. Sheriff's Costs: $30.50 PD 05/04/2000 RCPT NO 136528 ET , "!ifil' '. ..,~. otil-t"6fG~mD1'()'J1Pleasof C1Jlriibetlall'dCriuiitY,PennsyIV'~nia . ";~~~~~i~1f!'L'::}i6'6'Bi~;'~tJ;~L ". . ,'_, vs. '" - Cheryl,A:f,iGray...... q.., -. -:',"<< - -+->,:/;S-i"'; ,-' No. 20-2614 Civil Now"". 5/2/00. ';"'''-'. ' '.' , 20 C<' ,1, SHERIFF OF CUMBERLAND COUNTY, P A, do . ,- '--','" . . pereby.depv#~~theSheri.ff of Dauph,in ;---::<~,;:,~,\,~,,-, County to exe.cute this Writ, this dep_oo befug """" "... ""In'" md "'k of'" PI.mtiff. ~ . ~~-:~~, 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 known to the contents thereof. So answers, , Sheriff of County, PA Sworn and subscribed before me this day of 20 '- COSTS SERVICE MILEAGE AFFIDAVIT $ $ ",;",,-, ',-. ,., ' .'"_'-'-"'I'_"'__'"~'~__'"__'c'-{,',,,, , --",-- '-" ,-~' ,,'. " " -""~""Vk,"_,,i;_-;;!,':,- --"-,,0,,',,.,-" ,~,,-..:d,-r. ,--- .;,;; -j";! John A Statler, Esquire Attorney 1 D, No, 43812 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P,O, Box 1268 Harrisburg, PA 17108.1268 Telephone: (717) 234-4161 Attorney for Defendant Cheryl A Gray FREDERICK L. YOUNG and DONNA M, YOUNG, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v, : NO. 00-2614 Civil CHERYL A GRAY, Defendant : JURY TRIAL DEMANDED NOTICE TO PLEAD TO: FREDERICK L. YOUNG and DONNA M. YOUNG, Plaintiffs c/o CLARK DeVERE, ESQUIRE Metzger Wickersham Knauss & Erb, P,C, 3111 North Front Street P,O, Box 5300 Harrisburg, PA 171110-0300 Attorney for Plaintiffs YOU ARE REQUIRED to plead to the within Answer With New Matter within twenty (20) days of service hereof or a default judgment may be entered against you, GOLDBERG, KATZMAN & SHIPMAN, P.c. BY~~ John A S tier, Esquire Attorney I. D, No, 43812 320 Market Street P.O, Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 DATE: (p / /1 J lJI, Attorney for Defendant Cheryl A, Gray j ->-->~~ ,... . . "'~ -', ~ - w,- 'v-~" ' ,:' -k C-_","" ,- --' ',' ,"_t-.__~ ~,,_ '.'" ~,::,;." ",',c-.' '_" "- John A Statler, Esquire Attorney 1. D, No, 43812 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P,Q. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney for Defendant Cheryl A. Gray FREDERICK L. YOUNG and DONNAM. YOUNG, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v, : NO, 00-2614 Civil CHERYL A. GRAY, Defendant : JURY TRIAL DEMANDED ANSWER OF DEFENDANT CHERYL A. GRAY TO PLAINTIFFS' COMPLAINT INCLUDING NEW MATTER AND NOW, comes the Defendant, Cheryl A. Gray, by her attorneys, Goldberg, Katzman and Shipman, P.C., who files the following Answer and New Matter in response to the Plaintiffs' Complaint: 1, Denied. After reasonable investigation, answering Defendant is without information sufficient to form a belief as to the truth or falsity of the averments in this paragraph and, therefore, denies the same and demands strict proof at time of trial if deemed material. 2, Admitted. 3. Admitted, ,'" <'. ,'- ",~ ,h".-" ,,:' "___~_;,;o"'>.C"",,, c' G.;',<, ,~,' -'_",___',~'r -_i,"'"-"_'",,,,~,,<<, ",:lJ.t,.~ ".""-';~'",.:, , ~i 4, Admitted, 5, Denied as stated, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments in this paragraph and, therefore, denies the same and demands strict proof at time of trial if deemed material. 6, The averments in this paragraph constitute conclusions oflaw to which no response is required, In the event a response is deemed to be required, it is denied that the Defendant was negligent, careless and reckless and denied that the alleged accident occurred solely as a result of any negligence, carelessness and recklessness on the part of the Defendant and denied that the accident was due in no manner to any act, or failure to act on the part of Plaintiff Frederick Young. 7. The averments in this paragraph constitute conclusions oflaw to which no response is required, 8. The averments in this paragraph constitute conclusions oflaw to which no response is required, In the event a response is deemed to be required, it is denied that the Defendant was negligent, careless and reckless in: a, moving a vehicle when it was not safe to do so in violation of75 Pa. C,S.A. ~3333 and applicable law; 2 " ,.~" ~ ~, d _ ~_.=_~ _ < ,,- 0"" _,', .'",' , --,'. - S'"""" ',' ,_",~",~",,_C_ I,"", -,,~~''i?--,;-- "-'&"i~-' ~.~,_ ~, '. b. failing to yield the right of way to pedestrians in violation of75 Pa. C,S.A ~3542 and applicable law; c. failing to yield the right of way to pedestrians in violation of75 Pa, C,S.A ~3547 and applicable law; d, backing her vehicle when it was not safe to do so in violation of75 Pa. C.S.A ~3702 and applicable law; e, operating her vehicle in careless disregard for the safety of persons and property in violation of75 Pa, C,S.A ~3714 and applicable law; f. operating her vehicle in reckless disregard for the safety of persons and property in violation of75 Pa, C.S.A ~3736 and applicable law; g, moving or backing her vehicle when her vision may have been obstructed; h, moving or backing her vehicle without properly checking for the presence of pedestrians; 1. leaving a parking spot or parking area without first making sure it was safe to back her vehicle; J, failing to keep alert and maintain a proper lookout for the presence of pedestrians; 3 r!f': ~ ~- -" ~- =___ ___=__ ~F."S_--_ - ,- ~.'" ~--- ~ ,-~,-, - - ~~- ,- , 'm-, _ '. _, k, operating her vehicle when she did not have a clear view or where her view may have been obstructed; I. failing to slow or stop the vehicle she was operating to avoid the collision with Plaintiff Frederick Young; m, failing to apply the brakes of the vehicle she was operating or take other evasive action to avoid a collision with Plaintiff Frederick Young; n, failing to maintain or control the vehicle she was operating to avoid a collision; 0, failing to give warning to Plaintiff Frederick Young of her impending collision with him; p, failing to keep her vehicle under proper and adequate control so as not to expose Plaintiff Frederick Young to unreasonable risk of harm; and q, failing to heed warnings of the impending collision, 9, The averments in this paragraph constitute conclusions oflaw to which no response is required. In the event a response is deemed to be required, it is denied that the Defendant was negligent, careless and reckless and denied that the Plaintiff suffered any injuries and damages as a direct and proximate result of any negligent, careless conduct of the Defendant. 4 ~o_ , "W, -'~-'-- - _ '.-,',- - ''';'' ~- '--" ',"~'.,.,,;.;"~_', ~"" - - ''';'~,"-'''<'-'_rl_''>__' ~ ~;_, 10, The averments in this paragraph constitute conclusions oflaw to which no response is required. In the event a response is deemed to be required, it is denied that the Defendant violated Pennsylvania statutes in effect at the time of the accident and denied that the Defendant is negligent per se and as a matter oflaw. COUNT I (Negligence) PlaintitTFrederick YOInnl!: v. Defendant 11. Defendant incorporates by reference her answers to the averments in paragraphs 1 through 10 of the Plaintiffs' Complaint as if set forth at length, 12, The averments in this paragraph constitute conclusions oflaw to which no response is required, In the event a response is deemed to be required, it is denied that the Defendant was negligent, careless and reckless and denied that the Plaintiff Frederick Young suffered any injuries or damages a direct and proximate result of any negligence, careless and reckless conduct on the part of the Defendant. By way of further answer, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiff s alleged injuries and damages and, therefore, denies the same and demands strict proof at time of trial if deemed material. 5 ~ .,- ,,- , -.', -.,,;',,~.,'-".~~- , .,-~,- ..':,,' ',.'.,' ',;.", .,- -,,~- :.-- .'_. i,~-"", "". '. 13, The averments in this paragraph constitute conclusions oflaw to which no response is required, In the event a response is deemed to be required, it is denied that the Defendant was negligent, careless and reckless and denied that the Plaintiff Frederick Young suffered any injuries or damages a direct and proximate result of any negligence, careless and reckless conduct on the part of the Defendant, By way of further answer, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiff's alleged injuries and damages and, therefore, denies the same and demands strict proof at time oftrial if deemed materiaL 14. The averments in this paragraph constitute conclusions oflaw to which no response is required. In the event a response is deemed to be required, it is denied that the Defendant was negligent, careless and reckless and denied that the Plaintiff Frederick Young suffered any injuries or damages a direct and proximate result of any negligence, careless and reckless conduct on the part of the Defendant. By way of further answer, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiff's alleged injuries and damages and, therefore, denies the same and demands strict proof at time oftrial if deemed materiaL 15. The averments in this paragraph constitute conclusions oflaw to which no response is required. In the event a response is deemed to be required, it is denied that the Defendant was negligent, careless and reckless and denied that the Plaintiff Frederick Young 6 ,-- ~ ,'" ' ,'. .~-"" '-" . -. --""~ ",>&"- ~"'~,-'- ""'~-'--"-;'--;-'"" ,'" --'-'"~""", ~wfC-; '. suffered any injuries or damages a direct and proximate result of any negligence, careless and reckless conduct on the part of the Defendant. By way of further answer, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiff's alleged injuries and damages and, therefore, denies the same and demands strict proof at time of tria! if deemed material. 16, The averments in this paragraph constitute conclusions oflaw to which no response is required, In the event a response is deemed to be required, it is denied that the Defendant was negligent, careless and reckless and denied that the Plaintiff Frederick Young suffered any injuries or damages a direct and proximate result of any negligence, careless and reckless conduct on the part of the Defendant. By way of further answer, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiff's alleged injuries and damages and, therefore, denies the same and demands strict proof at time oOria! if deemed material. 17. The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, it is denied that the Defendant was negligent, careless and reckless and denied that the Plaintiff Frederick Young suffered any injuries or damages a direct and proximate result of any negligence, careless and reckless conduct on the part of the Defendant. By way of further answer, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments concerning the 7 ~, ~~---- n_ _,_' _ . .. --'- _,''0.,_",-", . ~,,-, ','- >,~ . '-",<;,~ ""-$.-, '.,';; -;;1,";',;';'..,--, Plaintiff's alleged injuries and damages and, therefore, denies the same and demands strict proof at time oftrial if deemed material. WHEREFORE, Defendant Cheryl A. Gray respectfully requests that Count I of the Plaintiffs' Complaint be dismissed and that judgment be entered in favor of Defendant Cheryl A. Gray and against the Plaintiff Frederick L, Young, COUNT n (Loss of Consortium) Plaintiff Donna M. Y olln\l v. Defendant 18. Defendant incorporates by reference her answers to the averments in paragraphs 1 through 17 of the Plaintiffs' Complaint as if set forth at length, 19, The averments in this paragraph constitute conclusions of law to which no response is required, In the event a response is deemed to be required, it is denied that Defendant Cheryl A. Gray was negligent, careless and reckless and, therefore, denied that the Plaintiff suffered any injuries as a result of any negligence, carelessness and recklessness on the part of the Defendant. By way of further answer, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiff's alleged losses and damages and, therefore, denies the same and demands strict proof at time of trial if deemed material. 8 M_' " " ~',- ~_.;.., - '~-~--_-~- . __"~_',",_",_" .;;,<., -"".,'." ".--,"-~".-,,,S_',' ,'_"'"_'];0__' WHEREFORE, Defendant Cheryl A. Gray, respectfully requests that Count n of the Plaintiffs' Complaint be dismissed and that judgment be entered in favor of Defendant Cheryl A. Gray and against the Plaintiff Donna M, Young, NEW MATTER By way of additional answer and reply, Defendant Cheryl A. Gray raises the following new matters: 20, Some or all of the Plaintiffs' claims are barred in whole or in part and/or are limited by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa, C,S.A. ~1701, et seq., and, especially by ~~1705 and 1722 of that law. 21. At the time of the subject accident, Plaintiffs Frederick L. Young and/or Donna M, Young were limited tort electors and/or were otherwise bound by the limited tort option, 22, Plaintiff Frederick L. Young has not sustained a "serious injury" as defined by the Pennsylvania Motor Vehicle Financial Responsibility Law, 23, Some or all of the Plaintiffs' claims are barred in whole or in part by the provisions ofthe Pennsylvania Comparative Negligence Law and/or by the Doctrine of Comparative/Contributory Negligence, 9 - < '=- - ,- '''~'---~----' -.. ,';'i-"-~' "'--"~'-"~,-,,",,"',; 0;',,"--1' -~,_ ~'-:":'--"_''''''; ~o.-,.>-, '. WHEREFORE, Defendant Cheryl A Gray respectfully requests that the Plaintiffs' Complaint be dismissed and that judgment be entered in favor of Defendant Cheryl A Gray and against the Plaintiffs, Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. By ~~ Attorney 1. D, No. 43812 320 Market Street p, o. Box 1268 Harrisburg, PA 17108-1268 DATE: (p ( I '1 I ~O Attorneys for Defendant Cheryl A Gray 45197.1 10 , - ~ .', ",,^,- "'~,._~_~ ,""" ,,",' - "'s. '-_Hi'J --,,,,' , '-".,,", -,- _"'~_ -, .> C ",' , _,_,<< _,_ "". _~ ,,"",_,.. _ VERIFICATION I, CHERYL A. GRAY, hereby acknowledge that I am the Defendant in this action; that I have read the foregoing document; and that the facts stated therein are true and correct to the best of my knowledge, information and belief, I understand that any false statements herein are made subject to penalties of 18 Pa, C. S, Section 4904, relating to unsworn falsification to authorities, .~a~ ~. ; . CHKRYLA RAY DATE:7l0'lL. /d., cJOd cJ , ~= " , ~ ii__. ",_ -=.<"","". "0"'''. ^,~,_",,,-',,,;>-__,,"_,_,,;;:'--__--_ - .~'.J"_,-,,,,~- ",--,"-,];', " CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at """ Harrisburg, Pennsylvania, with first-class postage prepaid on the -.1l day of -J f1.1 of 2000, addressed to the following: Clark De Vere, Esquire Metzger Wickersbam Knauss & Erb, P.c. 3111 North Front Street P,O, Box 5300 Harrisburg, P A 171110-0300 GOLDBERG, KATZMAN & SHIPMAN, P.C. BY~~ John A Statler, Esquire Attorney I. D, No. 43812 320 Market Street P.O, Box 1268 Harrisburg, P A 17108-1268 Telephone: (717) 234-4161 Attorney for Defendant Cheryl A Gray .~.-----~-~~- ""........ " '''"''''''"' : - ~, I, ~_~'"' "r,' -~~' -~~ --~~ '. " , -, ,> C::. ~~ -1 , -, ~,p ,_, ~'-"'~_,:"" "... _r~',"~'~_ ",,"__~ n. ~ "" t-, i , _0< , ~ , .--';",',< ...' FREDERICK L. YOUNG and DONNA M. YOUNG, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiffs vs. CIVIL ACTION - LAW NO. 00-2614 CHERYL A. GRAY, Defendant mRY TRIAL DEMANDED PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER 20. Conclusions of law, no reply required. If a reply is required, the averments are denied pursuant to Pa.R.C.P. No. 1029(e). By way of further reply, Defendant does not specifY how Plaintiffs' claims are barred in whole or in part and/or are limited by the MVFRL and therefore no reply is required. 21. Conclusions of law, no reply required. If a reply is required, the averments are denied pursuant to Pa.R.C.P. No. 1029(e). By way of further reply, there was no proper election since there was no limited tort election form dated by my clients. Furthermore, Plaintiff Frederick Young sustained a "serious injury" and was a pedestrian at the time of the accident, 22. Conclusions of law, no reply required. If a reply is required, the averments are denied pursuant to Pa.R.C.P. No. 1029(e),By way of further reply, Plaintiff has suffered a "serious injury" as defined by the MVFRL and interpreting case law. 23. Conclusions of law, no reply required. If a reply is required, the averments are denied pursuant to Pa.R.C.P. Nos, 1029(e) and 1030(note). Moreover, Defendant has failed to specifY how Plaintiffs are negligent. Document #: 178103.1 ,l -"- - ,--.-,'" o~ , ,;".'~ WHEREFORE, Plaintiffs demand that Defendant's New Matter be dismissed and that judgment be entered in their favor and against Defendant for the damages claimed in the Complaint filed in this action plus interest and/or damages for delay and costs of prosecution. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: ~---, Clark DeVere, Esquire Attorney I.D, No. 68768 3211 North Front Street P.O. Box 5300 Harrisburg, P A 17110-0300 (717) 238-8187 Attorney for Plaintiffs Dated: June ;;'1:. 2000 -2- Document #: 178103.1 "''''''' - ,,~- '.,-. -~ ~ VERIFICATION """"""". , I, Frederick L. Young, hereby certify that the following is correct: The facts set forth in the foregoing Plaintiffs' Reply to Defendant's New Matter are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Plaintiffs' Reply to Defendant's New Matter is that of counsel and not my own. I have read the Plaintiffs' Reply to Defendant's New Matter, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Plaintiffs' Reply to Defendant's New Matter is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Plaintiffs' Reply to Defendant's New Matter are made subject to the penalties of 18 Pa. C.S.A. g4904 relating to unswom falsification to authorities. Dated: June 26, 2000 Document #: 178103.1 -~ - ~ -. ... .., VERIFICATION I,DonnaM. Young, hereby certifY that the following is correct: . The facts set forth in the foregoing Plaintiffs' Reply to Defendant's New Matter are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Plaintiffs' Reply to Defendant's New Matter is that of counsel and not my own. I have read the Plaintiffs' Reply to Defendant's New Matter, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Plaintiffs' Reply to Defendant's New Matter is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Plaintiffs' Reply to Defendant's New Matter are made subject to the penalties of 18 Pa. C.S.A. ~4904.relating to unswom falsification to authorities. J:t t7?vY7A_mJ~ Donna M. Young Dated: June 26, 2000 Document #: 178103.1 - _.. '-"-~ . , '.~ ~"". <'"'" " '" ,~" "-"'; , , CERTIFICATE OF SERVICE I, Clark DeVere, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and correct copy of Plaintiffs' Reply to Defendant's New Matter with reference to the foregoing action by first class mail, postage prepaid, this .,tli>l<cray of June, 2000 on the following: Cheryl A. Gray, Defendant c/o Jolm Statler, Esquire Goldberg, Katzman & Shipman, P.C. P.O. Box 1268 Harrisburg, PA 17108 METZGER, WICKERSHAM, KNAUSS & ERB, P .C. :.-~ ~ Clark De V ere, Esquire Document #: 178103.1 ~-I . . CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL GRAY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 Kes on behalf of JOHN STATLER, ESQ. defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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 the certificate, (3) 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 the notice of intent to serve the subpoena. s~ DATE: 07/31/2000 JOHN STATLER, ESQ. Attorney for DEFENDANT DEll-197900 32938-LOl - " " "". w COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Ul THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL GRAY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS DR. WILLIAM H. MILLER MOTORIST MUTUAL MEDICAL INSURANCE TO: CLARK DEVERE, ESQUIRE MCS on behalf of JOHN STATLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/11/2000 MCS on behalf of JOHN STATLER, ESQ. Attorney for DEFENDANT CC: JOHN STATLER, ESQ. - 22740-938 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-lZ7282 3Z938-COl - .' ,..;; ~ ~,~~~ COMMON"Vv"EAL TH OF PENNSYLVANIA COUNTY OF CUMBERLAND FREDERICK L. YOUNG AND DONNA M. YOUNG VS File No. 00-2614 CIVIL CHERYL A. GRAY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: DR. WM. MILLER (Same of Person or Entity) ""'jthin tv,..enty (20) days after sen'ice of this subpoena, you are ordered by the court to produce the foHowing documents or things: ~ 1''1': A TT Af~I11':n at MCS GROUP INC., 1601 MARKET STREET, #800, PHILADELPHIA, PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena. together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek. in advance,the reasonable cost 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 FOLLOY\'ING PERSON: NAME: JOHN A. STATLER, ESQUIRE . ADDRESS:320 MARKET STREET HARRISBURG, PA 17108-1268 TELEPHONE: (215) 246-0900 SUPREME COURT lD ;;: A TIORNEY FOR: THE DEFENDENT DATE: ~uly '7.::2..000 . Prothonotary/Clerk. Civil D" on '-- ~O/k" _ P ~m/)..rl' J Dep . ~ Seal of the Court ".-, "-, . EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. WILLIAM H. MILLER 121 NYES ROAD HARRISBURG, PA 17112 RE:32938 FREDERICK LEWIS YOUNG Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: FREDERICK LEWIS YOUNG , Social Security #: 192-30-1548 Date of Birth: 12-18-1939 SUlO-257562 32938-LOl ~" - ~ ~ I&- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL GRAY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOHN STATLER, ESQ. defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attacbed thereto was mailed or delivered to each party at least twenty 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 the certificate, (3) 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 the notice of intent to serve the subpoena. DATE: 07/31/2000 JOHN STATLER, ESQ. Attorney for DEFENDANT DEll-197901 32938-L02 [ " "~~ " ,"y ~Y.il"L COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL GRAY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS DR. WILLIAM H. MILLER MOTORIST MUTUAL MEDICAL INSURANCE TO: CLARK DEVERE, ESQUIRE MCS on behalf of JOHN STATLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/11/2000 MCS on behalf of JOHN STATLER, ESQ. Attorney for DEFENDANT CC, JOHN STATLER, ESQ. - 22740-938 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-127282 32938-COl . , ,-_........ COMMONYVEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FREDERICK L. YOUNG AND DONNA M. YOUNG VS File No. 00-2614 CIVIL CHERYL A. GRAY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: MOTORISTS INSURANCE CO. (Name of Person or Entit)'} Within tv."enty (20) days after sen'ic:e of this subpoena. you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC., 1601 MARKET STREET, #800, PHILADELPHIA,PA 19103 (Address) You may deHver or mail legible copies of the documents or produce things requested by this subpoena. together with the certificate of compHance, to the party making this request at the address listed above. You have the righl to seek. in advance. the reasonable cost of preparing the copies or producing the things sought. If you fail 10 produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving th.is subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOYVING PERSON: NAME: JOHN A. STATLER, ESQUIRE ADDRESS: 320 MARKET STREET HARRISBURG. PA 17108-1268 TELEPHONE: (215) 246-0900 SUPREME COURT 10 ii: A ITO&'1EY FOR: THE DEFENDENT DATE: ..JuJ 1 -^J ;lOon , ProthonotaryfOe:rk, G\'iI Divis' an~p ,P ?J{'!?/U~J Depu. <....... Seal of the Court w..~ ,~ c -',- ".,' - ", o. EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MOTORIST MUTUAL 2674 MONROEVILLE BL YD. MONROEVILLE, PA 15146 RE: 32938 FREDERICK LEWIS YOUNG CLAIM NO. 3-440773 1ST PARTY BENEFITS RECORDS Any and all claims files. Dates Requested: up to and including the present. Subject: FREDERICK LEWIS YOUNG , Social Security #: 192-30-1548 Date of Birth: 12-18-1939 Date of Loss: 03/18/1999 SUI0-257564 32938-L02 ~1ill~lilli'rIllJ!lo!i?!~ljf~BlMill;ti;il~iW.i\iil~~~~'~""iY-""1i~M_-~. ,~ ....;.,,;," .._1, ,~, .~. ~" .- .'-" ',"'-,,~ " ~, ". ,,',,'.. .c, ~",,, " _.. ~" <"__ ,0 '" "-.'>o;~ , '"~~~ '._, ,"<. N ill \; I ! '! '--;: i;: l" Ii: ii' f' I Ii! ii' i" " ! [ii r:: ~, I" '" i ~: ~ i' " n 0 0 ~ 0 -11 "" ,.., ~~ c:: I-n ::0 ,., f'np Zi:;;: I -om -.....'0 (F> " .;:- '~C ~-.-.. 0 .' ~B -0 -\..j? ~g :ll: i5:i\ -...0 )>' c- orn .. ~ ~ c.> "< "' ~.- Li J.",-, . CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL GRAY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOHN STATLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/01/2000 n~~on.Jh~_.of ~~~~;;~ESQ. Attorney for DEFENDANT DEll-215971 32938-L03 " .c' < -, .. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -vs- CASE NO: 00-2614-CIVIL GRAY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ALAN D. ROUMN, M.D. MEDICAL TO: CLARK DEVERE, ESQUIRE MCS on behalf of JOHN STATLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may he served. Complete copies of any reproduced records may be ordered at your.expense by completing the attached counsel card and returning same to MCS or by contacting our 10cal MCS office. DATE: 10/12/2000 MCS on behalf of JOHN STATLER, ESQ. Attorney for DEFENDANT CC: JOHN STATLER, ESQ. - 22740-938 Any questions regarding this matter, contact THE MCS GROUP IRC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-134491 32938-COl ~ - ~~ "- ' ,.- '~I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FREDERICK L.YOUNG AND DONNA M. YOUNG VS CHERYL A. GRAY File No. 00-2614 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: DR. ALAN ROUMM (Name of Penon or Entity)- Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the foJlowing documents or things: SF.F. ATTAr.HF.D at MCS GROUP INC,1601 MARKET ST., #800, PHILA.,PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost 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: !\'AME: JOHN A. STATLER. ESO. ADDRESS: 320 MARKET ST.PO BX 1268 HARRISBURG, PA 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID It: ATTORNEY FOR: 'I'HF nFFF1\11)AN'I' DATE: rJJnltwr 9, Jom Seal of the.Court (Eff. 7/97) .~ "", - , - EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALAN D. ROUMN, M.D. 650 POPLAR CHURCH RD. CAMP HILL, PA 17011 RE: 32938 FREDERICK LEWIS YOUNG Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consUltation, care or treatment. Dates Requested: up to and including the present. Subject: FREDERICK LEWIS YOUNG 728 S. 80TH STREET, HARRISBURG, PA 17111 Social Security #: 192-30-1548 Date of Birth: 12-18-1939 SUI0-271068 3293B-L03 ~lil_.ilililillidillJliliilliillifjj~"!i:~lli~llIlU~l~i!l~-~;:;l<<I/;~"';" -~=~"""""&' ~~ "L_ ,,,__,,,,_~,>,,_~",,, ,~ ilillollllil;;l =-~--.,'" _ '_' _,' ^' _ _'- ~. ,.,-f 1Ii"'~""""'-_'" .. 8 C> 0 s: 0 'I'I ;i{m 2: m a ~?j '''!:;: ;d , CD:?: Co J l::i -<;z ~C) :r;-.... --~;~) ;C;C) . ;, ~<) ~ ~~~ c co C),n ~ s;-! <.11 Xl -< "',,'C_ ._,,_ _,H "co>!?,-' .,~< =',=." __~~_~ l I I I I " .'" .~ ,.,. .~ , ~-~ .' ~ ~, .'~: ." h CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOEllA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS FREDERICK L. YOUNG & DONNA M. YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL CHERYL A. GRAY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOHN A. STATLER, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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, and (4) The subpoena which will be served I. Identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 11/27/2000 a3../~~f ~ A. STATLER, ESQUIRE Attorney for DEFENDANT DEll-220951 43895 -LOl ~. "~, CO~ONWEA.LTH OF PENNSYLVANIA. COUNTY OF CUMBERLAND III TIIIB MATTEB. 0': COURT 0' COMMOB PLEAS PBEDElUCK L. YOUNG (, DOBHA K. YOUNG TEllM., -VS- CASE BO: 00-2614-CIVlL CBEllYL A. GRAY NOTICE OF INTElf'r TO SERVE A SUBPOENA TO PRODUCE DOl;uJlJlSIlI"rS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DB.. B.OBEB.T L. GREElI DB..'S O'BB.YAN.LEISURE,WIllEBURG DB.. IIEVIlI BLACK MImlCAL MImlCAL MImlCAL TO: CLAllI: DEVEBE, ESQUIRE MCS on behalf of JOHN A. STATLER, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frOB the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty'day notice period is waived or if no objection is made. then the subpoena may be served. Complete copies of any reproduced records may be ordered at your ezpense by completing- !the attached counsel card and returning same to KCS or by contacting our local MCS office. DATE: 11/06/2000 KCS on behalf of .JOHN A. STATLER. ESQUlU Attorney for DEP'ENDAft CC: .JOIIII A. STA1'LBR. ESQUIRE - 22740-938 Any questions regarding this matter, contact TIlE KCS GROUP IBC. 1601 MAllDT STREET #800 PHILADELPHIA. PA 1910) (215) 246-0900 DE02-136728 43 S 9 5 - C 0 1. , _H~ , "",,~'. 0 - .' ",,,r_,, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND YOUNG VS File No. 00-2614-CIVIL GRAY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 . TO: CUSTODIAN OF RECORDS FOR: DR. ROBERT L. GREEN, D.O./DR.MICHAEL J. WOOD (Name of Penon or Entity) 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 MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103" (Ad_.) 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 requlred by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: JOHN A. STATLER, ESQ. 320 MARKET ST. 'RAllll,!,~lUTVr-. VA 171ns:t TELEPHONE: 215-246-0900 SUPREME COURT 1UI; ATTORNEY FOR: DEFENDANT D ATE: 71 N ,;.....};.u... ,}. .2 o-uo BYTHECOU~ rh . :t'-;""thon~ ~ Olvi.ion r;. '{". (J 1l.1 Jilt) .~ , Deputy Seal of the Court (Eff. 7/97) '~"" EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. ROBERT L. GREEN ARLINGTON ORTH. CLINIC 875 S. ARLINGTON AV. HARRISBURG, PA 17109 RE: 43895 FREDERICK LEWIS YOUNG ALSO ANY AND ALL RECORDS FROM DR. MICHAEL J. WOOD. Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: FREDERICK LEWIS YOUNG , Social Security #: 192.30-1548 Date of Birth: 12-18-1939 SUI0-275480 43895-LOl ~_. ~-,,-, .. A.. - i/!im#~r CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS FREDERICK L. YOUNG & DONNA M. YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL CHERYL A. GRAY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOHN A. STATLER, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 11/27/2000 JOHN A. STATLER, ESQUIRE Attorney for DEFENDANT DEll-220952 43895 -L02 , ~ - , ,,~ CO~ONWEA.LTH OF PENNSYLVANIA COUNTY OF CUMBERLAND III TIlE MATTER OF: COURT OF COMMOII PLEAS FREDERICK L. YOUNG Ii DOIIIIA K. YOUNG TEBK. -VS- CASE 110: 00-2614-CIVIL CHERYL A. GRAY NOTICE OF UI'J:JS1\I1' TO SERVE A SUBPOENA TO PRODUCE DOCtJllBN'rS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DR. ROBERT L. GllEEII DR. 's 0' BRYAlI, LEISUIlB, WIllEBURG DR. IEVDf BLACX MEDICAL MEDICAL MEDICAL TO: CLARK DEVERE, ESQUIRE MeS on behalf of JOBII A. STATLBll. ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in whicb to file of record and serve upon the undersigned an objection to the subpoena. If the twenty. day notice period is _ived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning sane to MeS or by contacting our local MeS office. DATE: 11/06/2000 MeS on behalf of JOBII A. STATLBll, ESQUIRE Attorney for DEPEllDANT cc: JOBII A. STA'fLD.. ESQUIRE - 22740-"8 Any questions regarding this matter, caatact TIlE MeS GROUP DC. 1601 MA1lDT STRD'i' #800 PBILADELPBIA, PA 19103 (215) 246-0900 D802-136728 4389S-COl !-.i, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND YOUNG VS FileNo. 00-2614-CIVIL GRAY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 . TO: CUSTODIAN OF RECORDS FOR: DR. O'BRYAN; DR. LEISURE; DR.WINEBURGH, LEBANON VA MEDICAl (Name o{Pelson or Entity) CENTEF Within twenty (20) days after service of this subpoena, you~ ordered by the courlto produce the foUowing documents or things: SEE ATTACllED at MCS GROUP INC., 1601 MARKET ST., 1/800,PHILA.,PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or produdng 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 connply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JOHN A. STATLER, ESQ. ADDRESS: 320 MARKET ST. PAl'n~i''''(;'. i'A 1710S TELEPHONE: 215'-246-0900 SUPREME COURT IIU; ATIORNEY FOR: DEFENDANT DATE: nrl~~.:J. ,;)fJ7J"l) BY TYlE COUp: ~ r1n-r..J~' t... yo Protho..otaIy. edcf'Clvll Division q'-Y-L a. 'fro d;L ./ Deputy Seal of the Court (Ef( 7/<fT) - ',. ~^ ......"-.~l.;;..i EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR.'S O'BRYAN,LEISURE,WINEBURG LEBANON VA MEDICAL CENTER 1700 S. LINCOLN AVE. LEBANON, PA 170427597 RE: 43895 FREDERICK LEWIS YOUNG Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: FREDERICK LEWIS YOUNG , Social Security #: 192-30-1548 Date of Birth: 12-18-1939 SUlO-275482 43895-L02 - ":b.::-i'J.i1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS FREDERICK L. YOUNG'& DONNA M. YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL CHERYL A. GRAY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOHN A. STATLER, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 11/27/2000 JOHN A. STATLER, ESQUIRE Attorney for DEFENDANT DEll-220953 43895-L03 -, ....... a>',*, CO~ONWE.ALTH OF PENNSYLVANIA. COUNTY OF CUMBERLAND DI THE MATTER OF: COURT OF COMMON PLEAS FREDERICK L. YOUNG I< DONNA M. YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL CHERYL A. GRAY NOTICE OF INTENT 'l'O SERVE A SUBPOENA 'l'O PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURsUANT 'l'O RULE 4009.21 DR. ROBERT L. GREEN DR. 's O'BRYAN,LEISURE,WINEBURG DR. KEVIN BLACK MEDICAL MEDICAL MEDICAL TO: CLARK DEVERE, ESQUIRE MCS on behalf of JOHN A. STATLER, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty. day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/06/2000 MCS on behalf of JOHN A. STATLER, ESQUIRE Attorney for DEFEJIDANT CC: JOHN A. STATLER, ESQUIRE - 22740-938 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-136728 43895-COl - '. ~-, ~"~."""'"h COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND YOUNG VS File No. 00-2614-CIVIL GRAY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 . TO: CUSTODIAN OF RECORDS FOR: DR. KEVIN BLACK, HERSHEY MEDICAL CENTER (Name of P......n or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doc:uments or things: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800, PHlLA.,PA 19103 (Add...., Vou may deliver or mail legibte copies of the doc:uments or produc:e things requested by this subpoena, together with the certificate of compliance, to the party making this request at the addrfts listed above. Vou have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the doc:uments 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 <CIon'" with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF mE FOLLOWING PERSON: NAME: ADDRESS: JOHN A. STATLER, ESQ. '320 MARKET ST. lfA'DDT'i!"RTTDr:!~ pj 17109 TELEPHONE: 215-246-0900 SUPREME COURT.1e ATIORNEY FOR: DEFENDANT DATE: 7Un~:l .2 o-W , BY~OU~: L;, _.' Prothonotaay~~CiVI1 Division ~u I . (} 71,.1/.._. Deputy Seal of the Court (Eff. 7/97) ". """,",--,,-- EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. KEVIN BLACK PENN STATE SPORTS MEDICIN 500 UNIVERSITY DR. HERSHEY, P A 17033 RE: 43895 FREDERICK LEWIS YOUNG Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: FREDERICK LEWIS YOUNG , Social Security #: 192-30-1548 Date of Birth: 12-18-1939 SUlO-275484 4389S-L03 ~ij~lfJlJl~illi\i;..IIlfifr-tlliliii;ll$ali!lj;jMlIt",~L'Il;itli,'lIo'-'-'- "";,~"'''''-Al~,llli<i3llliiii"cl~~~13;iU!l'''''IoH:ll,;@-~''''''' ~,','~ J l~~ ~~ ~,~ _. LH ~~ 0 > ~-- '"iii ~ . !oJ ~~IlIIid.Ui~~ ... . -... - 'I I I II [I II , -0 0 0 ~ 0 ." -U- ;;e: ~ :::;1 ~U' 0 rn <<:: - fr12! :'D :g;S; w ;:Q,hn -<4:::: 0 ~..l_.'? j('-l .r=0 :':::?j~oo) ~ ;bio 2:0 3: ~~ --0 9 Pc:: ~ Ul 't;! fA :v -< . , "., o ~"~_ .; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY YOUNG . VEL GRAY NO. 002614 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 APRIL STRANG-KUTAY, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). r< 2/7/01 / (, ,. \t.V~- l ic7...t >(;;/Jl<).....,:~:::c/)~" ~~~ I. /, ~\ ! t'.'.t/'X."."/ jI \ / ~" \ ./ '>""" ~Q File #: M270951 " ,';'<,;. \h APRIL STRANG-KUTAY, ESQUIRE GOLDBERG KATZMAN & SHIPMAN PO BOX 1268 HARRISBURG, PA 17108 717-234-4161 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3590 By: Christine Janiszewski " "-. "'-- <'" '" - '" . -- 0 'J > ~-. Ollr-". IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY YOUNG . . Va. GRAY No. 002614 TO: CLARK DEVERE, ESQ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVlERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 1/16/01 APRIL STRANG-KUTAY, ESQUIRE GOLDBERG KATZMAN & SHIPMAN PO BOX 1268 HARRISBURG, PA 17108 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO. MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 By: Christine Janiszewski Enc(s): Copy of subpoena(s) Counsel return card File #: 11270951 OHf)NNEALTH OF PmNSYLVANIA cnJNl'Y OF CllMBlmAND YOUNG ,,{S. 002614 File No. GRAY SUBPOENA TO PROOUcE DOC:1.t'ENTS OR lli I NGS FOR 0 I SOOVERY ~SUANT TO RULE 4009.22 TO: DR WILLIAM RICHWINE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doc:unent!l or things: **SEE ATTACHED ADDENDUM** d . Inc 4940 D'sston ~t ~n~la FA 1~13S Medical Legal Repro uct~ons . at (Address) You may deliver or mail legible copies of the docunents or produce things requested b) this subpoena, together with the certificate of carpliance, to the party making thi" request at the address listed above. You have the right to seek in advance the rea~.onab le cost of preparing the copies or producing the things sought. If you fail to produee the docunents or things required by this subpoena within tli'lenty (20) days after its serv~ce, the party serving thi5 subpoena may seek a court orde'- carpe 11 ing you to carp ly with it. llilS SUBPOENA WAS ISSUED AT 1liE REQUEST OF 1liE FOLLONING PERSON: APRIL STRANG-KUTAY, ESQ AOORESS:PO BOX 1268 -HARRISBURG PA 17108 NAI'E : (215) 335-3212 TELEPH:lNE: SlPRe-E G(UlT 10' ATTORNEY FOR: DEFENDANT DATE~-O{ Sea 1 of the Court y (Eff. 1/97) - ~ '~ ,eU ADDENDUM TO SUBPOENA YOUNG vs. No. 002614 GRAY CUSTODIAN OF RECORDS FOR: DR WILLIAM RICHWINE ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: FREDERICK L YOUNG ADDRESS: 728 S 80TH ST HARRISBURG PA DATE OF BIRTH: 12/18/39 SSAN: 192301548 CERTIJ<lED PHOTOCOPIES OF THE RECORDS WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. County of: CUMBERLAND MLR File #: M270951-01 .-~ jj~~rlIiiIll~liilriJ:illlitll~ldil~21i~!iillll"li.m'~~R!W~!I.rll=Jil>>il~~iill---: ,.... '."" ,..~,,~,.1 ~~1. ~ 1. ~_~".~'" ~ _, n-' .-., " ~.I ~ .'.'_ _~.~ ,_. --.'" ~'-'-.idI'''' -"" ,~~_',J'" ~~ ....... ~ , 0 ~-, ....._,/ ~? c: ."0 u-' "Tj SP '~'1 1.-_.:; Zr' tv T (75 . G) , ; ~ "- ," , ! ) .:::::::: ., J" ., ?:(-',; () p(~ (=-j~--fl ;,::; ':AI 5J =::; 'D ;:JJ -< .~, .1 '-~ - "~= II' PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE POOTHOOOTARY OF CUMBERLAND COUNTY Please list the fallowing case: (Check one) x for JURY trial at the next tenn of civil court. for trial without a jury. ----------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (check one) FREDERICK L. YOUNG and DONNA M. YOUNG, ( X ) Civil Action - Law Appeal from Ami tration (other) ( plaintiff) vs. CHERYL A. GRAY The trial list will be called on 04/03/01 and Trials commence on April 30, 2001 (Defendant) Pretrials will be held on April 11, 2001 (Briefs are due 5 days before pretrials. ) vs. (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No. 2614 Civil Action - Law XlI 2000 Indicate the attorney who- will try case for the party who files this praecipe: Clark DeVere, Esquire, c/o Metzger, Wickersham, Knauss & Erb, P.C. P.O. Box 5300, Har,isburg, PA 17110-0300; Counsel for Plaintiff(s) Indicate trial counsel for other parties if known: John A. Statler, Esquire, c/o Goldberg, Katzman & Shipman, P.C., 320 Market Street, Strawberry Square, P.O. Box 1268, Harrisburg, PA 17108-1268; Counsel for Defendant This case is ready for trial. Signed: ~ -:;--., Print Name: Clark DeVere, Esquire Date: ,,2/018/01 , Attorney for: Plaintiffs 1!ItI!II!_~I.I~~IIiilII~"U!iilrllffi-~""- <-~'. '''':~;''':I-""",""",,,""",,,;iI:>.'/il'''''-''iill!l_~~l8ild.Iiilll_' """~ - - ~= ~, ~ --, '" - _,,"__ _~__<,A,""", ,j",~ ~". jW"~ L !i I r iMlIO I' ii i~ 1-: i:! r; Ii 0 a c = -,e -::.;,- .-''''' -0 0= ::-:,-~ r:; :;>:::; Z 1:.: u , 2~ (/.'J ~, C -' ~i: -0. -:7 (~! ...n )::- Q ':? '-- -,j z ~0 --I :0 -< 0 -< ... ..~" ,~ ", --~"-~, I CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL GRAY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOHN STATLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 03/05/2001 lf of JOHN STATLER, ESQ. Attorney for DEFENDANT DEll-238336 32938 -LO 4 .. 'llIlc'" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL GRAY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 COHMllNITY IMAGING ASSOCIATES COHMllNITY GENERAL HOSPITAL PENN ST. GEISINGER PENN ST. GEISINGER VA MEDICAL CENTER X-RAY OIlLY X-RAY OIlLY X-RAY OIlLY X-RAY OIlLY X-RAY OIlLY TO: CLARK DEVERE, ESQUIRE MCS on behalf of JOHN STATLER, ESQ. intends to serve a suhpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/12/2001 MCS on behalf of JOHN STATLER, ESQ. Attorney for DEFENDANT CC: JOHN STATLER, ESQ. - 22740-938 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-144927 32938-COl -- .-" j~ COMMONWEAL T..H OF PENNSYLVANIA . COUNTY OF CUMBERLA.."iD YOUNG VS File No. 00-2614-CIVIL GRAY SUBPOENA TO PRODUCE DOCUME.~lS OR THINGS FOR DISCOVERY PURSUA..1'I.ol TO RULE 4009 .,., TO: CUSTODIAN OF RECORDS FOR: COMMUNITY IMAGING ASSOCIATES (Name of Person or E..'"'lti~.) v\"ithin rv-'e:"l~' (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE A TT ACHED MCS GROUP INC.,1601 MARKET ST., #800, PHILA.,PA 19103 at (Addr...) You may deiiyer or mail legible copies of the documents or produce tlUngs requested by this subpoena. together with the certificate a: compliance, to the party making this request at the address listed above. You have the right to .eek, in ad,'ance. the "",sonable cost of preparing the copies or producing the tlUngs sought. If you fail to ?=,oduce the documents or things required by this subpoena. ",'itr.m twenty (20) cays after its sen.-ice, the party sen.'ing this s\:bpoena may seek a court order compelling you to comply with it. THIS SLllPOENA WAS ISSUED ATTIJ:E REQUEST OF THE FOLLOWING PERSON: NAME: TOHN S1'A1'T RR RSO ADDRESS: 320 MARKET ST., PO BX 1268 HARRTSBllRG. PA 17108 TElEPHO~~ 215-246-0900 SUPREME COURT ID #: AITOR.'\EY FOR:Di"i~TDH'T BY THE COURT: DATE: ~.J ,?, 02M'/ Deputy Seal of the Court (Efr. 7/97) 0- ~, "0 ll,;.k, EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMUNITY IMAGING ASSOCIATES 865 S. ARLINGTON AVENUE HARRISBURG, PA 17109 RE: 32938 FREDERICK LEWIS YOUNG ANY AND ALL ACTUAL FILMS OF MRI - L KNEE, DATED 5/18/99. Any and all X-Rays pertaining to patient. Dates Requested: up to and including the present. Subject: FREDERICK LEWIS YOUNG 728 S. 80TH STREET, HARRISBURG, PA 17111 Social Security #: 192.30.1548 Date of Birth: 12-18-1939 SUlO-290052 32938 -LO 4 .. ; ~ ~ ....,k. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL GRAY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOHN STATLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/05/2001 JOHN STATLER, ESQ. Attorney for DEFENDANT DEll-238337 32938-LOS ,',-. J' ,L COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -vs- CASE NO: 00-2614-CIVIL GRAY NOTICE OP INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS POR DISCOVERY PURSUANT TO RULE 4009.21 COHMllllITY IMAGING ASSOCIATES COMHllNITY GENERAL HOSPITAL PENN ST. GEISINGER PENN ST. GEISIHGE1I. VA MEDICAL CENTER X-RAY ONLY X-RAY ONLY X-RAY ONLY X-RAY ONLY X-RAY ONLY TO: CLARK DEVE1I.E, ESqUIRE KCS on behalf of JOBH STATLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frOlll the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to KCS or by contacting our local KCS office. DATE: 02/12/2001 KCS on behalf of JOHN STATLER, ESQ. Attorney for DEFEHDART CC: JOBH STATLER, ESQ. - 22740-938 Any questions regarding this matter, contact THE KCS GROUP IRC. 1601 IfARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-144927 3293S-COl ~ _m'_ "~'-X-"'M~: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLA..."iD YOUNG VS File So. 00-2614-CIVIL GRAY SUBPOENA TO PRODUCE DOctJME.'\-rS OR THINGS FOR DISCOVERY PURSUA.I\-r TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: COMMUNITY GENERAL OSTEOPATHIC HOSPITAL (Name of Penon or' Etltity) Within twen~' (20) days after service of this subpoena, you are ordered by tht! court to produce the following documents or things: SEE ATTACHED MCS GROUP INC.,1601 MARKET ST., #800, PHILA.,PA 19103 at (Addffils) You may deii"'r or mail legible copies of the documents or produce things re<;uested by this subpoena. together with the certificate o! compliance, to the party making this request at the address listed .above. You ha\'e the right to seek. in ad,'ance.the ,...onable cost of preparing the copies or producing the things sought. I !! I I I I I I If you fail tc roduce the documents or things required by this subpoena.. ~'it.\....in twenty (20) days after its service, the party ser\'ing this s-..:opoena may seek a court order compelling you to comply ",;th i:... THIS SLllPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: SAME: TORN S'1'A'1'T FR FSO ADDRESS: 320 MARKET ST., PO BX 1268 llARRTSl\URG. FA 17108 TELEPHOSE: 215-246-0900 SUPREME COURT ID #: ATTOR.-;EY FOR:m,H~'Dn''1' BY THE COURT: DATE: r:h~. .5 ;::;a:J / Deputy Seal of the Court (Eff i /97) ~~ ,- ;~~~ EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMUNITY GENERAL HOSPITAL 4300 LONDONDERRY RD. P.O. BOX 3000 HARRISBURG, PA 17105 RE: 32938 FREDERICK LEWIS YOUNG ANY AND ALL ACTUAL FILMS, PLAIN RADIOLOGY VIEWS R & L KNEE ON 2/5/97. Any and all X-Rays pertaining to patient. Dates Requested: up to and including the present. Subject: FREDERICK LEWIS YOUNG 728 S. 80TH STREET, HARRISBURG, PA 17111 Social Security #: 192-30-1548 Date of Birth: 12-18-1939 SUI0-2900S4 32938-LOS ,~ .~ - ".roi;'h_i CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL GRAY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOHN STATLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03{05/2001 JOHN STATLER, ESQ. Attorney for DEFENDANT DEll-238338 32938 -L06 . , ~ """"cl_ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -vs- CASE NO: 00-2614-CIVIL GRAY NOTICE OF INTENT '1'0 SERVE A SUBPOENA '1'0 PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUART '1'0 RULE 4009.21 . COMMllHITY IMAGIlIG ASSOCIATES COMMllHITY GENERAL HOSPITAL PENH ST. GEISIlIGER PENH ST. GEISIlIGER VA MEDICAL CERTER X-RAY ONLY X-RAY'ONLY X-RAY ONLY X-RAY ONLY X-RAY ONLY TO: CLARX DEVERE, ESQUIRE MCS on behalf of JOHN STATLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days fram the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena _y be served. Complete copies of any reproduced records _y be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/12/2001 MCS on behalf of JOHN STATLER, ESQ. Attorney for DEPERDAIIT CC: JOHN STATLER, ESQ. - 22740-938 Any questions regarding this _tter, contact THE MCS GROUP IlIC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-144927 3293 a - C 0.1 - --.~ - ., " ,:,_",',-, COMMONWEAL T,H OF PENNSYLVANIA COUNTY OF CUMBERLA...'iD YOUNG VS file So. 00-2614-CIVIL GRAY SUBPOENA TO PRODUCE DOCUME.,."lS OR THINGS FOR DISCOVERY PURSUA..'l TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: PENN STATE GEISINGER {Namr of Penon or E.."'ltiry) v\'!hhin twen::" (20) days after sen'ice of this subpoena. you are ordered. by th~ court to produce the following documents or things: SEE ATTACHED MCS GROUP INC.,1601 MARKET ST., #800, PHILA.,PA 19103 at (Addns.) You may deih.er or mail legible copies of the documents or produce things re-quested by this subpoena. together with the certificate of compliance. to the party making this request at the address listed above. You ha\'e the right to seek, in advance, the ",..onable cost of preparing the copies or producing the things sought. 1I you fail to ?,="oduce the documents or things required by this subpoena.. ""it:-..in twenty (20) cays after its ser\'ice, the party sen'ing this 5~bpoena may seek a court order compelling you to comply ",-ith it. THIS SL"BPOEN A WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: SAME: TOHN STATT 1'11 RSQ. ADDRESS: 320 MARKET ST., PO EX 1268 HA11RTSBURG. FA 17108 TELEPHOS=: 215-246-0900 SUPREME COURT ID #: AITOR.'\EY FOR: ViVlnW ANT BY THE COURT: DATE: ~~, .5 d~t:J1 Prothono Deputy Seal of the Court (Eff. i /97) . , "-. ~- . - -'iillrir!IJb!' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PENN ST. GEISINGER 500 UNIVERSITY DRIVE P.O. BOX 850 HERSHEY, P A 17033 RE: 32938 FREDERICK LEWIS YOUNG ANY AND ALL AcruAL FILMS OF PLAIN RADIOLOGY VIEWS L - TIB/FIB FILM 2/19/99. Any and all X-Rays pertaining to patient. Dates Requested: up to and including the present. Subject: FREDERICK LEWIS YOUNG 728 S. 80TH STREET, HARRlSBURG, PA 17111 Social Security #: 192-30-1548 Date of Birth: 12-18-1939 SU10-290056 32938-L06 <~ ~ t!ll!ii._-j CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL GRAY 'As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOHN STATLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be servedf (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, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/05/2001 JOHN STATLER, ESQ. Attorney for DEFENDANT DEll-238339 32938-L07 ~--~ ~~~l!<I.' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL GRAY NOTICE OF INTEN'.r TO SERVE A SUBPOENA TO PRODUCE DOCOMEN'.rS AND THINGS FOR DISCOVERY PURSUANT TO ROLE 4009.21 COHKUHITY IMAGING ASSOCIATES COHKUHITY GENERAL HOSPITAL PENH ST. GEISINGER PENH ST. GEISINGER VA MEDICAL CERTEB. X-RAY ONLY X-RAY 'ONLY X-RAY ONLY X-RAY ONLY X-RAY ONLY TO: CLARK DEVERE, ESQUIRE MCS on behalf of JOHH STATLER, ESQ. intends to serve a suhpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed belov in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/12/2001 MCS on behalf of JOHH STATLER, ESQ. Attorney for DEFENDANT CC: JOHH STATLER, ESQ. - 22740-938 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-144927 32938 - C 01 ~-~" "'OCii='_:'! I~-! (; " j,: "i ;:i ::1 1,1 ii 1:1 i I ['I 1\ !j \'1 ;] \,i ;j .1 1! ., Ii I': Ii " COMMONWEALTH OF PENNSYl. VANIA COUNTY OF CUMBERLA..'-m YOUNG VS FileNo. 00-2614-CIVIL GRAY SUBPOENA TO PRODUCE DOCUMThlS OR THI~GS FOR DISCOVERY PURSUA..!\i TO RULE 4009.22 " ;j '1 TO: CUSTODIAN OF RECORDS FOR: PENN STATE GEISINGER (Name of Person or E:tri~.) ("dare..) H Ii l~ i-; 11 H \-1, ;1 II ;, \-\"ithin ty..'e:"l::,!" (20) days after service of this subpoena. you are ordered by th~ court to produce the fallowing documents or things: SEE ATTACHED at MCS GROUP INC.,1601 MARKET ST., 11800, PHILA.,PA 19103 You may deihoer or mail legible copies of the documents or,produce things requested by this subpoena. together with the certificate <T. compliance, to the party making this request at the address listed ~bove. You h~ve the righllo seek. in ad,'ance, the ",..onable cost of preparing the copies or producing the things sought. I; !_1 If you fail to ?,=,oduce the documents or things required by this subpoena.. y.;thin twenty (20) days after its service. the party serving this st.:bpoena may seek a court order compelling you to comply y.;th i:.. THIS SlllPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PEnSON: !\'AME: TnHN S1'A1'T1<:R 1<: so ADDRESS: 320 MARKET ST., PO BX 1268 HARRTSBURG. PA 17108 TELEPHON~ 215-246-0900 SUPREME COURT ID #: ATTORXEY FOR= DiVi]\W ^l\T'T' BY THE COURT: DATE: ~j - .5 0200/ Deputy Seal of the Court (Eff. 7/97) I-'~!lliim,j,' EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PENN ST. GEISINGER 500 UNIVERSITY DRIVE P.O. BOX 850 HERSHEY, PA 17033 RE: 32938 FREDERICK LEWIS YOUNG ANY AND ALL AcruAL FILMS OF PLAIN RADIOLOGY VIEWS OF L-KNEE 3-4 VIEWS 3/18/99. Any and all X-Rays pertaining to patient. Dates Requested: up to and including the present. Subject: FREDERICK LEW1S YOUNG 728 S. 80TH STREET, HARRISBURG, PA 17111 Social Security #: 192-30-1548 Date of Birth: 12-18-1939 SUI0-290058 32938 -LO 7 ""'''''''''' !lIi!AA.., CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS YOUNG TERM, -VS- CASE NO: 00-2614-CIVIL GRAY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOHN STATLER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty 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, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/05/2001 JOHN STATLER, ESQ. Attorney for DEFENDANT DEll-238340 32938 -L08 ~~ - COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS YdUNG TERM, -VS- CASE NO: 00-26l4-CIVIL GRAY NOTICE OP IN'l'EN'l' TO SERVE. A SUBPOENA TO PRODUCE DOCUMEN'l'S AND TJlINGSPOR DISCOVERY PURSUANT TO RUIJ!C 4009.21 CONtUIIITY IMAGING ASSOCIATES CONtUIIITY GEIlEllAL HOSPITAL PEIllI ST. GEISINGER PEIllI ST. GEISINGER VA MEDICAL CENTEll X-RAY ONLY X-RAY'ONLY X-RAY ONLY X-RAY ONLY X-RAY ONLY TO: CLARK DEVERE, ESQUIRE MCS on behalf of JOHN STATLER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/12/2001 MCS on behalf of JOHN STATLER, ESQ. Attorney for DEl'ENDAlI'l CC: JOHN STATLER, ESQ. - 22740-938 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 HARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-144927 32938-CO.1 r"H ~iIli:"'-: ii 1,: j,: j: [',I ;) I': " 1:1 I': \,; I:! I;: ;i :.i J:i ,I I ;'1 i-I , " Ii II i:i ,. :"1 'i I'i ij " i:i , ;,1 f.j 1:1 ;I !I fl ,li 'J ri i,i Ii :1 ~" I~ . , , ~ --~~l~fi: COMMONW'EAL T.H OF PENNSYLVANIA COUNTY OF CUMBERL.-\';'iD YOUNG VS FileNo. 00-2614-CIVIL GRAY SUBPOENA TO PRODUCE DOCUMThlS OR THINGS FOR DISCOVERY PURSUAAl TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR:V.A. MEDICAL CENTER (Namr of Prrson or Entity) Within twt!rr:y (20) days after service of this subpoena, you are ordered by the court to. produce the following documents or things: SEE ATTACHED MCS GROUP INC.,1601 MARKET ST., #800, PHILA.,PA 19103 at (Address) You may deih'er 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 ",..onable cost of preparing the copies or producing the things sought. If you fail to ;>:oducethe documents or things required by this subpoena. within twenty (20) da~'s after its service, the party serving this subpoena may seek a court order compelling you to comply with r_ THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TOHN S'l'A'l'l',RR. RSQ. ADDRESS: 320 MARKET ST., PO BX 1268 HARRTSRlJRG. PA 171 08 TELEPHONE: 215-246-0900 SUPREME COURT 10 It: ATTOR.'\EY FOR: DJl1l11Ml:> A}lT BY THE COURT: DATE: ~j.. ~ ~I Deputy Seal of the Court (Eff.? / 97) ~~ k. - EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: VA MEDICAL CENTER 1700 S. LINCOLN AVE. LEBANON, PA 17042 RE: 32938 FREDERICK LEWIS YOUNG ANY AND ALL ACTUAL FILMS OF PLAIN RADIOLOGY VIEWS BILATERAL KNEES 1114/97. CASE NO.#240 - 11104/97 Any and all X-Rays pertaining to patient. Dates Requested: up to and including the present. Subject: FREDERICK LEWIS YOUNG 728 S. 80TH STREET, HARRISBURG, PA 17111 Social Security #: 192-30-1548 Date of Birth: 12-18-1939 SUlO-290060 32938-L08 -""'- , 1Ili:!J~1t 1~ if, ,I, ~~ ~; ji ~! ,!' (; , ~': k ';"1:!fIiJl~II~l.liU!l:lw~~li~alillllli1!il;lliijilllf~i__<!;'~j(",liialiM:iii<;a.;Jl~;:i;!i_l'l'~wm<!~- _0 ......iillllifjl.- ~~ ~ ~=~, ~. ^ ~ -~ ~.. ,.,.... l'iM""'.llIiIIIll!lIO~I_H'---_ ~. " . (') 0 0 C ~ ~,~ -u t}j ::r. ~ l'1l;n ):;;r. ::1: Z:u :;:u nl ::a ~s;: -Oh1 ~- (fJ N -'-.0 ~.2: ~C) 0 ?Eo :l::a :r::'8 :.;:: Qo --0 )>~ '?? Din -, ~ ~) ~ IJ:l ., . ~ -~ , ",,~..,~,~""'~.- , FREDERICK L. YOUNG and DONNA M. YOUNG, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiffs vs. CIVIL ACTION - LAW NO. 00-2614 CHERYL A. GRAY, Defendant JURY TRIAL DEMANDED PLAINTIFFS' PRAECIPE TO SETTLE. DISCONTINUE AND END Kindly mark the above action by Plaintiffs Frederick 1. and Donna M, Young settled, discontinued and ended. METZGER, WICKERSHAM, KNAUSS & ERB, P.C, By: ~ -~,(L Clark DeVere, Esquire Attorney I.D, No. 68768 321 I North Front Street P,O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiffs Dated: /o/~/o( Document #: 217454.1 .' .'.'..1 .. ~ , 1:.1 ;1 "I [..'..1 !, , ,- CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage prepaid on the ~ day of Oc b ~ , 2001, addressed to the following: Clark DeVere, Esquire Metzger Wickersham Knauss & Erb, P.C. 3111 North Front Street P.O. Box 5300 Harrisburg, PAl 71 I 10-0300 GOLDBERG, KATZMAN & SHIPMAN, P.C. By'\fl.;:j John A. Statler, Es . Attorney!. D. No. 43812 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney for Defendant Cheryl A. Gray i~Ii/IiiI" "'-'~",~.; o~)", ~,~,I" ",_,"_'_ ~~- _~""'," ~ I ,'> ,~ _-,~ -0 ~- -"" _1 " ~, -, -w". " '." -< . ,-~ , --...::) -,-1 ~-=-, -( , .- :'.:J ~, ~.< .