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HomeMy WebLinkAbout02-5771KEITH A. WILLIAMSON and IN THE COUKI ur uutnivnur4 ri a yr MARY ALICE WILLIAMSON, Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA V. 2002-,:5'17/ CIVIL TERM DORIS A. ZEIGLER Defendant CIVIL ACTION - LAW PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS TO CURTIS R. LONG, PROTHONOTARY: Please issue a Writ of Summons against the defendant, DORIS A. ZEIGLER, and enter my appearance on behalf of the plaintiffs, Keith A. Williamson and Mary Alice Williamson. Please direct the Sheriff to serve the defendant as follows: Doris A. Zeigler 121 West Hunter Road Carlisle, PA 17013 Respectfully submitted, By: December 3, 2002 IRWIN, MCKNIGJK & Marcus AL McKnight, fW, Esquire 60 West Pomfret Street, Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No: 25476 To: DORIS A. ZEIGLER You are hereby notified that Keith A. Williamson and Mary Alice Williamson, plaintiffs, have commenced an action against you which you are required to defend or a default judgment may be entered against you. P1 12 0- , PROTH OTARY By: A A- A A . !! llwi DEPUTY Date: h?n.ee wc.? 3 , 2002 c v 1 ) SHERIFF'S RETURN - REGULAR CASE NO: 2002-05771 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WILLIAMSON KEITH A ET AL VS ZEIGLER DORIS A JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon ZEIGLER DORIS A the DEFENDANT , at 2109:00 HOURS, on the 12th day of December 2002 at 121 WEST HUNTER ROAD CARLISLE, PA 17013 by handing to DORIS ZEIGLER a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18 00 Service . Affidavit 3.45 Surcharge .00 10.00 .00 31.45 Sworn and Subscribed to before me this j,,? day of ' 1rU A. D. r ,Prothonotary" So Answers: R Thomas Kline 12/13/2002 IRWIN MCKNIGHT HUGHES By: De uty 6heri m:\home\bqa\litigat\statefrm\ZEIGLER\entryofappearance.wpd Draft #1 January 20, 2003 Brigid Q. Alford, Esquire Supreme Court L.D. #38590 Jeffrey E. Piccola, Esquire Supreme Court I.D. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zeigler KEITH A. WILLIAMSON and : IN THE COURT OF COMMON PLEAS MARY ALICE WILLIAMSON, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : No. 2002-5771 CIVIL TERM DORIS A. ZEIGLER, Defendant : CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE Kindly enter the appearances of Brigid Q. Alford, Esquire and Boswell, Tintner, Piccola & Wickersham on behalf of Defendant Doris A. Zeigler. Respectfully submitted, By: -a Brigid Q. Alford, Esquir Supreme Court I.D. #38 90 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zeigler Date: /.?j 10-3 CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Praecipe for Entry of Appearance by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 By: _ Brigid Q. Alford, quire Date: //a 1lQ3 c- - c -, = . m:\home\bqa\litigat\statefrm\ZEIGLER\entryofappearance.wpd Draft #1 January 20, 2003 Brigid Q. Alford, Esquire Supreme Court I.D. #38590 Jeffrey E. Piccola, Esquire Supreme Court I.D. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zeigler KEITH A. WILLIAMSON and : IN THE COURT OF COMMON PLEAS MARY ALICE WILLIAMSON, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : No. 2002-5771 CIVIL TERM DORIS A. ZEIGLER, Defendant : CIVIL ACTION - LAW PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Enter a rule upon the Plaintiff to file a Complaint within twenty (20) days after service of the Rule, or Judgment of Non Pros will be entered. Respectfully submitted, By: ` Brigid Q. Alford, squi Supreme Court I.D. #38590 Jeffrey E. Piccola, Esquire Supreme Court I.D. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zeigler Date: //.2/ 3 KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, V. Plaintiffs DORIS A. ZEIGLER, Defendant TO THE PLAINTIFFS: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 2002-5771 CIVIL TERM CIVIL ACTION - LAW RULE You are ruled to file a Complaint within twenty (20) days after service hereof. Date: ± s ? (i(Li 13K ' Ar s,' PROTH6NO ARY CERTIFICATE OF SERVICE I do hereby certify that I have served on this date a true and correct copy of the foregoing Rule to File Complaint on the following by first-class mail, postage prepaid and addressed as follows: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 & C)-_ ??z 4r?_! Brigid Q. Al rd, Esquire Date: / a/ ,?, _ -, - -? i -, ,?' KEITH A. WILLIAMSON and IN THE COURT OF COMMON PLEAS OF MARY ALICE WILLIAMSON, : Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA V. 2002-5771 CIVIL TERM DORIS A. ZEIGLER , Defendant CIVIL ACTION - LAW NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint, order and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse, 4th Floor Carlisle, PA 17013 (717) 243-6200 Americans with Disabilities Act of 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. KEITH A. WILLIAMSON and : IN THE COURT OF COMMON PLEAS OF MARY ALICE WILLIAMSON, : Plaintiffs : CUMBERLAND COUNTY, PENNSYLVANIA V. 2002- 5771 CIVIL TERM DORIS A. ZEIGLER Defendant CIVIL ACTION - LAW COMPLAINT AND NOW, this 5th day of February, 2003, come the Plaintiffs, KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, by and through their attorneys, Irwin, McKnight & Hughes, and make the following Complaint against the Defendant, DORIS A. ZEIGLER, averring as follows: 1. Plaintiffs, Keith A. Williamson and Mary Alice Williamson are adult individuals principally residing at 305 Heisers Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Doris A. Zeigler, is an adult individual principally residing at 121 West Hunter Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. On or about December 10, 2000, at approximately 8:30 a.m. Plaintiff, Keith A. Williamson was lawfully operating his automobile and was traveling north on Petersburg Road in Cumberland County, Pennsylvania. 4. On or about December 10, 2000, Defendant Doris A. Zeigler was traveling on Limestone Road approaching Petersburg Road. 5. Plaintiff, Keith A. Williamson, was lawfully operating his automobile and had the right- of-way on Petersburg Road. 6. Defendant, Doris A. Zeigler, did not lawfully obey the posted Stop Sign at the intersection of Limestone Road and Petersburg Road. 7. Plaintiff, Keith A. Williamson, was lawfully operating his automobile and was suddenly struck by Defendant, Doris A. Zeigler's automobile as she attempted to cross Petersburg Road in front of Plaintiff. 8. The Plaintiff, Keith A. Williamson, was unable to avoid the Defendant's vehicle. 9. The actions on the Defendant, Doris A. Zeigler, were negligent, careless and reckless in that she: a. failed to obey a traffic sign; a. failed to operate her automobile in a safe manner:; b. failed to yield the right of way to traffic on Petersburg Road; c. failed to avoid striking Plaintiff's vehicle; d. failed to look for approaching traffic; e. failed to observe Plaintiff's vehicle; f. otherwise failed to exercise due and proper care under the circumstances. 2 10. The impact between the Plaintiff's automobile and the Defendant's automobile on the highway caused the Plaintiff's automobile roll over onto the driver's side and onto its roof. The passenger's side of the Plaintiff's automobile was also crushed from the impact of Defendant's automobile. 11. As a result of the accident, the Plaintiff, Keith A. Williamson, suffered severe injuries and treated at Carlisle Hospital as well as by Dr. Rodney Hough, Dr. John Rychak, Dr. Kevin Clawson, Dr. David Baker and Alan D. Roumm, M.D. He has also received physical therapy. 12. The negligent, careless and reckless actions of the Defendant, Doris A. Zeigler, are the proximate cause of the injuries to the Plaintiff, Keith A. Williamson. 13. Defendant, Doris A. Zeigler, received a traffic citation for her failure to stop at the intersection in this accident. 14. Plaintiff, Keith A. Williamson, seeks compensation for the pain and suffering he has endured since the date of the accident and for pain and suffering which he will continue to experience in the future. 15. Plaintiff, Keith A. Williamson, seeks compensation for the medical expenses incurred as a result of the accident as well as the continuing medical expenses which will possible accrue in the future as his need for medical care continues. 3 16. The Plaintiff Keith A. Williamson, seeks compensation for his permanent injuries. 17. The Plaintiff, Mary Alice Williamson, seeks compensation for the loss of companionship and society as a consequence of the injuries to her husband, Keith A. Williamson, caused by the accident. WHEREFORE, the Plaintiffs, Keith A. Williamson and, demand judgment against Defendant, Doris A. Zeigler, in an amount in excess of the arbitration limit of Twenty-Five Thousand ($25,000.00) Dollars, plus costs, interest, and all other relief this Honorable Court deems fair and just. Respectfully Submitted, IRWIN, MCKNIGHT & HUGHES By: Supreme Cou ID # 25476 West Pomfret P essional B 60 West Pomfret Stree Carlisle, Pennsylvania 17013 Fe t (717) 249-2353 Dated: kcu ?1t7?j Attorney for. Plaintiffs 4 VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. KPITN A. WILT. DL ,l- Date: FEBRUARY 5 , ??? VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. AR ALICE WILLIAMSON Date: MRUARY 5 1 20 3 KEITH A. WILLIAMSON and IN THE COURT OF COMMON PLEAS OF MARY ALICE WILLIAMSON, Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA V. 2002-5771 CIVIL TERM DORIS A. ZEIGLER . Defendant CIVIL ACTION -• LAW CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Brigid Q. Alford, Esq. Boswell, Tintner, Piccola & Wickersham 315 North Front Street P. O. Box 741 Harrisburg, PA 17108-0741 IRWIN, McKNIGHT & HUGHES Date: February 5, 2003 By: 41M?a?re?A. McKnight, I , Esq ' e 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No. 25476 1 - ? 71 Fn Brigid Q. Alford, Esquire Supreme Court I.D. 08590 Jeffrey E. Piccola, Esquire Supreme Court I.D. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zeigler KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. DORIS A. ZEIGLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 2002-5771 CIVIL TERM CIVIL ACTION - LAW NOTICE TO PLEAD TO: Keith A. Williamson and Mary Alice Williamson C/O Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. BOSWELL, TINTNER, PICCOLA & WICKERSHAM By: ae?? Brigid . Alford, Es wire Date: *103 m:\home\bqa\litigat\statefrmVEIGLER\Answer MTR.wpd Draft #1 March 5, 2003 Brigid Q. Alford, Esquire Supreme Court I.D. #38590 Jeffrey E. Piccola, Esquire Supreme Court I.D. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zeigler KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. DORIS A. ZEIGLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 2002-5771 CIVIL TERM CIVIL ACTION - LAW DEFENDANT ZEIGLER'S ANSWER TO COMPLAINT WITH NEW MATTER Defendant Doris A. Zeigler, by her attorneys, Brigid Q. Alford, Esquire and Boswell, Tintner, Piccola & Wickersham, answers Plaintiffs' Complaint, as follows: 1. Defendant is without knowledge or information sufficient to form a belief as to the truth of the matters averred in Paragraph 1; the same are therefore denied and proof thereof demanded. 2. Admitted. 3. Admitted, upon information and belief. 4. Admitted. 5. Paragraph 5 sets forth a conclusion of law to which no response is required. To the extent a response is deemed required, Defendant denies the allegations as to lawful operation and right-of-way and avers, to the contrary, that Plaintiff Keith A. Williamson was traveling in excess of the posted speed limit and approached the intersection at issue at such a high rate of speed that he was unable to see and react appropriately and with due care to the fact that Defendant Zeigler had commenced her entrance onto Petersburg Road well in advance of his approaching the same intersection. 6. Paragraph 6 sets forth a conclusion of law to which no response is required. To the extent a response is deemed required, Defendant denies that allegations as to the stop sign and avers, to the contrary, that she did lawfully obey the posted Stop Sign. 7. The allegations as to lawful operations set forth conclusions of law to which no response is required. As to the remaining averment, Defendant denies the implication that the operation and/or path of her motor vehicle was the legal cause of the accident at issue. By way of further Answer, Defendant incorporates herein by reference her Answer to Paragraph 5, above. 8. Denied; to the contrary, had Plaintiff been traveling within the posted speed limit and/or otherwise operating his motor vehicle with due care, he would have been able to avoid and/or limit the force of his vehicle's impact with the Defendant's. 9. Paragraph 9 sets forth a conclusion of law to which no response is required. Should a response be deemed required, Defendant Zeigler: a. Denies that she failed to obey a traffic sign; a. [N.B. There are 2 sub-paragraphs denominated as "a" in the Complaint.] Denies that she failed to operate her automobile in a safe manner; -2- b. Denies that she failed to yield the right of way to traffic on Petersburg Road; C. Denies that she failed to avoid striking Plaintiff's vehicle; d. Denies that she failed to look for approaching traffic; e. Denies that she failed to observe Plaintiff's vehicle; f. Denies that she otherwise failed to exercise due and proper care under the circumstances. 10. Admitted only that there was an impact; the remaining averments are denied as stated. 11. Defendant is without knowledge or information sufficient to form a truth as to the averments raised in Paragraph 11; the same are therefore denied and proof thereof demanded. 12. Paragraph 12 sets forth a conclusion of law to which no response is required. 13. Denied as stated. Admitted only that Defendant received a citation; the form and contents of which speak for themselves. 14. Paragraph 14 sets forth a statement in the nature of a prayer for relief to which no response is required. 15. Paragraph 15 sets forth a statement in the nature of a prayer for relief to which no response is required. 16. Paragraph 16 sets forth a statement in the nature of a prayer for relief to which no response is required. 17. Paragraph 17 sets forth a statement in the nature of a prayer for relief to which no response is required. -3- WHEREFORE, Defendant Zeigler respectfully requests that the Complaint against her be dismissed or, in the alternative, that judgment be entered in her favor and against the Plaintiffs. NEW MATTER 18. Plaintiffs' Complaint fails to set forth a claim upon which relief can be granted. 19. The applicable statute of limitations may serve to bar Plaintiffs' claims. 20. Pennsylvania's comparative negligence statute and the doctrine of contributory negligence may serve to bar all or part of Plaintiffs' claims. 21. The doctrine of assumption of risk may serve to bar Plaintiffs' claims. 22. Plaintiffs' injuries and damages, if any, were caused, in whole or in part, by the acts and/or omissions of persons other than Defendant. 23. Plaintiffs' claims may be barred, in whole or in part, as a result of their tort selection under the applicable provisions of Pennsylvania's Motor Vehicle Code. WHEREFORE, Defendant Zeigler respectfully requests that the Complaint against her be dismissed or, in the alternative, that judgment be entered in her favor and against the Plaintiffs. Respectfully submitted, By: L41,? -2 121?? Brigid . Alfo , E ire Supreme Court I.D. #38590 Boswell, Tintner, Piccola & Wickersham 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zeigler Date: 3 VERIFICATION I, Doris A. Zeigler, hereby verify that the facts contained in the foregoing Defendant's Answer to Plaintiffs' Complaint with New Matter are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. G[?( J ?6?-6 b? Doris A. Zeigler Date: s 0 3 CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Defendant Zeigler's Answer to Complaint with New Matter by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 By: A, - , '? Brigid Q. lford, Esquir Date: 3?5 ??? t'7 c-a c c.? -,? :?- ??,; : ? -- ? ; ?..? ?, ? _ !`{ ? `; ? . .. . _ << Brigid Q. Alford Esquire Supreme Court I.D. 438590 BOSWELL, TINTNER. PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zeigler KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. DORIS A. ZEIGLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2002-5771 CIVIL TERM : CIVIL ACTION - LAW CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifys that: (1) A Notice of Intent to serve the subpoenas with copies of the subpoenas attached thereto was mailed to Plaintiff's counsel on August 19, 2003, at least twenty days prior to the date on which the subpoenas are sought to be served. (2) A copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, marked as Exhibit A. (3) No objection to the subpoenas has been received. Counsel for Plaintiff waived the 20 day waiting period on August 29, 2003. (4) The subpoenas which were served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. Respectfully submitted, By: Brigid . Alf: , Es VO Supreme Court#385 Boswell, Tintner, Piccola & Wickersham 315 North Front Street Harrisburg, PA 17101 (717) 236-9377 Attorneys for Defendant Zeigler Date: September 2, 2003 Brigid Q. Alford, Esquire Supreme Court I.D. #38590 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zeigler KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2002-5771 CIVIL TERM DORIS A. ZEIGLER, Defendant : CIVIL ACTION - LAW NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant Doris A. Zeigler, intends to serve subpoenas identical to the ones that are attached to this notice upon the following: 1. Kevin R. Clawson, D.O. Alan D. Roumm, M.D. Rodney K. Hough, M.D. 4. David C. Baker, M.D. 5. John Rychek, M.D. 6. Penns Woods Physical Therapy Naval Supply Depot, Mechanicsburg EXHIBIT 11 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. Respectfully submitted, By: ?? - Brigi Q. Alford, Esq re Attorneys for Defend t Doris Zeigler DATE: August 19, 2003 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. File No. 2002-5771 DORIS A. ZEIGLER, Defendant SUSPOENATO PRODUCE DOCUMENTS ORTHINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 Kevin R. Clawson, D.O. :". - (Name or Ferscn or catiy) 'riithjn wen-,y (20) days ai-.ef ScrVice of this Suopoena, you are ordered by the court to produce the following -- - bents or things: Co ies of referrals, etc. for Keith A. SS# 172-48-5350 from January 1, 1990 to resent. 315 N Front Street Harrisburg, PA 17101 (Accress) vc,_ ng,; rellVef of mail IEC::.iE Cosies of the dcc-rrients or produce thinCs re-uested by this subpoena. together ihE CertlflCa:e of CO'"iGliaiCe, to the paf`.y r-2klno -,njs r3_uesi at the address Ilste'?. above. You have the right .c sEek in . Vance the re=scnacle cost of pr=eparing the Gcies or proC!ucinC the things sought. 'i VCU Tall to or--duce the god:lm eats or things r e_uired by t`lis subpoena within `JJenty (20) days after its service, °.e part' serving this subpoena nay seek a court order compelling yet to comply with it. 'r;lS SU5PCENA WAS ISSUcD .ATT=E REQUEST OF T_c FOLLOWING PERSON: ?ianE Rri gy(1_Q Al fnrA Fcm i re - ess 315 N_ Front St., P.O. Box 741 Harrisburg, PA 17108-0741 -e E^ho-E (717) 236-9377 :.ar_ne Ccu-t ID = 38590 mev Por. Defendant Doris A Zeigler ,ate: ?r? 3 Seal of the Ccurt BY 7l-4;= COURT: PrcthenotaryiClerk, Civ' Sion S --Z- Deputy (Eft. 7/9-/) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs File No. 2002-5771 V DORIS A. ZEIGLER, Defendant SUBPOENATO PRODUCE DOCUMENTS ORTHINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 Rodne R. Hou h 0: (Nate Of Person cr cony) ' Wer,y (5'0) days aiief SeNice Oi the subpoena, VCU are ordered by the court to produce the iGIIOWInC TJithln _ccunents or thincs: _^^^^ T^e referrals, etc. for Keith A. Williamson SS& 172-48-5350 from January 1, 1990 to 315 N. Front Street Harrisbur PA 17101 (Adcress) v-,, rn,a,J deliver or mail IEC:GIe CCCies of the hCc:1^ents -or produce thin-:s re-UE5tst vv this sLbpcena. toggeth of the CefLIilCafe 0t Comciiance, to the partynakinO this requeV ci tnE address lister above. You have the richt .C seek in aCVanCE the reascna- e cost -of preparing the CCcies Or producing the ihiny^s SOUCht. 'i VCU 'all to p!CdUCe tare or CUr-.ents or t"ings requiter by this SubpOEnc: within aly wylGh Ot. days oiler its ser`JICe, °.a party servlnC th;s sub,poEna may seek a Ccur- Crier Conp. Ellino You to COn CIS SUBPOENA WAS ISSUED AT 7 HE REOUEST OF T'_ FOLLOWING PERSON: 4ane 315 N. Front St., P.O. Box 741 -...cress Harrisburg, PA 17108-0741 ee^hcnE: (717) 236-9377 -orec,e ccurt ID = 38590 mevFor. Defendant Doris A. Zeigler date: Seal of the Court BY' THE COURT: a Prcthonotary/Clerk, C' I ivisien /J o Deputy (Eff. 7/9-1) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. File No. 2002-5771 DORIS A. ZEIGLER, Defendant SUBPOENATO PRODUCE DOCUMENTS ORTHINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 -O' David C. Baker, M. (Name of Person Or Entity) bVithin twenty (20) days after service of this subpoena, you are ordered by the court to produce the following dCcurtents or things: referrals etc. for Keith A Williamson, date-ot-bircn: SS# 172-48-5350 from Janua 1, 1990 to resent. 315 N. Front Street Harrisbur PA 17101 (Adcress) Ycu^ay deliver or rail legible codes of the dccuments or produce things requested by this subpoena. together faith the certificate of compliance, to the party making this request at the address listed above. You have the riche c seek in advance the reasonable Cost of preparing the copies or producing the things sought. vcu fail to produce the documents or things required by this subpoena within twenty (20) days after its service, :he part/ serving thl5 subpoena may seek a pour; Order COmpEllinG you to Comp y with It. 7 CIS SUBPOENA WAS ISSUED AT THE RECUES T OF THE FOLLO'VVING PERSON: dame Rri rsi A ,Q, Al fnrA Fc sn i - 315 N. Front St., P.O. Box 741 ?..dr=_ss Harrisburg, PA 17108-0741 cne (717) 236-9377 _uoreme Court ID = 38590 !ttcrnev For; Defendant Doris A. Zeigler -2 ate: a, Seal of the Court BYL;Frcthcnotary/Clerk, OURT: I?Division Deputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. Rie No. 2002-5771 DORIS A. ZEIGLER, Defendant SUSPOENATO PRODUCE DOCUMENTS ORTHINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 John Rychek, M.D. O: - r-ersan cr ?nr„y) (Nzne or, NiLtiin went' (ZO) c_ys a er sar?ice OT' this subpoena, you are Ordered by the court to produce the fcllowing dOCUnents or thin-_: referrals, etc. for Keith A_ SS# 172-48-5350 from January 1, 1990 to resent. 315 N. Front Street Harrisburg, PA 17101 - (;,dcress) v:,- may ^-11Ver Cf mall legibi2 CCCies Of the do CUrents or produce thi;Cs rezuest_d CV this subpcer,a, together ;:ith t..e CertiflCate CT C-70iiar.ce, to the parry making -this rcGuesi at the acdr255 IStc''. abOVE. YOU have the rlChi C seek Ir. acvanCe the reascr?a_le cost of preparing the cpCies Or pr-dllcing the inings sought. VCU Tail ,-- prpdUCe tale CCCUC:ents or things,ulrec bV this subppena within tv?sny (20) days a-er its service, 14 ".,e party serving U`?Is subpoena may seek a court pr-er compellinc you tO CCr;iply with it. 7 ;IS SUBPOENA WAS ISSUED AT THE RECUEST OFTH ,.°_ FOLLOWING PERSON: dame Sri aid Cl Al fnrA Fc i 315 N. Front St., P.O. Box 741 -„drass. Harrisburg, PA 17108-0741 -aie^hone (717) 236-9377 7..cre^e COu,, ID = 38590 ?..ornev For: Defendant Doris A. Zeigler BY K;PrcLhcnctary/C1erk, URT: Ci ivision I-lc?_Q?_ 2 /JQ e 7 Date: 3 Deputy -i Seal of the Cour, (Eff• 7/97) COMMON`V=ALI rt yr ronra r wNiv,r COUNTY OF CUMSERLAND IZEITH A. WILLIA14SON and MARY ALICE WILLIAMSON, Plaintiffs V. Fiie No. 2002-5771 ' DORIS A. ZEIGLER, Defendant SUBPOENATO PRODUCE DOCUMENTS ORTHINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 Penns Woods Ph sica _-,. _ (Nar..e ai =erson cr ?aary) ii^•In itJ?!l i?/ (??? CcVS ?ie! 52^(ice of tills si::Poe^a, VCu are ordered OV the court to produce the fcllewi"c OCCUrlents or VMrc-s: nAwnnc. referrals etc. for Keith A. GS# 172-48-5350 fl 1990 to 315 N. Front Street Harrisbur PA 17101 ' (ACCTess) aV -EiIVEr Or a:I IECI'CIE COCIES Or tilE ?C Enis or prCd:;Ce'Mi^Cs re_u ESZ-t V ihls si::+ocena. COCEiher :"ii ?`E CErtGICct3 CT Cc:':+lia'CEiC t`E rZry ra:<ir?- "nis reduest at L?1E BCCrE55 IiSCEd = cve. You have the riChi seE!C in vancs the r eascnaclE cCSt ci pre::anng the CCCies Or produC:nG the Ihin_S scuciit. ' VCU Tall tC prC dUCE t.^ie CCCt:r-Ents Cr tilincs re_uirE? by this SU'.^.pCEncS withlri ylJeniV (?J? days titer its ser'JICe, der occ=!line you t0 corply with it. suti CC=ra -aV SE_K a CCUrt Cr C :;.e :,art'/ servinC t.., r.IS SUBPGENA wAS !SSUE'D °-TnE RE LL =-ST OF Tr,= FOLLOWi1NG F EP SON: ?Ia77a 315 N_ Front St., P.O. Box 741 Harrisburg, PA 17108-0741 _ (717) 236-9377 =?'ncne =__.. -.e Ocu t ID = 38590 cmey Pc r. Defendant Doris A_ Zeigler S al of the Ccurz EY THE COURT: PrcthcnataryiClerk, Division ? pepury (Eff. 7/977) CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct co Notice of intent to Serve Subpoenas to Produce Documents and Things ofor D scovveg Pefendat to Rule 4009.21 b rY ursuan to by first-class United States mail upon the following parties at the addresses set forth below: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 By: L enise L. Foster, Paralegal Date: August 19, 2003 CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Certificate Prerequisite to Service of Subpoenas on the following by first-class mail, postage prepaid and addressed as follows: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 By: a]', u? Denise L. Foster, Paralegal Date: September 2, 2003 (i '<f ?U Brigid Q. Alford, Esquire Supreme Court I.D. #38590 BOSWELL, TINTNER, PICCOLA &. 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zeig KEITH A. WILLI SON and : IN THE COURT OF COMMON PLEAS MARY ALICE WILL AMSON, : CUMBERLAND COUNTY, PENNSYLVANIA laintiffs V. : No. 2002-5771 CIVIL TERM DORIS A. ZEIGLER efendant : CIVIL ACTION - LAW SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant ce*ifys that: (1) A Notic? of Intent to serve the subpoenas with copies of the subpoenas attached thereto was mailed to plaintiff's counsel on October 16, 2003, at least twenty days prior to the date on which the subpoenas are sought to be served. (2) A copy bf the notice of intent, including the proposed subpoenas, is attached to this certificate, (3) No as Exhibit A. to the subpoenas has been received. Counsel for Plaintiffs waived the 20 day waiting pe*d on October 20, 2003. (4) The subpoenas which were served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. Respectfully submitted, By: B 'gid . Alfor , Esq e Supreme Court #3859 Boswell, Tintner, Piccola & Alford 315 North Front Street Harrisburg, PA 17101 (717) 236-9377 Attorneys for Defendant Zeigler Date: October 24, Brigid Q. Alford. Esquire Supreme Court I.D. 038590 BOSWELL, TB lTNER PICCOLA & 315 North Front Street post office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zei KEITH A. W11 MARY ALICE V. DORIS A. Defendant attached to this notice and : IN THE COURT OF COMMON PLEAS '(ON. : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2002-5771 CIVIL TERM CIVIL ACTION - LAW A. Zeigler, intends to serve subpoenas identical to the ones that are the following: William Graham, M.D. (Retired) - John P. Stratis, M.D. Mayapple Golf Links You and serve upon the subpoena may be twenty (20) days from the date listed below in which to file of record an objection to the subpoena. If no objection is made, the Respectfully submitted, By: 9t ?G , Brigid .Alford, Esq21, Attorneys for Defend oris Zeigler DATE: October 16, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, PLAINTIFFS V. File No. 2002-5771 CIVIL DORIS A. ZEIGLER, DEFENDANT SUB OENATO PRODUCE DOCUMENTS ORTHINGS F R DISCOVERY PURSUANTTO RULE 4009.22 TO: William G 816 Belevedere Street Carlisle{NMe of Person or Entity) 17013 Within twenty (20) days after se vice of this subpoena, you are ordered by the court to produce the documents or things: Copies of an ?Sorrgsnondencn_ refem etc. for Keith A. Willi on, te-of-birth October 25, 1955; SS#172-48-5350 Records requested from Tanuaryo'l. 1990 to the present. at 315 N. Front Harrisburg, (717) 236-937 You may deliver or mail legible c pies of the documents or produce things requested by this subpoena, togs with the certificate of comp , to the party making this request at the address listed above-You have the to seek in advance the reasona le cost of preparing the copies or producing the things sought. If you fail to produce the docuME the party serving this subpoena THIS SUBPOENA WAS ISSUE Name Brigid Q. Alford Address: Telephone: Supreme Court ID # 38590 Attorney For: (Address) or things required by this subpoena within twenty (20) days after its ser ? seek a court order compelling you to comply with it. AT THE REQUEST OF THE FOLLOWING PERSON: Boa 741 17108-0741 Doris BY THE COURT: Prothonotary/Clerk, Civil Date Seal of the Court ng 1 (Eff. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and V. DORIS A. ZEIGLER, TO: SU Golf Links. 11 Within twenty (20) days after documents or things: Copies of any and all salary records and emplc October 25, 1995, SS#172 at (Address) You may deliver or mail legible c pies of the documents or produce things requested by this subpoena, tog to or producing thelth ngs sought. have the with the seek in certificate the ealsona le cost of preparing the copies s If you fail to produce the do the party serving this subp THIS SUBPOENA WAS ISSUE Name Brigid Q. Alford, Address: 315 N. Front ARY ALICE WILLIAMSON. PLAINTIFFS File No. 2002-5771 CIVIL TEpcn DEFENDANT ENATO PRODUCE DOCUMENTS ORTHINGS DISCOVERY PURSUANTTO RULE 4009.22 (Name of Person or Entity) of this subpoena, you are ordered by the court to produce the nts or things required by this subpoena within twenty (20) days after its sei may seek a court order compelling you to comply with it. AT THE REQUEST OF THE FOLLOWING PERSON: /PO Boa 741 Harrisburg, PIA 17108-0741 Telephone: (717) Supreme Court ID # 38590 Attorney For: Doris BY THE COURT: Prothonotary/Clerk, Civil Date: Seal of the Court (Eff. CERTIFICATE OF SERVICE: I do hereby certi that I have served a true and correct copy of the foregoing Defendant's Notice of Intent to Serve Subpoenas to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 by first-class United States mail upon the following parties at the addresses set forth below: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 By: Denise L. Foster, Paralegal Date: October 16, CERTIFICATE OF SERVICE I do hereby cers Prerequisite to Service addressed as follows: that I have served a true and correct copy of the foregoing Certificate Subpoenas on the following by first-class mail, postage prepaid and Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 By: Z4 Lx??t Denise L. Foster, Paralegal Date: October 24, ;a t 3 ^ N Brigid Q. Alford, Esquire Supreme Court I.D. #38590 BOSWELL, TINTNER, PICCOLA & ALFORD 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zeigler KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. DORIS A. ZEIGLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2002-5771 CIVIL TERM CIVIL ACTION -LAW CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: (1) A Notice of Intent to serve the subpoenas with copies of the subpoenas attached thereto was mailed to Plaintiff's counsel on December 13, 2004, at least twenty days prior to the date on which the subpoenas are sought to be served. (2) A copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, marked as Exhibit A. (3) No objection to the subpoenas has been received. (4) The subpoenas which were served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. Respectfully submitted, n / By: Al i Brigi Q. Alford, Esqui Supreme Court #38590 Boswell, Tintner, Piccola & Alford 315 North Front Street Harrisburg, PA 17101 (717) 236-9377 Attorneys for Defendant Zeigler Date: January 13, 2005 Brigid Q. Alford, Esquire Supreme Court I.D. #38590 Jeffrey E. Piccola, Esquire Supreme Court I.D. #18018 BOSWELL TINTNER, PICCOLA & WICKERSHAM 315 North From Street Post Office Box 741 Harrisburg, Pennsylvania [7108-0741 Attomeys for Defendant Doris A. Zeigler KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. DORIS A. ZEIGLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 2002-5771 CIVIL TERM :CIVIL ACTION -LAW NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant Doris A. Zeigler, intends to serve subpoenas identical to the ones that are attached to this notice upon the following: Rodney K.Hough, M.D. 2. Alan D. Roumm, M.D. 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. Respectfully submitted, CAL By: Brigid (. Alford, Esq tte Supreme Court #385 Boswell, Tintner, Piccola & Alford 315 North Front Street DATE: December 13, 2004 Harrisburg, PA 17101 (717) 236-9377 Attorneys for Defendant Doris Zeigler COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and : IN THE COURT OF COMMON PLEAS MARY ALICE WILLIAMSON, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : No. 2002-5771 CIVIL TERM DORIS A. ZEIGLER, Defendant .:CIVIL ACTION -LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 TO: RODNEY K. HOUGH M.D. 49 Brookwood Avenue. Carlisle PA 17013 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Conies of anv and all medical records, treatment records, correspondence, x-rav reports, etc., for KEITH A. WILLIAMSON, SS#172-48-5350, Date of birth October 25,1955. Records requested are from Seotember 1, 2003 through December 13. 2004. at Boswell Tintner Piccola & Alford 315 N Front Street[PO Box 741, Harrisburi PA 17108- 0741 (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: NAME: Brigid O. Alford. Esquire ADDRESS: 315 N. Front Street/PO Box 741 Harrisburg. PA 17108-0741 TELEPHONE : (717) 236-9377 SUPREME COURT ID #: 38590 ATTORNEY FOR: Defendant Zeigler BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and : IN THE COURT OF COMMON PLEAS MARY ALICE WILLIAMSON, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. DORIS A. ZEIGLER, Defendant : No. 2002-5771 CIVIL TERNI : CIVIL ACTION - LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ALAN D. ROUMM, M.D.. 650 Poplar Church Road. Camp Hill. PA 17011 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Copies of any and all medical records, treatment records, correspondence, x-ray reports, etc.. for KEITH A. WILLIAMSON, SS#172-48-5350. Date of birth October 25.1955. Records requested are from September 1, 2003_throu8h December 13. 2004. at Boswell. Tintner Piccola & Alford 315 N. Front Street/PO Box 741, Harrisburg PA 17108- 0741 (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: NAME: Brigid O. Alford, Esquire ADDRESS: 315 N. Front Street/PO Box 741 Harrisbure, PA 17108-0741 TELEPHONE : (717) 236-9377 SUPREME COURT ID #: 38590 ATTORNEY FOR: Defendant Zeigler BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Notice of Intent on the following by first-class mail, postage prepaid and addressed as follows: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 L4?? By: «3/ v Denise L. Foster, Paralegal Date: December 13, 2004 CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Certificate Prerequisite to Service of Subpoenas on the following by first-class mail, postage prepaid and addressed as follows: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 By: 14^ C/a Denise L. Foster, Paralegal DateJanuary 13, 2005 r-? t L? ? ?- PI . . . ? _? t_ . l: ?.. (? ?,f,? n,t Brigid Q. Alford, Esquire Supreme Court I.D. #38590 BOS WELL, TINTNER, PICCOLA & ALFORD 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zeigler KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. DORIS A. ZEIGLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2002-5771 CIVIL TERM :CIVIL ACTION -LAW CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: (1) A Notice of Intent to serve the subpoenas with copies of the subpoenas attached thereto was mailed to Plaintiff's counsel on May 3, 2005, at least twenty days prior to the date on which the subpoenas are sought to be served. (2) A copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, marked as Exhibit A. (3) No objection to the subpoenas has been received. (4) The subpoenas which were served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. Respectfully submitted, By:?? ?. Brigg Q. Alford, Esgi}? e Supreme Court #3859 Boswell, Tintner, Piccola & Alford 315 North Front Street Harrisburg, PA 17101 (717) 236-9377 Attorneys for Defendant Zeigler Date: June 8, 2005 Brigid Q. Alford, Esquire Supreme Court I.D. #38590 Jeffrey E. Piccola, Esquire Supreme Court I.D. #18018 BOSWELL TINTNER, PICCOLA & ALFORD 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Dons A. Zeigler KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. DORIS A. ZEIGLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2002-5771 CIVIL TERM :CIVIL ACTION -LAW NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant Doris A. Zeigler, intends to serve subpoenas identical to the ones that are attached to this notice upon the following: 1. Sheperdstown Family Practice 2. Carlisle Hospital 3. John Rychak, M.D. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objections are made, the subpoenas may be served. Respectfully submitted, By: Brigid Q. Alford, E uire Supreme Court #38 0 Boswell, Tintner, Piccola & Alford 315 North Front Street Harrisburg, PA 17101 (717) 236-4377 ` DATE: May 3, 2005 Attomeys for Defendant Doris Zeigler COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and : IN THE COURT OF COMMON PLEAS MARY ALICE WILLIAMSON, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. No. 2002-5771 CIVIL TERM DORIS A. ZEIGLER, Defendant :CIVIL ACTION -LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Shepherdstown Familv Practice. 2140 Fisher Road, Mechanicsburg. PA 17055 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Copies of any and all medical records treatment records. correspondence x-ray reports etc. for KEITH A. WILLIAMSON. SS#172-48-5350. Date of birth October 25, 1955. Records requested are from.1anuarv 1, 1992 through Mav 3. 2005. at Boswell. Tintner. Piccola & Alford. 315 N. Front Street/PO Box 741. Harrisburg. PA 17105- 0741 (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: NAME: Brigid O. Alford. Esquire ADDRESS: 315 N. Front Street/PO Box 741 Harrisburg. PA 17108-0741 TELEPHONE : (717) 236-9377 SUPREME COURT ID #: 38590 ATTORNEY FOR: Defendant Zeigler BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk ?`R COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and : IN THE COURT OF COMMON PLEAS MARY ALICE WILLIAMSON, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. DORIS A. ZEIGLER, Defendant : CIVIL ACTION - LAW TO: Carlisle Hospital 246 Parker Street Post Office Box 310, Carlisle. PA 17013-0310 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Copies of anv and all medical records. treatment records. Correspondence, x-ray reports etc for KEITH A. WILLIAMSON. SS#172.48-5350. Date of birth October 25. 1955. Records requested are from Ianuarv 1. 1992 through Mav 3. 2005. at Boswell. Tintner. Piccola & Alford. 315 N. Front Street/PO Box 741. Harrisbura. PA 17108- 0711 (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: No. 20025771 CIVIL TERM SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 NAME: Brigid O. Alford. Esquire ADDRESS: 315 N. Front Street/PO Box 741 Harrisburg. PA 17108-0741 TELEPHONE : (717) 236-9377 SUPREME COURT ID#: 38590 ATTORNEY FOR: Defendant Zeigler BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and : PI THE COURT OF COMMON PLEAS MARY ALICE WILLIAMSON, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. No. 2002-5771 CIVIL TERM DORIS A. ZEIGLER, Defendant : CIVIL ACTION -LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: John Rvchak. M.D.. Orthopedic Surgeons of Central Pennsylvania. 99 November Drive, Camp Hill, PA 17011 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Copies of any and all medical records, treatment records, correspondence x-ray reports etc for KEITH A. WILLIAMSON SS#172-48-5350. Date of birth October 25. 1955. Records requested are from April 9,2002 through Mav 3. 2005. at _Boswell Tintner. Piccola & Alford. 315 N. Front Street/PO Box 741, Harrisburs, PA 17103- 0741 (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: NAME: Brigid O. Alford. Esquire ADDRESS: 315 N. Front Street/PO Box 741 Harrisbure, PA 17108-0741 TELEPHONE : (717) 236-9377 SUPREME COURT ID #: 38590 ATTORNEY FOR: Defendant Zeieler BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Notice of Intent on the following by first-class mail, postage prepaid and addressed as follows: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 By: Denise L. Foster, Paralegal Date: May 3, 2005 CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Certificate Prerequisite to Service of Subpoenas on the following by first-class mail, postage prepaid and addressed as follows: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 By: l Denise L. Foster, Paralegal Date: June 8, 2005 l> N ? ? co c-n t J Brigid Q. Alford, Esquire Supreme Court LD. #38590 BOSWELL, I INTNER, PICCOLA & ALFORD 315 North Front Street Post Office Box 741 HuFusburg, Pennsylvania 17108-0741 Attorneys for Defendant Doris A. Zeigler KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. DORIS A. ZEIGLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2002-5771 CIVIL TERM : CIVIL ACTION - LAW CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: (1) A Notice of Intent to serve the subpoenas with copies of the subpoenas attached thereto was mailed to Plaintiff's counsel on February 2, 2006. (2) A copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, marked as Exhibit A. (3) No objection to the subpoenas has been received. (4) The subpoenas which were served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. Respectfully submitted, By: Brigid . Alford, Esquir Supreme Court #38590 Boswell, Tintner, Piccola & Alford 315 North Front Street Harrisburg, PA 17101 (717) 236-9377 Attorneys for Defendant Zeigler Date: February 24, 2006 Brigid Q. Alford, Esquire Supreme Court I.D. #38590 Jeffrey E. Piccola, Esquire Supreme Court LD. #18018 BOSWELL, TINPNER, PICCOIA & AIFORD 315 North Front Street Post Office Box 741 Harrisburg Pennsylvania 17108-0741 Attorneys for Defendant Dods A Zeigler KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. DORIS A. ZEIGLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 2002-5771 CIVIL TERM CIVIL ACTION - LAW NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant Doris A. Zeigler, intends to serve subpoenas identical to the ones that are attached to this notice upon the following: 1. Carlisle Hospital 2. John Rychak, M.D. 3. Alan D. Roumm, M.D. 4. Penns Wood Physical Therapy 5. Erie Insurance You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objections are made, the subpoenas may be served. Respectfully submitted, By: Brigill Q. Alford, Es re Supreme Court #385 Boswell, Tintner, Piccola & Alford 315 North Front Street Harrisburg, PA 17101 (717) 236-9377 Attorneys for Defendant Doris Zeigler DATE: February 2, 2006 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and : IN THE COURT OF COMMON PLEAS MARY ALICE WILLIAMSON, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. No. 2002-5771 CIVIL TERM DORIS A. ZEIGLER, Defendant : CIVIL ACTION - LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: john Rychak M.D., Orthopedic Surgeons of Central Pennsylvania, 99 November Drive, Camp Hill, PA 17011 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Copies of any and all medical records, treatment records, correspondence x-ray reports etc for KEITH A. WILLIAMSON, SS#172-48-5350, Date of birth October 25, 1955 Records requested are from May 4 2005 through February 2, 2006. at Boswell Tintner Piccola & Alford 315 N Front Street/PO Box 741. Harrisburg. PA 17108- 0741 (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: NAME: Brigid O. Alford, Esquire ADDRESS: 315 N. Front Street/PO Box 741 Harrisburg. PA 17108-0741 TELEPHONE : (717) 236-9377 SUPREME COURT ID #: 38590 ATTORNEY FOR: Defendant Zeieler BY THE COURT: DATE: Sea] of the Court Prothonotary/Clerk COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and : IN THE COURT OF COMMON PLEAS MARY ALICE WILLIAMSON, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. No. 2002-5771 CIVIL TERM DORIS A. ZEIGLER, Defendant : CIVIL ACTION - LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Alan D. Roumm M.D., 650 Poplar Church Road Camp Hill PA 17011 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Copies of any and all medical records, treatment records correspondence, x-ray reports etc. for KEITH A WILLIAMSON SS#172-48-5350 Date of birth October 25, 1955. Records requested are from December 14, 2004 through February 2 2006. at Boswell Tintner. Piccola & Alford, 315 N Front Street/PO Box 741 H• rrisbure, PA 17108- 0741 (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: NAME: Brigid O. Alford, Esquire ADDRESS: 315 N. Front Street/PO Box 741 Harrisburg, PA 17108-0741 TELEPHONE : (717) 236-9377 SUPREME COURT ID #: 38590 ATTORNEY FOR: Defendant Zeigler DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and : IN THE COURT OF COMMON PLEAS MARY ALICE WILLIAMSON, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. No. 2002-5771 CIVIL TERM DORIS A. ZEIGLER, Defendant : CIVIL ACTION - LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Hospital, 246 Parker Street PO Box 310, Carlisle PA 17013-0310 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Copies of any and all medical records treatment records correspondence, x-ray reports etc, for KEITH A WILLIAMSON SS#172-48-5350 Date of birth October 25, 1955, Records requested are from May 4 2005 through February 2 2006 at _ Boswell, Tintner, Pieeola & Alford 315 N Front Street/PO Box 741 Hanisbure PA 17108- 0741 (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: NAME: Brigid O. Alford, Esquire ADDRESS: 315 N. Front Street/PO Box 741 Harrisburi!, PA 17108-0741 TELEPHONE : (717) 236-9377 SUPREME COURT ID#: 38590 ATTORNEY FOR: Defendant Zeider BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 2002-5771 CIVIL TERM DORIS A. ZEIGLER, Defendant CIVIL ACTION -LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Penns Woods Physical Therapy, 425 Stonehedge Drive Carlisle, PA 17013 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Copies of any and all medical records, treatment records, correspondence x-ray reports etc for KEITH A WILLIAMSON SS#172-48-5350, Date of birth October 25, 1955 Records requested are from September 3 2003 through February 2, 2006. at Boswell Tintner Piccola & Alford 315 N Front Street/PO Box 741, Harrisburg. PA 17108- 0741 (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: NAME: Brigid O. Alford, Esquire ADDRESS: 315 N. Front Street/PO Box 741 Harrisburg, PA 17108-0741 TELEPHONE : (717) 236-9377 SUPREME COURT ID #: 38590 ATTORNEY FOR: Defendant Zeigler BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEITH A. WILLIAMSON and : IN THE COURT OF COMMON PLEAS MARY ALICE WILLIAMSON, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. : No. 2002-5771 CIVIL TERM DORIS A. ZEIGLER, Defendant : CIVIL ACTION - LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Erie Insurance Company, PO Box 2013, Mechanicsburg PA 17055-0710 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Copies of any and all Worker's Compensation Records for Claim #01010-722522 -Claimant: KEITH A. WILLIAMSON, SS#172-48-5350, Date of birth October 25, 1955. Employer - Mayapple Golf Course, Carlisle, Pennsylvania: Date of Loss - 9/24/04. at Boswell, Tintner, Piccola & Alford. 315 N Front Street/PO Box 741, Harrisburg PA 17108- 0741 (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: NAME: Brigid O. Alford, Esuuire ADDRESS: 315 N. Front Street/PO Box 741 Harrisburg, PA 17108-0741 TELEPHONE : (717) 236-9377 SUPREME COURT ID #: 38590 ATTORNEY FOR: Defendant Zeigler BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Notice of Intent on the following by first-class mail, postage prepaid and addressed as follows: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 By: Denise L. Foster, Paralegal Date: February 2, 2006 CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Certificate Prerequisite to Service of Subpoenas on the following by first-class mail, postage prepaid and addressed as follows: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 r By: (,&, Denise L. Foster, Paralegal Date: February 24, 2006 ?. ) < -fi . _i ..... ^ 1 _,i ., in ? - ? l'J . .) ._ i PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) ( XX ) for JURY trial at the next term of civil court. ( ) for trial without a jury. CAPTION OF CASE (entire caption roust be stated in full) Keith A. Williamson and Mary Alice Williamson, vs. Doris A. Zeigler (Plaintiff) (check one) ( ) Assumpsit ( ) Trespass ( VI) Trespass (Motor Vehicle) (other) The trial list will be called on August 22, 2006 and Trials commence on Sept 18, 2006 VS. (Defendant) Pretrials will be held on (Briefs are due 5 days before pretrials.) (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. 5771 Civil 2002 1d®c___ Indicate the attorney who will try case for the party who files this praecipe: Brigid Q. Alford, Esquire 41S N 1? nE St ,_P_n_ Anx 741, Harrichvrg, PA 17109-0741 (7171-236-9377 Indicate trial counsel for other parties if known: Marcus A. McKnight. III Esquire 60 West Pomfret St., Carlisle, PA 17013 (717) 249-2353 This case is ready for trial. Date: 7fk 10 6 Signed: --- ?f"- !) Print Name: Brigid Q. Alford, Esquire Attorney for: Defendant Doris A. Zeigler a Brigid O. Afford, Esquire Supreme Court I.D. 438590 BOSWELL, TINTNER, PICCOLA & ALFORD 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 (Phone) (717) 236-9316 (Facsimile) brigidalford@att.net (Email) Attorneys for Defendant Doris A. Zeigler KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. DORIS A. ZEIGLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2002-5771 CIVIL TERM CIVIL ACTION -LAW NOTICE OF DEATH PURSUANT TO Pa.R.C.P. No. 2355 The April 27, 2006 death of Doris A. Zeigler, a party to the above action, during the pendency of this action, is noted upon the record. Boswell, Tintner, Piccola & Alford By: A-4 2 J45-'z Brigid . Alford, quire Supreme Court ID No. 38590 315 N. Front St. P. O. Box 741 Harrisburg, PA 17108-0741 (717) 236-9377 Attorneys for the Deceased Party Defendant Date: o CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Notice of Death by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Marcus A. McKnight, III, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 By: t,2_ Brigid . Alford, quire Date: 0!401- , ? c? -n ? : ? ? ? ? ? "` N ? ? iC U,.- ? ? _? -r, s ?: ? p° '- `? r . ?.. :Y{_ ? --t ?C: '? N N KEITH A. WILLIA14SON and IN THE COURT OF COMMON PLEAS OF MARY ALICE WILLIAMSON, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 2002-S:;:;:;1• CIVIL xjt DORIS A. ZEIGLER, Defendant CIVIL ACTION -LAW RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Brigid O. Alford. Esquire -,counsel for the off/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of the plaintiff in the action is $2 5 , 0 0 0.0 0 The counterclaim of the defendant in the action is $ 5 , 0 0 0. 0 0 The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Marcus A. McKnight, III, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, Brigid Q. lfo d, uire Supreme Court ID#3 90 ORDER OF COURT Attorney for Defendant Zeigler AND NOW, '19 , in consideration of the foregoing petition, Esq., Esq., and , Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. By the Court, P.J. e ?o d C?? .-. ?_- w? $? G ?i -r1 rn? T1;T' _,} _. C) T_. =;i c_.-) C-7 ?rrrn f ? KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. LEEANN ZEIGLER, Executrix for the Estate of DORIS A. ZIEGLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2002- 5771 CIVIL TERM CIVIL ACTION - LAW PRAECIPE TO AMEND CAPTION To the Prothonotary: Please amend the caption from Doris A. Ziegler, Defendant, to Leeann Zeigler, Executrix for the Estate of Doris A. Zeigler, Defendant. IRWIN & Marcus P Mc ight, 60 West P et Street Carlisle, 17013 (717) 249-2353 Supreme Ct. ID. 25476 Date: October 15, 2007 KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. LEEANN ZEIGLER, Executrix for the Estate of DORIS A. ZIEGLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2002- 5771 CIVIL TERM CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Praecipe was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & Wickersham 315 North Front Street Post Office Box 741 Harrisburg, PA 17101 IRWIN & McKNIGHT By: MaWe"-stPomfret igh III, Esquire 60 treet C lisle, P(717) - Supreme Court I.D. No. 25476 Date: October 15, 2007 m r a-' -r m UO I Plaintiff ? In The Court of Common Pleas or Cumberland Plaintiff County, Pennsylvania No. -__ r...L' ?-7 7 Defendant Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. signature Signature Signature ?JD-uJ,'J Nam6 (e+eirn? Name Name Law F' Address Law Firm Address Law Firm Address C am' r? ?? f roc' _1 /?i p (lYl(f ??Jv'? ?/rt / :? ',SS - ? _ -o 13 City, zip city, zip city, zip ? C),;8 -* 101707 Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: damages for delay are awarded, they shall be separately stated.) ,1 1 I VII, ->Z V?1 1Cti a - _ V 1-r _ , %, r ,Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: 1,0 - I S - ®'7 Date of Award: K0 - t S _ D-2 Notice of Entry of Award poe'- Ili K'A- L - It Now,the 31St day of _ L-b r , 20_0_?, at 8.,Aq , A_.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: S?j p , dQ 7 By: Prothonotary Deputy A4 COP +. ? •? E- L-7? 0 1 Ord I ?d G n? KEITH A. WILLIAMSON and MARY ALICE WILLIAMSON, Plaintiffs V. LEEANN ZEIGLER, Executrix for the Estate of DORIS A. ZIEGLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2002- 5771 CIVIL TERM CIVIL ACTION - LAW SiL+S7y PRAECIPE T ETTLE AND DISCONTINUE To Curtis R. Long, Prothonotary: Please mark the above-captioned case^settled and discontinued. Respectfully submitted, IRWIN & McKNI By: t??7 Marcus . Mc ttgreet ht, II Esquire 60 West Pomfret Ca rlisle, Pennsyl013 (717) 249-2353 Date: November 14, 2007 KEITH A. WILLIAMSON and IN THE COURT OF COMMON PLEAS OF MARY ALICE WILLIAMSON, Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA V. 2002- 5771 CIVIL TERM LEEANN ZEIGLER, Executrix for the Estate of CIVIL ACTION - LAW DORIS A. ZIEGLER, Defendant CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Praecipe to Settle and Discontinue was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Brigid Q. Alford, Esq. Boswell, Tintner, Piccola & Wickersham 315 North Front Street P. O. Box 741 Harrisburg, PA 17108-0741 IRWIN & McKNIGHT By: Date: November 14, 2007 (717) 249-2353 Supreme Court I.D. No. 25476 e?-a f? G a ? ? -^? ? "` c? ? rrt ?.: ...- Y , ,?"' ?V7 ? ; ?-? `<'?. rec.' ?' r :??, ?? ?- ? ?. ??? ? ?? ? ? _ ?