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Home My WebLink About97-00555 s '1 ~ / ~i <:i , i \ j ! J 6 Hoffer DEBRA CONNOR and HAROLD CONNOR. Plainti ff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 97-555 CIVIL TERM IN TRESPASS IM,V,) V, ALAN D, BERLIN. Defendant llLRL--P.REIR IALLQNEE.R.Elli A pretrial conference was held before the Honorable George E, Hoffer, President Judge. on Wednesday, February 25. 1998, In this vehicle accident case. David L, Lutz. Esquire. represents the plaintiff. and James G, Nealon, III. Esquire, represents the defendant, The accident occurred on the Route 581 connector on February 26, 1995, Plaintiff claims that she was stopped in a line of traffic on the right-hand lane and she was stopped for the legitimate reason that all traffic in her lane had stopped for some reason, Defendant was behind plaintiff in the left-hand passing lane as he approached the area where she was stopped, Defendant claims that he had his car under control readY to make a stop when his car hit a hidden patch of ice. causing him to slide into the side of plaintiff's vehicle, Defendant will be claiming the benefit of a charge which relieves him of liability. and the Court requests that we receive this full charge within a week of today's date so that the Court and plaintiff's counsel can review the same, Plaintiff sustained injuries which required some surgery on her shoulder which plaintiff claims continues to cause her pain and loss of motion, 97-555 CIVIL TERM PRETRIAL CONFERENCE PAGE 2 This case appears to be able to be tried in one and a half to two days, Plaintiff's medicals were approximately $14.000,00, The bills in excess of $10,000,00 were paid by her husband's insurance carrier and they claim subrogation for those bills, Counsel are directed to present a stipulation ta the Court with a resolution for handling the excess medicals so that that amount can be added to the Jury verdict. if there is liability, By the Court. David L. LutZ. Esquire 4503 N. Front Street Harrisburg, Pa, 17110 For the Plaintiff James G, Nealon. III, ESQ, p, 0, Box 865 Harrisburg. Pa, 17108-0865 For the Defendant Prothonotary's Office Court Administrator :mtf .1 ,-" \: " . I'! I" ., :,.: L i . l /.!." 'J_J ~v ., , , ' C'.) :......~\>;-j-: ;,~ ,~ -i ~ tA'IlAL CIILlYIU SrsflM~ lll....1 . NatlCluiJr . Same- lI,y . thur,nlcl:'d I', , \ L Addrc~~ ii" \...'( I Slale , \" ,\ .,' ellY 1/: I 1,1'\ i j' \/. PIckup Dill No, ~ q Dill To ~ i Remarks t l. Job No, )101 C. Will'ne Slreet IlarlisburA, PA 17111 (717)561-77112 1,1100-451-11111 Fax: (717) 561-1956 INo, Dranch ., 1 i j;~/c Indil'ldua' N1m< I'., I, Compan)' N~mr :.t \'~"\ i " j ( 1l4" '/,, i ~ , " 'id, .\ ill ' , ,,"( Zop Slille Zip J i '/ \. l ' ~, J ,: I - It , \ Piece!> Mileage , .- Dri\'crlNn.._ ~. / -F,., /'l:~' Price ;\ "" "~~~,~'~~~~J>:~Ki!:';,::" , t" 'J , ',' -/ " ~.. ~' '>'. ~.' " ",' ~,' :;" . ".~ ;: . " , "':.' ",:'.-:;" >"~n.. , "," .: ..,'-1. "",I; ,.,.- ",', .:,' ..--'-F-.-':',. ',," - .-,. ;';.. .--:" .,t:' ~:': : - ." .:~.{ , , ",,- ,!. -...' '. ~. . .'.,-' ..,__,:i;: '-':'! :'.;~;~it,,:: ,~'. . '~\' - '. \,>:1" ./ l:,' - " ',',I;.,,-.:!/ '\\':' .<; >,., .. J 'tt., '::.~'\~-:--: " ~' 1:. p' __L~_~-';~';:-" .'. , ."'" ~,' . .' ..' .' '".: ! .1 ,', ":.".' . .....: . -'~c; "~ ".:'~' .~~<,-:,' :: ~- - ",. ............. DEBRA CONNER HAROLD CONNER, Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ : CIVIL ACTION - LAW v. : NO. 97-555 ALAN D. BERLIN, Defendant : JURY TRIAL DEMANDED PROPOSED POINTS FOR CHARGE OF THE DEFENDANT. ALAN D. BERLIN Respectfully submitted, NEALON By: q - James G, Nealon, III, Esquire Atty.I.D,#46457 301 Market Street -- 9th Floor P,O, Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 02. ISSUES IN THE CASE J ~ \ The Plaintiffs claim that they were injured and sustained damage as a result of " the negligent conduct of the Defendant. The Plaintiff has the burden of proving his claims. Based upon the evidence presented at this Trial, the only issues for you to decide in accordance with the law as I shall give it to you, are: First: Was the Defendant Negligent? Second: Was the Defendant's Conduct a Substantial Factor is bring about harm to the Plaintiff? Third: The damages, if any, to be awarded to the Plaintiffs, Pa, SSJI (Civ,) 3.00 * * 165 0831 7591 .:'[\!)P()~. ",.c.. '~ '" . Ifi((~ I ~ ".....-. 0"0 320 PD85 49600 · . FED 19 98 ''''"RlcIllJl/C p. 1 7 1 0 , NEALON & GOVER A PROFESSIONAL COR~ORATION ATTORNEYS AT LAW 301 MARKET STREET - 9TH f"LOOR PO BOX 865 HARRISBURG, PENNSYLVANIA 17108.0865 c t: CD ~ III t: III % r&1 , BROWNSTOWN FAMILY MEDICAL CENTER, Inc, A, Peler Caluslc, 0,0, C, David Noll, 0,0, Susan F. Northwall, 0,0, William E, Longenecker, 0,0, Jonathon A, Sneller, 0,0, 4224 Oregon Pike Brawnslown, PA 17508-OA89 Telephone: (717) 859.1 123 April April 7, 1997 Mr. David L. Lutz Angina & Rovner, P.C. 4503 N. Front Street Harrisburg, PA 17110-1708 Re: Debra L. Connor Date of Accident: 2/26/95 Dear Mr. Lutz: 1 received your letter regarding Debra L. Connor and your request for information regarding her auto accident in February 26, 1995. My office has enclosed copies of her medical records as you have requested. Please note that we have kept separate progress notes related to Debra's motor vehicle accident. We do this primarily to simplify copying the records for billing purposes. Patients however will certainly come in with multiple complaints some which payor may not be related to the accident. In Debra's ca~e you will note that some of the office visits in the latter part of 1996 have information pertained to medical problems as well as her injuries. For the sake of your keeping track of her record, please use the dates and not the page numbers of the progress notes to establish chronicity. While we attempt to keep the information separated, it is sometimes not easy to do that. I apologize for any confusion this may lead your office staff. If you have any questions about the progress note records, don I t hesi tate to contact our office. 1 first saw Debra on February 28, 1995 as a result of injuries sustained in a motor vehicle accident. She was seen in my off ice. Two days before this she had been seen and evaluated at the Ephrata Community Hospital Emergency Room. At that time the ER physician made a diagnosis of acute cervical and thoracic strain. When I saw her February 28 she was complaining of pain in her neck, shoulder and back. My diagnosis was cervical, D-rv' b;t ~ Page 2 - Debra L. Connor continued: thoracic strain and sprain and right shoulder sprain. I started her on a muscle relaxant, She had already been taking an analgesic as prescribed by the ER doctor. I also started physical therapy, modal i ties through FliCkinger Physical Therapy Services. Copies of his notes are included in the records. As you can see from the records. I saw her approximately every 4 to 6 six weeks through September. 1995. During that time she made slow. but gradual improvement. I made medication changes including switching muscle relaxants and analgesics. Through a course of treatment additional symptoms surfaced. In March. 1995 she complained of ankle pain secondary to her feet being impacted into the pedals of the car. In April. 1995 she complained of jaw discomfort. She saw her dentist for that. By August she was complaining of the some weakness in the shoulder in addi tion to pain. When I saw her in September. 1995 she was still having symptoms of pain ,stiffness and discomfort primarily in the shoulder. During this same time span a number of diagnostic studies were performed. February 27th in the emergency room a cervical spine was done that showed some slight narrowing of the disc spaces at C4.5 and C5.6. A chest x-rayon that same day lIas normal. I had x-rayed her foot and ankle in Apr 11. 1995 and these were unremarkable. I also obtained a right shoulder x-ray in August. 1995 which was unremarkable. We did an MRI of the right shoulder as well. which showed what appeared to be some fluid around the subacromial bursa. Her diagnosis at this time was acromi-clavicular tendonitis. bursitis .impingement syndrome of the right shoulder wi th thoracic strain secondary to motor vehicle accident. Certainly through this time period all of her symptoms and injuries. in my opinion. were with a reasonable degree of medical certainty directly related to her motor vehicle accident in February 26. 1995. I next saw her November 6. 1995 for an unrelated medical matter. However. at that time I did refill her muscle relaxant (Soma) with instructions to take these 4 times a day as she was still having shoulder symptoms. She had also still been receiving some physical therapy through October. 1995. Page 3- Debra L. Connor continued: In January 17, 1996 Deb was seen by my associate. She pulled open a door in December , about 5 weeks before this visit. She used her right arm and apparently it was heavy, ior in pulling it open, her shoulder just gave out. The door then hit her in the right eye. She was given an osteopathic manipulation by Dr. Sneller on this date and got some relief from that specific treatment. I saw her in follow-up on January 19 and February 5th. As a result of her having persistent discomfort and weakness in the shoulder, I referred her to Dr. Raymond Dragann, who has been primarily managing her case since. I did see her on several occasions in 1996. I saw her March 25th to do a history and physical examination on her prior to her having an arthroscopy wi th an open acromioplasty and resection of the distal clavicle on the right shoulder by Dr. Raymond Dragann. Post operatively, according to his letters to me, she improved somewhat but remained with persistent pain in the neck and shoulder area. He ordered an MRI of her cervical spine in September 1996 which demonstrated a small disc herniation on the right side at C6,7 innerspace. She was sent for epidural steroid injections, which were performed by Dr. James Artuso, of Anesthesia Associates of Lancaster. She completed this course of therapy, receiving excellent short term pain reI ief, but many of her symptoms in the shoulder, neck and upper back persisted. From September 1996 through March 1997 I've seen her on several occasions. Nost recently in December, 1996 she complained of intermittent numbness in her legs and at that time indicated she was having low back symptoms ever since her motor vehicle accident. This is the first I recall that she mentioned this in her history. She was referred back to Dr. Dragann and an MRI scan done in January 1997 showed simply some degenerative disc disease in the L4,5 region without any disc herniation. It should also be noted that in the fall of 1996, Deb was referred to Dr. Robert B. Frazier, a clinical psychologist, for treatment of depression.(part of which was certainly due to the fact that she was living in a state of fairly constant pain and discomfort). Brownstown Family Medical Center anoclatrd with [ph""" (ommunily Ho\pll,t1 .12'!" Orl',l.;lIl1 Plkt'. P. n ntl\ .11I1). 1110\\ 1\\111\\ n. 1'..\ 17illH -17171 B,I)-II.!i. 1.1\ 17171 Hjl)-2WJ/I January 27, 1998 A Pdt'j ( tlhl,j(. I U). lI'jlll,'/11 I. 11I1I,~"II1'1 k"l. IH) C 1J,1I/l1 ~IIII.IHl S"',1I11. ~lIrlh\\"II, Il.ll. 1IlIl,,'h,1I1 A SIll,I"",, 11 () Mr. David L. Lutz Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 Re: Debra L. Connor Date of Accident: 2/26/95 Dear Mr. Lutz: This is a letter in reference to your query in November regarding the question of a causal relationship of Mrs. Connor's low back pain to her motor vehicle accident in February 26, 1995. You are correct that I did indicate in my letter to you that I did not recall her mentioning low back pain before her December, 1996 office visit. I reviewed my progress notes, and found, in fact that on March 20, 1995 I indicated there was a 1umbo-sacral strain that was in my opinion at that time secondary to her accident. I did not document in the physical exam component of that visit an examination of her low back however. I note on September 11, 1995 that she is having mid-thoracic spasm, which is intermittent. In January 17, 1996 Dr. Sneller indicates she had a muscle spasm in the thoracic region and in September 17, 1996, at that point I indicate she's having increasing pain in the lumbar region and in my impression indicate that both her cervical pain and lumbar pain were secondary to her accident. This again is referenced in my August 25, 1997 progress note as well. As I review my April 7th letter to you, clearly my reference on page 4 failed to mention the above presented notations in my progress notes regarding her low back pain. My progress notes indicated that I did believe her low back injury to be causally related to her motor vehicle accident. On page 3, paragraph 3, in this same letter, I indicate I could not recall a previous mention of the numbness in her legs before December, 1996. After reviewing the records again, that was the first time I noted that particular symptom. Continued on page 2 o ii :c dj PATIENT: DEBRA L. CONNOR PAGE (2\ She was given a subacromial cortisone injection and received significant, but temporary, relief indicating at that time that her symptoms were primarily located in the subacromial area of the shoulder. Because of her eventual failure to respond to non-surgical treatment, she was taken to the Operating Room on 3/25/96 at which time she was felt to have a second degree sprain to the AC Joint, Impingement Syndrome, and a small tear of the rotator cuff. She underwent arthroscopy of the right shoulder with debridement, open acromioplasty and repair of the rotator cuff with partial distal clavicle resection. Initially, she was immobilized and started in a physical therapy program. Unfortunately, she developed adhesive capsulitis which considerably lengthened the need for therapy. She had intermittent flare ups of pain, but, overall, she made progress. Because of her continued neck pain, an MRI Scan was ordered. This showed osteophyte formation at C4/5, C5/6 and C6/7 and a small disc herniation at C6/7 on the right. A cervical epidural steroid injection was recommended. She also complained of pain in her low back since the accident. No abnormal neurologic findings were identified. When last seen by me on 3/26/97, Debra was making slow but steady progress with her right shoulder. She still had some discomfort in that area. She was also still having cervical and lumbar discomfort. I recommended an evaluation by our spinal specialist, Dr. Oliveri. He felt that she had multi-level cervical discogenic disease at C4/5, C5/6 and C6/7 with a right sided cervical disc herniation. He also felt that she had lumbar degenerative disc disease with symptomatic right lower extremity radiculitis and, finally, evidence of right shoulder impingement syndrome. o - :s :c .lj James Nealon, III, Esquire Page 2 November 21, 1997 Please let me know your answer as I may need to retain a medical bill expert. Very truly yours, 'd'~~ David L, Lutz DLL:mtg w ~ ~ .'r" "- "I, " "\'" '.." , ' ~-<'::--'-'- ~-::.+~~~.~'--~: '.:':'--'-=--~ ~?{f:~~~:~~~~f'<' ~'" ~a~~f~ :;;.;..~ ...........",................... ....", ..,., , , ~- .~ ',. ,:< ,:.1. J, "", ".'''''' . ... " VI. Exhibits 1, Photographs of the Plaintiff's vehicle: 2, Property damage estimates of the vehicles involved; 3, Medical records of the Plaintiff, VII, Settlement No offer has been made by the Defendant, however, the matter is currently being evaluated and counsel expects to have some settlement authority at the Pre-Trial Conference, Respectfully submitted, NEALON ~ GOVER - . --l-\--... // - '(' / .....)/ , \\ ~/-\ <-...~ By: - James G, Nealon,Esquire Atty, I.D. #46457 301 Market Street -- 9th Floor P,O, Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 .. '. t " AND NOW, this 18'h day of February, 1998, I hereby certify that I have served the foregoing Answer on the following by depositing a true and correct copy of same in the United States mails, postage prepaid. addressed to: David L. Lutz, Esquire ANGINO & ROVNER 4503 N. Front Street Harrisburg, PA 17110-1708 / C" \ - James G. Nealon, III. Esquire i ~' Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :, DEBRA CONNOR and HAROLD CONNOR, v, NO, 97-555 ALAN D, BERLIN, Defendant JURY TRIAL DEMANDED 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 and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator 4th Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 l06396/STU DEBRA CONNOR and HAROLD CONNOR, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v. CIVIL ACTION - LAW ALAN D, BERLIN, Defendant NO. 97-555 JURY TRIAL DEMANDED NOTICIA Le h" dem"d'do . 'nted en 10 cme. Si 'Sted q'iere defenderse de est.s dem.nd.s eXP'est.s en 1.s p.gin.s s'gn"entes, 'sted tiene viente '201 di.s de p1.,0 " P'rtir de 1. fech. de 1. dem"d. Y " notific,cion. Usted debe presentar 'os ,parienci. escrit. 0 en person. 0 Por 'bog'do Y 'rchiv., en 1. cor'e en form. escrit. S's defens.s 0 S's Objeciones . 1.s dem.nd.s en con'r. de so person.. 5" ,vi"do q'e s, 'S'ed no se defiende, 1. core, tom.r. medid.s Y P'ede entr.r on. orden con',. 'sted s'n previn ,viso 0 nO'ific'cion Y por C"'q'ier q'ej. 0 "ivio q'e es pedido on 10 Peticion de dem.nd.. Unted p'ede perdee dinero 0 s's proPiedades 0 otros derechos importantes para Usted. LLEVE ESTA DEMAND A A UN ABDGADQ I_DIATE.ENTE. 51 NO TIENE ABDGADQ 0 51 NO TIENE EL DINERO SUFICIENTE DE PAGAR TAt SERVICIO, VAYA EN PERSONA 0 LtAME POR TELEFONO A LA OFIClNA CU'A DIRECCION SE ENCUENTRA ESCRITA ASAJO PARA AVERIGUAR DDNDE SE PUEDE CDNSEGUIR ASISTENCIA LEGAL. COurt Administrator Cumberland County COurthouse 4th Floor Carlisle, PA 17013 (717) 240-6200 f l 7. As Mr, Berlin entered onto the bridge on Route 581 West, his Cadillac began to slid from side to side, :, 8. The rear passenger side of Mr, Berlin's vehicle violently collided into Mrs. Connor's driver's side door. 9. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiffs Debra and Harold Connor are the direct and proximate result of the negligent, careless, wanton and reckless manner in which the Defendant, Alan Berlin, operated his motor vehicle as follows: a. failure to stay within his lane of travel; b. failure to maintain control of his vehicle to avoid colliding into the driver's door of Mrs, Connor's vehicle; c. failure to travel at a safe speed given the road conditions; d. failure to drive his vehicle with due regard for the highway and traffic conditions which were existing and of which he was or should have been aware; e. failure to keep proper and adequate cor.trol over his vehicle; and f, dri ving his vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. CLAIM I Debra Connor v. Alan D. Berlin 10. Paragraphs 1 through 9 of the Complaint are incorporated herein by reference. 11. Plaintiff Debra Connor sustained painful and serious injuries, causing a serious impairment of bodily function, which 2 include but are not limited to acute cervical, thoracic, and lumbar strain/sprain, herniated disc at C 6-7, bruises on both feet, right knee, upper right posterior shoulder area, and right shoulder acromioclavicular tendinitis/bursitis impingement syndrome. 12. By reason of the aforesaid injuries sustained by Mrs. Connor, she was forced to incur liability for medical treatment, physical therapy, medications, hospitalization and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 13. Because of the nature of her injuries, Mrs. Connor has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 14. As a result of the aforementioned injuries, Mrs. Connor has undergone and in the future will undergo physical and mental suffering, inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 15. As a result of the aforesaid injuries, Mrs. Connor has been and in the future will be subject to humiliation and embarrassment, and claim is made therefor. 16. As a result of the aforementioned injuries, Mrs. Connor has sustained a serious injury and a serious impairment of bodily function. 17. As a result of the aforementioned injuries, Mrs. Connor has sustained work loss, loss of opportunity, and permanent 3 diminution of her earning power and capacity, and claim is made therefor. 18. As a result of the aforementioned injuries, Mrs. Connor has sustained uncompensated work loss and medical bills, and claim is made therefor. 19. As a result of the aforesaid accident, Mrs. Connor has sustained scars which will result in a permanent disfigurement, and claim is made thereto. 20. Mrs. Connor continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefor. CLAIM II Harold Connor v. Alan D. Berlin 21. Paragraphs 1 through 20 of the Complaint are incorporated herein by reference. 22. As a result of the aforementioned injuries sustained by his wife, Plaintiff Debra Connor, Plaintiff Harold Connor has been and may in the future be deprived of the care, companionship, consortium, and society of his wife, all of which will be to his great detriment, and claim is made therefor. WHEREFORE, Plaintiffs Debra and Harold Connor demand judgment against Defendant Alan Berlin in an amount in excess of Twenty-five Thousand Dollars ($25,000.00), exclusive of interest and costs and 4 ~ ,. C!. lJ": j- ";. '.! u,' , , ( ,- -, tV \ ~. . t,', (;1' ( -, Ut , L: to. --'. .- . 11._ r- () ~. C. a ~ --::8 ."" \~} "Q .~ \" J i"' I .- .~ ,. 8 Ll,' , r<) ,- , ...J ~ t,...; , 3 Lt. 0 C<' VI <. 1,"\ 0 0 ' ,~ 00 ~ . 'oj ::r l{) -:r \tJ ::r 91 '" 1; Tt -' CL .J -....I I , , , , , , ~ , , 1 ... , 1 $ , ml 1 , ml , l:lS , , .S en.... I .... , I ~l 'g , ....... I B c, c :~ ltl .~ 01 ~<l:"" ~ ~ '....' N "'''' :e ..... ~ 0 i ...1 ... .... U' g 2 J ~i =' . \0 '09 U11 ..:I.t: C1 , ,~ 88 I ... B''' '< :;jl . ~ .., U11 U'O . ..:1;2 N U11 C ~I '0 ,~~ ~I ltl.... . , il~ C UI ",-iM ~r-- ~ I >0 .... I I 2jU1 .... ~:z: , ....:z:~ I , , ~ , , , DEBRA CONNOR and HAROLD CONNOR, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW plaintiffs vs, NO, 97-555 ALAN D, BERLIN, Defendant JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE This is to certify that on the 21st day of February, 1997, the Complaint was mailed to Defendant, Alan D, Berlin, via certified mail, return receipt requested, at 410 Blacklatch Lane, Camp Hill, PA 17011. A copy of the certified mail receipt No, P 170 666 921 is attached hereto, ~~;ra.~ RETURN OF SERVICE This is to certify that on the 22nd day of February, 1997, the Complaint was served upon Defendant, Alan D, Berlin, via certified mail, return receipt requested at the above-noted address, A copy of the signed receipt No, P 170 666 92 is attached hereto, Sworn to and subscribed before me this .~Ij(\ day of \i~)(tI(I~\~L ,1997, '.___.M.'__..___.,__. v,- , ~.;f~_! \u. · C' 1 l r...~...r,' I .'..-:::.J'~'l;. ~"'"... (, ~ (J~'~ ttLj' nv ~E:1.I/C,--- ...,;'~,;,'.:".~.:';~.:' ; . . NotaryPliblic ._.__.-_._-._.....~;;..,,; .~..! My commission expires: I I l07159/MTG \ P 170 bbb 921 US PoslaJ Sorvice Receipt for Certified Mall No InllU,ane. Coverage PrtMded. 00 I lor IntornaUonaJ I SOB , Pol, PoIlIQO $ CenI6ed Fe. SpoaII 0eW0Iy F.. "",""'eel 0eW0Iy F.. '" s: AeIum Roc.... SI100Wlg 10 .- Whum & O..le Oe~.81.d a -""",~.-.. <I( DIII.1Adltes.w',Mttu 8" TOTAL P_ &F... $ ~ ~";;;Dl G\D, 1\-'17 lr ;Jr() '1 ... :1 'I z Ii 11~1-al~~h la~e tMp H." I 1/19- /'JDl J l~ 'J ;f I 5. Received By: (Print N/J1Il8) . . CompltI. bm. 1 1nCV0I 2 Jot addIUonII iMI't'Q.. 'COmPel' HImI3..c.. and 4b. .Pritt)'OW ~ n:J 1ddrH. on 1hI,..,.,.. of thAI tonn 10 INI... can"urn 1hI. _00 you. . Anach IhiI torm 10 lhe "anI of IhI mII1pIKle, or on (hi bIdt It aplOI doN not '~R~ RICWIpt ~~M themailplec;ebllowlhl.11idt runbeI. -The Relum RICIipt: willhow 10 whom 1M aItld, waf dehefed Iftdlhl dIIe -.ct, I 6, Slgnal~re: (Addre!&H or Agent) X JI PS Form 3811, December 1994 , " i I j f .. I I \ ( , I \ ~- <"J r~. Ii: ~'~ ,. f': , t:' ' ,~ (j' iC\ I' \ C' r.-' l. -, (.1 ,',J ...J '-:'- l.. C", .u t" I- t.... I ~ I... " f- l.) _,l C' '.J c-.. /.... t r I O'u:':r'! '..iT Lilvl,l.a ..... r' ?: q; M ..... ~ N '."ot: ") . - (. :'; ~:: ~ :"J:::! ~ ( . 0: ". ,'. . '\~-I c,Jp ... -,,- ct. :'t'f! 6c. [~;: :h u..:1~ -' CL: 1I.!~ ~~. oCt lin j"':': ::J: -, ~- u, <C ::> U l7' U