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HomeMy WebLinkAbout07-1223a. Stephen G. Held, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 (717) 233-3029 Fax E-mail: HELDa-hhrlaw.com Attorney for Plaintiff SHERI REED, Plaintiff V. GERALD L. HEICHEL, Defendant IN THE COURT OF COMMON PLEA5 CUMBERLAND COUNTY, PENNSYLVANIA NO.: 0 CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 r SHERI REED, V. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA GERALD L. HEICHEL, Defendant NO.. CIVIL ACTION - LAW AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYAA LASIGUIENTE OFICINA. ESTAOFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 I Stephen G. Held, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax: (717) 233-3029 Attorney for Plaintiff E-mail: HELDCc_hhrlaw.com SHERI REED, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA GERALD L. HEICHEL, Defendant : CIVIL ACTION-LAW COMPLAINT AND NOW, comes the Plaintiff, Sheri Reed, by and through their attorneys, HANDLER, HENNING & ROSENBERG, LLP, by Stephen G. Held, Esquire, and brings forth this Complaint against Defendant, Gerald L. Heichel, and avers as follows: 1. Plaintiff, Sheri Reed, is an adult individual currently residing at 529 Jonathan St., Shippensburg, Franklin County, PA 17257. 2. Defendant, Gerald L. Heichel, is an adult individual currently residing at 105 Milky Way, Shippensburg, Cumberland County, PA 17257. 3. At all times material hereto, Plaintiff, Sheri Reed, was an invitee of a friend at a wedding reception. 4. At all times material hereto, Defendant, Gerald L. Heichel was under the influence of alcohol. 5. On or about June 5, 2004, Defendant, Gerald L. Heichel approached Plaintiff, Sheri Reed, forcibly lifted her up off of the ground, violently spun her around in the air and suddenly and negligently, without warning, caused her to crash to the or ground. 6. As a direct and proximate result of the negligence of Defendant, Gerald L. Heichel, Plaintiff, Sheri Reed, sustained extensive and serious personal injuries, as set forth more specifically below. NEGLIGENCE SHERI REED v. GERALD L. HEICHEL 7. The occurrence of the aforementioned incident and all the resultant injuries to Plaintiff, Sheri Reed, are the direct and proximate result of the negligence of the Defendant, Gerald L. Heichel, generally, and more specifically, as set forth below: (a) In breaching the duty of ordinary care owed to Plaintiff as an invitee not to injure her; (b) In failing to approach and engage Plaintiff in a safe and reasonable manner; (c) In forcibly seizing Plaintiff; (d) In recklessly and carelessly lifting and spinning Plaintiff in a violent manner; (e) In allowing Plaintiff to fall from an elevated height, a height at which Defendant caused Plaintiff to be; (f) In failing to keep Plaintiff safe from a danger which Defendant himself negligently caused; (g) In exposing Plaintiff to a danger which she would not normally have encountered; and (h) In being under the influence of alcohol when exposing Plaintiff to the conditions listed more specifically above. r 8. As a direct and proximate result of the negligence of the Defendant, Gerald L. Heichel, Plaintiff, Sheri Reed, has suffered serious injuries, including but not limited to a concussion with brief loss of consciousness, increased pressure inside the head, neck strain, acute post-concussion syndrome, headaches, neck pain and stiffness, dizziness, subluxation and verticle fixation, increased anxiety and post traumatic stress disorder. 9. As a direct and proximate result of the negligence of Defendant, Gerald L. Heichel, Plaintiff, Sheri Reed, has suffered lost wages and may in the future continue to suffer a loss of income and/or loss of earning capacity. 10. As a direct and proximate result of the negligence of Defendant, Gerald L. Heichel, Plaintiff, Sheri Reed, has suffered physical pain, discomfort, and mental anguish, and she will continue to endure the same for an indefinite period of time in the future, to her physical, emotional, and financial detriment and loss. 11. As a direct and proximate result of the negligence of Defendant, Gerald L. Heichel, Plaintiff, Sheri Reed, has been compelled, in order to effect a cure for aforesaid injuries, to expend money for medicine and/or medical attention, and may be required to expend money for the same purposes in the future, to her detriment and loss. 12. As a direct and proximate result of the negligence of Defendant, Gerald L. Heichel, Plaintiff, Sheri Reed, has suffered a loss of life's pleasures, and she will continue to suffer the same in the future, to her detriment and loss. 13. As a direct and proximate result of the negligence of Defendant, Gerald L. Heichel, Plaintiff, Sheri Reed, has been, and will in the future be, hindered from attending to her daily duties, to her detriment, loss, humiliation, and embarrassment. WHEREFORE, Plaintiff, Sheri Reed, seeks damages from Defendant, Gerald L. Heichel, in an amount in excess of the compulsory arbitration limits of Franklin County, exclusive of interest and costs. Date: S 0 Respectfully submitted, HANDLER, EN ING & ROSENBERG, LLP By: _ io Step en G. eld, Esquire I.D. No. 72663 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiffs VERIFICATION THE UNDERSIGNED hereby verifies that the statements in the foregoing document are based on information that was gathered by counsel in preparation of this lawsuit. The language of the above-named document is of counsel and not my own. I have read the said document and, to the extent that it is based on information that I gave to courisei, ii is true and 'Corr Oct to the best of my knowledge, information, and belief. To the extent that the contents of the said document is that of counsel, I have relied upon my counsel in preparing this Verification. THE UNDERSIGNED also understands that the statements therein are made subject to the penalties of 18 Pa.R.C.P. 2252(d) C.S. Section 4904, relating to unsworn falsification to authorities. Date: -- 3-o/7 4'V__L:X I I heri Reed T? 6 3 IlJ ?? q ' 1 C v w c ra C*) w'7 0 -n 51--n _ .r CJ j f11 7 0 0 Stephen G. Held, Esquire I.D. #72663 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Tele: (717) 238-2000 Fax: (717) 233-3029 E-mail: HELDO-hhrlaw.com Attorney for Plaintiff SHERI REED, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA V. : NO.: 07-1223 CIVIL TERM GERALD L. HEICHEL, Defendant : CIVIL ACTION - LAW ACCEPTANCE OF SERVICE I accept service of the Complaint (on behalf of ?? ,,,--(" and certify that I am authorized to do so). (Date) O)efern'd5nt or Authonzed Agent) (Mailing Address) I Z:?_q 77C C7 i WFW/mspNS-111296 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, CIVIL DIVISION Plaintiff, No. 07-1223 vs. ANSWER AND NEW MATTER GERALD L. HEICHEL, Filed on Behalf of Defendant, Gerald L. Defendant. Heichel Counsel of Record for this Party: WALTER FREDRICK WALL, ESQUIRE PA. I.D. #23657 MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, P.L.L.C. 120 Lakemont Park Boulevard Altoona, PA 16602 Telephone No.: (814) 941-4600 Fax No.: (814) 941-4605 JURY TRIAL DEMANDED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED NOTICE TO PLEAD In accordance with Rules 1026 and 1361 of the Pennsylvania Rules of Civil Procedure, you are hereby notified to plead to the within ANSWER and NEW MATTER within twenty (20) days from service hereof or a default judgment may be entered against you. MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY: - ER FREDRICK ALL, SQUI Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 D # 23657 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED ANSWER AND NEW MATTER NOW COMES the Defendant, Gerald L. Heichel, by and through his counsel, MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC and files this Answer and New Matter to Plaintiff's Complaint of which the following is a statement: 1. The identity of the Plaintiff is admitted. The remaining allegations are denied in that after reasonable investigation, this Defendant lacks information sufficient upon which to form an opinion in regard to the truth of same. Strict proof of same is demanded at the time of trial. 2. Admitted. 3. Admitted. 4. Denied. 5. Denied as stated. On the contrary, at the time alleged, Defendant approached the Plaintiff and without improper intent, lifted her off the ground when Defendant lost his footing and fell to the ground with Plaintiff involuntarily falling upon the Defendant. 6. Denied in that after reasonable investigation, this Defendant lacks information sufficient upon which to form an opinion in regard to the truth of same and further denied as issues of law. Strict proof of same is demanded at the time of trial. NEGLIGENCE Sheri Reed v. Gerald L. Heichel 7. All allegations of negligence are denied. All allegations of injuries and/or damages and/or causation are denied as conclusions of law and that despite reasonable investigation, this Defendant lacks information sufficient upon which to form an opinion in regard to truth of same. Strict proof of same is demanded at the time of trial as to all subparagraphs. 8-13. All allegations of negligence are denied as conclusions of law and for reasons set forth above and hereinafter all of which are incorporated herein by reference thereto as if same were set forth at length. All allegations of injuries and/or damages causally related thereto are denied for reasons set forth above and hereinafter all of which are incorporated herein by reference thereto as if same were set forth at length and that in after reasonable investigation, this Defendant lacks information sufficient upon which to form an opinion in regard to the truth of same Strict proof of same is demanded at the time of trial. WHEREFORE, Defendant, Gerald L. Heichel, prays that Plaintiffs Complaint be dismissed. NEW MATTER 14. Plaintiff's damages are the direct, sole and proximate result of preexisting conditions. 15. Plaintiff's damages are the direct result of superceding, intervening events. 16. This Defendant has been advised that all affirmative defenses must be pled herein in order to preserve same as the facts are developed through discovery and, in light of same, pleads the defenses of contributory negligence of the Plaintiff; assumption of the risk by Plaintiff; and failure to mitigate damages by the Plaintiff. 17. Plaintiffs cause of action is barred under the Doctrine of Accord, Satisfaction and Release. MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY: WATER FREDRICK WALL, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID #23657 COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF BLAIR ) Personally appeared before me, the undersigned authority, a Notary Public in and for said State and County, Walter Fredrick Wall, who being duly sworn according to law, deposes and says that the allegations of facts set forth in the foregoing ANSWER & NEW MATTER, are true and correct to the best of his knowledge, information and belief and that the a Praecipe to Supplement the Verifications will be filed hereafter. X? alter Fredrick Wall Sworn to and subscribed before me this day of PV41 12007. Nota ubl' NOTARIAL SEAL Wndi S. pensyl, Notary Public Logan Twp., Blair Coon 9 2010,i My commission expires August CERTIFICATE OF SERVICE TO THE PROTHONOTARY: I, Walter Fredrick Wall, Esquire, of the law firm of MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, hereby certify that on this 16th day of April, 2007, 1 have served the foregoing Answer and New Matter on behalf of Defendant, Gerald L. Heichel, upon all counsel/parties of record, by mailing a true and correct copy of same by United States first class mail, postage prepaid as follows: Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY: w AVER FREDRICK WALL, LIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID # 23657 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED PRAECIPE FOR SUBSTITUTION OF VERIFICATION FOR ANSWER AND NEW MATTER TO THE PROTHONOTARY: Please file the attached Verification in Support of the Answer and New Matter, of Defendant previously filed on behalf of Defendant, Gerald L. Heichel. MEYER, DARRAGH, BUCKL R BEBENEK & ECK, PLLC BY: LTER FREDRICK WALL, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID # 23657 I, Gerald L. Heichel, do hereby verify that I have read the foregoing ANSWER AND NEW MATTER. The statements therein are true and correct to the best of my knowledge as to part, and based upon information and belief as to the rest. This statement is made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, I may be subject to criminal penalties. DATE:.-X-6 Z *d L610 'ON AVSZ :0l LOOT 'El *a dV --. CERTIFICATE OF SERVICE TO THE PROTHONOTARY: I, Walter Fredrick Wall, Esquire, of the law firm of MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, hereby certify that on this 26" day of April, 2007, 1 have served the foregoing Praecipe for Substitution of Verification to the Answer and New Matter on behalf of Defendant, Gerald L. Heichel, upon all counsel/parties of record, by mailing a true and correct copy of same by United States first class mail, postage prepaid as follows: Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY: ALTER FREDRICK WA ,ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 I D # 23657 n ? ? t ,?., mss' 4 ; %? -T7 G3 4?!. ! ? ^'t" ? ;?..1'; . ? '.' i lam tom/ ..? . r ,. ;y ? Stephen G. Held, Esquire I.D.#72663 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax: (717) 233-3029 E-mail: HELDA-hhrlaw.com Attorney for Plaintiffs SHERI REED, V. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA : NO.: 07-1223 CIVIL TERM GERALD L. HEICHEL, . Defendant : CIVIL ACTION - LAW PLAINTIFF'S REPLY TO NEW MATTER OF DEFENDANT AND NOW, comes the Plaintiff, Sheri Reed, in her own right, by and through her attorneys, HANDLER, HENNING & ROSENBERG, LLP, by Stephen G. Held, Esquire, who answers New Matter of Defendant as follows: 14. The averment of this paragraph is a conclusion of law to which no responsive pleading is required. To the extent this averment may be deemed factual, it is hereby denied. By way of amplification, Plaintiffs damages are the direct, sole and proximate result of Defendant's negligence. 15. The averment of this paragraph is a conclusion of law to which no responsive pleading is required. To the extent this averment may be deemed factual, it is hereby denied. By way of amplification, Plaintiffs damages are the direct result of Defendant's negligence. 16. The averment of this paragraph is a conclusion of law to which no responsive pleading is required. To the extent this averment may be deemed factual, it is hereby denied. By way of amplification, Plaintiff was not contributorily negligent; Plaintiff did not assume the risk of her injuries; and Plaintiff did not fail to mitigate her damages. 17. The averment of this paragraph is a conclusion of law to which no responsive pleading is required. To the extent this averment may be deemed factual, it is hereby denied. By way of amplification, Plaintiffs cause of action is not barred under the Doctrine of Accord, Satisfaction and Release. WHEREFORE, Plaintiff respectfully requests this Court dismiss Defendant's Answer and New Matter and enter judgment in her favor. Respectfully submitted, HANDLE HEN I G & ROSENBERG, LLP Date: By: E44hdfi G. Held, Esquire I.D. # 72663 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorneys for Plaintiff VERIFICATION PURSUANT TO PA R.C.P. NO. 1024 (c) STEPHEN G. HELD, ESQUIRE, states that he is the attorney for the party filing the foregoing document; that he makes this affidavit as an attorney, because the party he represents lacks sufficient knowledge or information upon which to make a verification and/or because he has greater personal knowledge of the information and belief than that of the party for whom he makes this affidavit; and that he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa C.S. §4904 relating to unsworn falsification to authorities. Date: ST HE G. HELD, ESQUIRE SHERI REED, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA V. : NO.: 07-1223 CIVIL TERM GERALD L. HEICHEL, Defendant : CIVIL ACTION - LAW CERTIFICATE OF SERVICE AND NOW, this -, ? day of , 2007, 1 hereby certify that I have served the within document upon Counsel of Record by sending a true and correct copy of the same to them via First Class United States mail, postage prepaid, and addressed as follows: First Class U. S. Mail. Walter F. Wall, Esq. Myer, Darragh, Buckler, Bebenek & Eck, P.L.L.C. 120 Lakemont Park Blvd. Altoona, PA 16602 HANDLER, HENNING & ROSENBERG, LLP Maria Wells, Legal Secretary to Stephen G. Held, Esquire N `_" L i t ii ?~ GJ V ?f WFW/c1c/US-111296 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant, Gerald L. Heichel, certifies that: (1) a Notice of Intent to serve a subpoena with a copy of the subpoena attached thereto has been mailed to counsel of record, (2) a copy of the Notice of Intent, including the proposed subpoena, is attached to this certificate, (3) counsel for the parties have consented to waive the twenty (20) day objection period, and (4) the subpoena which will be served is identical to the subpoena which is attached to the Notice of Intent to serve the subpoena. MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY: •'` ER FREDRICK WALL, SQ IRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID #23657 V t1 WFW/c1c/US-111296 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant, Gerald L. Heichel, intends to serve a subpoena identical to that which is attached to this notice. Counsel have consented to service of this subpoena. No objection has been made and the subpoena may be served. MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY: ER FREDRICK WALL, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 I D # 23657 Date: June 21, 2007 CERTIFICATE OF SERVICE TO THE PROTHONOTARY: I, Walter Fredrick Wall, Esquire, of the law firm of MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, hereby certify that on this 21S1 day of June, 2007,1 have served the foregoing Notice of Intentto Serve a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 and Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 on behalf of Defendant, Gerald L. Heichel, upon all counsel/parties of record, by mailing a true and correct copy of same by United States first class mail, postage prepaid as follows: Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Altoona, PA 16602 Phone No.: (814) 941-4600 I D # 23657 MEYER, DAR BUCKLER, BEBENEK ECK, PLLC BY• WALL, ESQUIRE Counsel for Defendant, Gerald L. Heichel WALTER 120 Lakemont Park FR RICK Boulevard r _ rC't ? W PRAECIPE FOR LISTING CASE FOR ARGUMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, CIVIL DIVISION No. 07-1223 vs. GERALD L. HEICHEL, Defendant. JURY TRIAL DEMANDED 1. State matter to argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): Defendant's Motion to Compel 2. Identify counsel who will argue case: (a) for plaintiff: Stephen G. Held, Esquire Address: Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 (b) for defendant: Walter F. Wall, Esquire Address: Meyer Darragh 120 Lakemont Park Blvd. Altoona, PA 16602 3. 1 will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: 8/15/07 (time to be announced by Court) Dated: June 25, 2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED ORDER AND NOW this day of , 2007, upon consideration of the Motion to Compel, it is hereby ORDERED, DIRECTED and DECREED that Plaintiff, Sheri Reed, fully and completely answer the Request for Production and Interrogatories within fifteen (15) days of the date of this Order. BY THE COURT: J. W FW/NDC/msp/US-111296 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, CIVIL DIVISION Plaintiff, No. 07-1223 vs. MOTION TO COMPEL GERALD L. HEICHEL, Filed on Behalf of Defendant, Gerald L. Defendant. Heichel Counsel of Record for this Party: WALTER FREDRICK WALL, ESQUIRE PA. I . D. #23657 MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, P.L.L.C. 120 Lakemont Park Boulevard Altoona, PA 16602 Telephone No.: (814) 941-4600 Fax No.: (814) 941-4605 JURY TRIAL DEMANDED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, CIVIL DIVISION No. 07-1223 vs. GERALD L. HEICHEL, Defendant. JURY TRIAL DEMANDED MOTION TO COMPEL NOW COMES the Defendant, Gerald L. Heichel, by and through his counsel, MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC and files this Motion to Compel of which the following is a statement: 1. Plaintiff commenced this personal injury action by filing for a Writ of Summons on or about February 11, 2005. 2. This Defendant served upon the Plaintiff Interrogatories Directed to Plaintiff and a Request for : Production of Documents by mailing, first class, prepaid postage on or about February 21, 2007, directed to: Sheri Reed c/o Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 3. Plaintiff failed to respond to the requested discovery within thirty (30) days as required by the Pennsylvania Rules of Civil Procedure. 4. On or about May 23, 2007, after a period in excess of ninety (90) days, counsel for moving Defendant by letter addressed to Plaintiff's counsel requested full responses be received within fifteen (15) days. (A true and correct copy of said letter is marked as Exhibit "A" and attached hereto). 5. Plaintiff has failed or refused to supply the requested discovery. 6. Plaintiffs failure or refusal to supply the requested discovery is prejudicial to this Defendant's ability to defend against the claims asserted in Plaintiff's Complaint. WHEREFORE, Defendant, Gerald L. Heichel, respectfully requests that this Court enter an Order directing Plaintiff to file full and complete answers to Defendants Interrogatories and Request for Production of Documents within fifteen (15) days of the Court's Order. MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY: T R FREDRICK WALL, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 I D # 23657 r ' MEYER ? DARRAGH NEM BUCKLER BEBENEK & ECK, P.L.L.C. DARRAGH Attorneys-at-Law ® 120 Lakemont Park Boulevard ? Altoona, PA 16602 www.mdbbe.com Phone: (814) 941-4600 ? Fax: (814) 941-4605 Walter F. Wall Telephone: (814) 941-4600, ExL 120 Attomey at Law May 23, 2007 Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 RE: Sheri Reed v. Gerald L. Heichel Franklin County, No. 2005-00380 Our File No. US-111296 Dear Attorney Held: This matter comes out of diary in I note that we served Interrogatories and a Request for Production on February 21St. Obviously it is not my practice to insist upon Answers-Within the 30 days provided by the rules, however, the discovery has now been outstanding for 90 days. Please ensure that we receive full responses within the next 15 days. Yours very truly, alter Fredrick all WFW/clc CERTIFICATE OF SERVICE TO THE PROTHONOTARY: I, Walter Fredrick Wall, Esquire, of the law firm of MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, hereby certify that on this 26th day of June, 2007, 1 have served the foregoing Motion to Compel on behalf of Defendant, Gerald L. Heichel, upon all counsel/parties of record, by mailing a true and correct copy of same by United States first class mail, postage prepaid as follows: Stephen G. Held, Esquire Handier, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY: ALTER FRE RICK WA , ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID # 23657 C'1 c-3 tt'1 CO r7 W F WIN DC/m s p/U S-111296 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, CIVIL DIVISION Plaintiff, No. 07-1223 vs. MOTION TO COMPEL GERALD L. HEICHEL, Filed on Behalf of Defendant, Gerald L. Defendant. Heichel Counsel of Record for this Party: WALTER FREDRICK WALL, ESQUIRE PA. I . D. #23657 MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, P.L.L.C. 120 Lakemont Park Boulevard Altoona, PA 16602 Telephone No.: (814) 941-4600 Fax No.: (814) 941-4605 JURY TRIAL DEMANDED . PRAECIPE FOR LISTING CASE FOR ARGUMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED 1. State matter to argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): Defendant's Motion to Compel 2. Identify counsel who will argue case: (a) for plaintiff: Stephen G. Held, Esquire Address: Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 (b) for defendant: Walter F. Wall, Esquire Address: Meyer Darragh 120 Lakemont Park Blvd. Altoona, PA 16602 3. 1 will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: Dated: July 2, 2007 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, CIVIL DIVISION No. 07-1223 vs. GERALD L. HEICHEL, Defendant. AND NOW this day of JURY TRIAL DEMANDED ORDER 2007, upon consideration of the Motion to Compel, it is hereby ORDERED, DIRECTED and DECREED that Plaintiff, Sheri Reed, fully and completely answer the Request for Production and Interrogatories within fifteen (15) days of the date of this Order. BY THE COURT: J. w- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED MOTION TO COMPEL NOW COMES the Defendant, Gerald L. Heichel, by and through his counsel, MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC and files this Motion to Compel of which the following is a statement: 1. Plaintiff commenced this personal injury action by filing for a Writ of Summons on or about February 11, 2005. 2. This Defendant served upon the Plaintiff Interrogatories Directed to Plaintiff and a Request for : Production of Documents by mailing, first class, prepaid postage on or about February 21, 2007, directed to: Sheri Reed c/o Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 3. Plaintiff failed to respond to the requested discovery within thirty (30) days as required by the Pennsylvania Rules of Civil Procedure. 4. On or about May 23, 2007, after a period in excess of ninety (90) days, counsel for moving Defendant by letter addressed to Plaintiff's counsel requested full responses be received within fifteen (15) days. (A true and correct copy of said letter is marked as Exhibit "A" and attached hereto). 5. Plaintiff has failed or refused to supply the requested discovery. 6. Plaintiffs failure or refusal to supply the requested discovery is prejudicial to this Defendant's ability to defend against the claims asserted in Plaintiff's Complaint. WHEREFORE, Defendant, Gerald L. Heichel, respectfully requests that this Court enter an Order directing Plaintiff to file full and complete answers to Defendants Interrogatories and Request for Production of Documents within fifteen (15) days of the Court's Order. MEYER, DARRAGIA BUCKLER, BEBENEK & EJqK, PLLC WALTER FREDRICK WALL, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID # 23657 . 1 -% CERTIFICATE OF SERVICE TO THE PROTHONOTARY: I, Walter Fredrick Wall, Esquire, of the law firm of MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, hereby certify that on this 26" day of June, 2007, 1 have served the foregoing Motion to Compel on behalf of Defendant, Gerald L. Heichel, upon all counsel/parties of record, by mailing a true and correct copy of same by United States first class mail, postage prepaid as follows: Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 MEYER, DARRAG BUCKLER, BEBENEK & ECK, PLLC Y: WALTER FREDRICK WALL, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID # 23657 r-..1 C ? ?i l .. .- ?! ?2 ?.?_ » ,? ;,? r`? e ?? t)?', _' -a= ,-? % --G .? ? PRAECIPE TO WITHDRAW LISTING OF CASE FOR ARGUMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please withdraw the listing of this case for Argument on August 15, 2007 and send same to Court for Argument on Discovery Motions. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, CIVIL DIVISION No. 07-1223 vs. GERALD L. HEICHEL, Defendant. JURY TRIAL DEMANDED State matter to argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): Defendant's Motion to Compel 2. Identify counsel who will argue case: (a) for plaintiff: Stephen G. Held, Esquire Address: Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 (b) for defendant: Walter F. Wall, Esquire Address: Meyer Darragh 120 Lakemont Park Blvd. Altoona, PA 16602 MEYER, DARRA H, BUCKLER, BEBENEK & ECK, PLLC Y: WALTER FRE RICK WALL, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID # 23657 Dated: July 2, 2007 ?y ? s? ? ? Y? ? a ? ? ;, x t.f't { -? ?, ?.`? ?? `?_ -r? .. - ? - 51' :? ?-, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED PRAECIPE TO AMEND MOTION TO COMPEL PURSUANT TO LOCAL RULE 208.3(a) (2) No Judge has ruled upon any other issue in this case. (9) Counsel for moving party attempted to seek compliance with the Rules and concurrence from opposing counsel by letter of May 23, 2007 (see Exhibit "A" to Motion). No other attempts at concurrence were made prior to filing the Motion to Compel filed on or about June 26, 2007, a copy of which was forwarded by regular mail to Plaintiff's counsel. MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY: ` LTER FREDRICK WALL, SQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID # 23657 CJ ? ? r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED RULE NOW THIS day of , 2007, a Rule is hereby issued upon Plaintiff, Sheri Reed, to show cause, if any there should be, why the Motion to Compel of Defendant, Gerald L. Heichel, should not be granted. Said Rule Returnable the ?b day of , 2007, at o'clock, .m., Courtroom No. , Cumberl County Cou ouse, Carlisle, Pennsylvania. J. RE: Failure to Comply with Cumberland County Local Rule 208 Page 1 of 1 Calvanelli, Melissa From: Calvanelli, Melissa Sent: Wednesday, July 11, 2007 9:33 AM To: 'Walter Fredrick Wall (wwall@mdbbe.com)' Subject: RE: Notice of Failure to Comply with Local Rule SECOND NOTICE Melissa H. Calvanelli Assistant Court Administrator Cumberland County -----Original Message----- From: Calvanelli, Melissa Sent: Friday, July 06, 2007 4:00 PM To: 'Walter Fredrick Wall (wwall@mdbbe.com)' Subject: Notice of Failure to Comply with Local Rule RE: Failure to Comply with Cumberland County Local Rule 208.3(a) Motion to Compel (07-1223 - Reed v. Heichel) Dear Mr. Wall: Please note that due to your failure to comply with Cumberland County Local Rule 208.3 (a)(2) and/or Rule 208.3(a)(9), your motion will be held in the Court Administrator's Office until an amendment containing the missing information is filed in the Prothonotary's Office. Rule 208.3(a). Motions. (2) The motion shall state whether or not a Judge has ruled upon any other issue in the same or related matter, and, if so, shall sped the judge and the issue. (9) All motions and petitions shall contain a paragraph indicating that the concurrence of any opposing counsel of record was sought and the response of said counsel; provided, that this requirement shall not apply to preliminary objections, motions for judgment on the pleadings, motions for summary judgment, petitions to open or strike judgments, and motions for post-trial relief. Please note that you do not need to file an additional proposed order or provide additional envelopes for service. Your amendment will be attached to the original motion. Please feel free to contact me if you have any questions or concerns regarding this matter. Sincerely, Melissa H. Calvanelli Assistant Court Administrator 7/11/2007 oguu L019 1/9 pagtpoIN ?oop•IItnuuW SuilnpagoS o2pyg\IdN'I0\salt31ausalul favioduiaZ\sButjjaS juoo-j\XuogfWw)l\s2uijjoS puu sjuauznooQ\:D d\ gWVNg'II3 ? 04u9 aouazaJuOD oaptA joilo algnoa -S1 32ppu aouaaajuOD oaptA 01 IIOJ3S 't I 442WJOM ON \ BOWO p ano ¦ amMuaj ¦ Mng ? a :awi„wa buy Moog ssaJPPV w04 PPd :awp>w 6uge9w . su W , lo:b oo:£ oo: (MaIA h(l) 404 I :uaoZ 16ullnpa ps [ loddb AUJ P3ueD V ...a:)ua,ulbaQd ^4i W Puri Pi suoAR w0i MIAA ljasul M* va 49 ?IOOS SSUNG(IV NIO2Id QQV asoogD '£I ? ? r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY: WALTER FREDRICK WALL, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID # 23657 GERALD L. HEICHEL, Defendant. TO THE PROTHONOTARY: CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Walter Fredrick Wall, Esquire, of the law firm of MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, hereby certify that on this 26th day of July, 2007, 1 have served the foregoing Rule on behalf of Defendant, Gerald L. Heichel, upon all counsel/parties of record, by mailing a true and correct copy of same by United States first class mail, postage prepaid as follows: ±Eal IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED RULE 1?? NOW THIS 2? ok day of , 2007, a Rule is hereby issued upon Plaintiff, Sheri Reed, to show cause, if any there should be, why the Motion to Compel of Defendant, Gerald L. Heichel, should not be granted. Said Rule Returnable the Ito day of , 2007, at o'clock, f.m., Courtroom No. , Cumberla County Cou ouse, Carlisle, Pennsylvania. J. C, _ j CJ A. WFW/cIGUS-111296 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant, Gerald L. Heichel, certifies that: (1) a Notice of Intent to serve a subpoena with a copy of the subpoena attached thereto has been mailed to counsel of record, (2) a copy of the Notice of Intent, including the proposed subpoena, is attached to this certificate, (3) counsel for the parties have consented to waive the twenty (20) day objection period, and (4) the subpoena which will be served is identical to the subpoena which is attached to the Notice of Intent to serve the subpoena. MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY' !-4-z? - ALTER FREDRICK WALL, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID # 23657 . WFWlcIGUS-111296 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. GERALD L. HEICHEL, SHERI REED, Plaintiff, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant, Gerald L. Heichel, intends to serve a subpoena identical to that which is attached to this notice. Counsel have consented to service of this subpoena. No objection has been made and the subpoena may be served. MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY: WALTER FREDRICK WALL, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID # 23657 Date: July 26, 2007 .. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Sheri Reed, Plaintiff VS. Gerald L. Heichel, Defendant. File No. 07 - 1223 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Progressive Specialty Insurance Company, Philadelphia Claims Office TO:Att:.Tyeddie L. Williams, (2145) 5165 Campus Drive, Plymouth Meeting, PA 19462. (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: " le: Sheri A. Reed, 529 Jonathan St., Shippensburg, PA 17257, DOB: 3/29/76, SSN: 186-56-0892, )/L: 11/19/05, Claim No.: 057191743 & 0120057191743 - A full and complete copy of the entire claims Eile on Sheri Reed for a.mva occurring on or about, 11/19/05, including, but not limited to, PIP )enefits paid - wage loss and medicals, any statements, written or oral, application for benefits, nedical reports, IME, etc. at120 Lakemont Park Boulevard. Altoona. PA 16602 (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 parry 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: NAMEWalter Fredrick Wall. Esquire ADDRESS:120 Lakemont Park Boulevard Altoona. PA 16602 TELEPHONE: (814) 941-4600 SUPREME COURT ID # 2365 7 ATTORNEY FOR: Defendant, Gerald I. Date: 11,4,1 Q ' S al the Court Heichel BY THE COURT: d.it? P. C'mq Prothonotary, Civil Divi n A-fu eputy 0 ILI) mcl-` t_. 13 t?s .?.?? ern IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. TO THE PROTHONOTARY: CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED PRAECIPE Please withdraw the Defendant's Motion to Compel Plaintiff's Answers to Interrogatories and Responses to Request for Production of Documents currently scheduled for hearing on August 16, 2007 at 4:00 p.m. MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY: WALTER FREDRICK WALL, ESQUIRE Counsel for Defendant 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No. (814) 941-4600 PA I.D. #23657 l C'n X- WFW/MLWcIGUS-111296 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. PRAECIPE TO WITHDRAW/ENTER APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Walter Fredrick Wall, Esquire, as counsel for Defendant, Gerald L. Heichel, in the above-captioned matter. TO THE PROTHONOTARY: CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED MEYER, DARRAGH, BUCKLER BEBENEK & ECK, PLLC BY: LT R FREDRICK WALL, ESQUIRE 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID # 23657 Please enter my appearance as counsel for Defendant, Gerald L. Heichel, in the above- captioned matter. F? MEYER, DAR BUC ER,13EB EK & ECK, PLLC BY: RY LOU' IE O , ESQUIRE 20 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 I.D. #62175 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. TO THE PROTHONOTARY: CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Mary Lou Maierhofer, Esquire, of the law firm of MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, hereby certify that on this 13' day of November, 2007, 1 have served the foregoing Praecipe to Withdraw/Enter Appearance on behalf of Defendant, Gerald L. Heichel, upon all counsel/parties of record, by mailing a true and correct copy of same by United States first class mail, postage prepaid as follows: Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 MEYER, DAR H, BU LE , BEQLNEK & ECK, PLLC BY: MARY U AIER ER, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No.: (814) 941-4600 ID # 62175 C3 ° P R 73-u ???, Jrn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, CIVIL DIVISION No. 07-1223 vs. GERALD L. HEICHEL, Defendant. JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant, Gerald L. Heichel, intends to serve subpoenas identical to the ones that are attached to this notice upon Chambersburg Hospital; Cinda A. Liggon, M. D.; Connexus Pharmacy System, Wal-Mart Pharmacy; Cumberland Valley Family Physicians; Eckerd Drugs # 6664; Giant Pharmacy #61; IESI; Larry D. Walker, PhD; Liana I. Laza, M.D.; Margaret Copenhaver, PhD, L.P.C.; Moose Family Fraternity, Chapter2153; Moose Family Fraternity, Lodge 2500; Senior Life; Wellspan Behavioral Health; Social Security Administration; Jason K. Bosko, D.C., Chambersburg Chiropractic; and Norland Avenue Pharmacy. 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 objection is made the subpoenas may be served. MEYEF?j,A ( 0JCKLER, BEBENEK & ECK, PLLC BY: M M I OFER, ESQUIRE Counsel for rald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 (814) 941-4600 I. D. #62175 Date: June 19, 2008 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintif f File No. 07-1223 VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 186-56-0892 TO: rhambersburg Hospital (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: =plete copy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994 through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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: Marv Lou Maierhofer ADDRESS:,Meyer, Darragh, Buckler, 120 Lakemont Park Blvd. Altoona, PA 16602 TELEPHONE: (914) 941-4600 SUPREME COURT ID # _6 217 5 ATTORNEYFOR: Tefendant Date: 5 o7Q 08 "Se of the Court Debenek, & Eck BY THE CO Proth aotary, Civil Di Deputy COMMONWEALTH OF PENNSYLVANIA. COUNTY OF CUMBERLAND SHERI REED Plaintiff Fi3eNo. 07-1223 VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR TRINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 186-56-0892 TO: C;nda A Liggon. M.D., 533 South Main Street, Chambersburg, PA 17201 (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: Complete copy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic. studies, telephone logs, records of other health care providers, etc., from 1994:through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 maldng 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: Marv Lou Maierhofer ADDRESS:'-Meyer, Darragh, Buckler, 120 Lakemout Park Blvd. Altoona,- PA 16602 TBUPHONE: ($14) 941-4600 SUPREME COURT ID# 62179 A'ITORNEY FOP- Defendant _ Date: 5 c? 0 'Seal o the Court Bebenek, & Eck BY THE CO Pro notary, Ci ' ion Deputy COMMONWEALTH OF PENNSYLVANIA COUN'T'Y OF CUMBERLAND SHERI REED Plaintiff File No. 07-1223 VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3 / 2 9 / 7 6 186-56-0892 TO: Connexus_Tharmacy System, Wal-Mart Pharmacy (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: Co= ete copy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994'through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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: Marv Lou Maierhofer ADDRESS:`Meyer, Darragh, Buckler, 120 L emont Park Blvd Altoona, PA 16602 TELEPHONE: (814) 941-4600 SUPREME COURT ID # 6 217 5 ATTORNEYFOR: Defendant Date- UWfthe Court Bebenek, & Eck BY THE COUR Protho otary, Civil D' Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff File No. 07-122*3 vs. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3 / 2 9 / 7 6 186-56-0892 TO: Cumberland Valley Family Physicians (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: ca=iete copy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health-care providers, etc., from 1994'through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 requited 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: Marv Lou Maierhofer ADDRESS:Neyer, Darragh, Buckler, 120 Lakemiont Park Blvd Altoona, PA 16602 TELEPHONE: (81) 941-4600 SUPREME COURT ID # 6 217 5 ATTORNEYFOR: Defendant Date: 5 o't9 D Q 'Se of the Court 1ebenek, & Eck BY THE CO Pro -notary, Civi] Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintif f File No. 07-1223 VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE; Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 186-56-0892 TO: Eckerd Drugs 46664 300 South Fayette St., Shippensburg, PA 17257 (Name of Person or Fntity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: cn=lete copy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994'through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 malting 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: Marv Lou Maierhof er ADDRESS:,Meyer, Darragh, Buckler, 120 Lakemont Park Blvd. Altoona, PA 16602 TELEPHONE: (814) 941-4600 SUPREME COURT ID # 47175 ATTORNEY FOR: T)P-f endant Date: a'? ' Seal of a Court Bebenek, & Eck BY THE CO T: Ci ' sio PrAonotary, Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff . File No. 07-1223 VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3 / 2 9 / 7 6 186-56-0892 TO:Giant Pharmacy #61, 397 Baltimore Road, Shippensburg, PA 17257 (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.- co=lete copy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994:through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (Address) You may deliver or mail legEble 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. THUS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Marv Lou Maierhofer ADDRESS:Mever, Darragh, Buckler, 190 7.akemont Park Blvd Altoona, PA 16602 TELEPHONE: (814) 941-4600 SUPREME COURT ID # h 21 7 5 ATTORNEYFOR: nefendant Date: 5 44 O9 S &I o the Court $ebenek, & Eck BY THB wwid4 othono Di ' on Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff VS. GERALD L. HEICHEL Defendant File No. 07-1223 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 18.6-56-0892 TO: IESI, P.O. Box.399, Scotland, PA 17254 (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: Emnlovment applications, work history, including attendance records, --doctor excuses, incident reports, employer physical exams, disability insurance benefits or applications, W2 forms, wage information, any and all documentation relating to-workers' compensation, notice of-En-jury, statement of wages,.benefits, etc. as well as a complete copy of'the personnel e, . at 120 Lakemont Park Blvd, Altoona, PA 16602 (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. TIM SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Marv Lou Maierhofer ADDRESS:Meyer. Darragh. Buckler. 12() Lakpmont Park Blyci - Alteeua,-PA-16602 TELEPHONE: SUPREMECO 62175 ATTORNEY FOR. Defendant Date: 5 4 'Sea of a Court Bebenek, & Eck BY THE CO 16 Pro onotary, Civil Di Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff File No. 07-1221 VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR TMNGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3 / 2 9 / 7 6 186-56-0892 TO:Larry D. Walker. PhD, 3544 North Progress Ave., Suite 110, Harrisburg, PA (Name of Person or Entity)' 17110 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994'through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 malting 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: Marv Lou Maierhofer ADDRESS:,Meyer, Darragh; Buckler, 120 7akemont Park Blvd Altoona, PA 16602 TELEPHONE:( 814) 941-4600 SUPREME COURT ID # 62175 ATTORNEY FOR: Ile f endan t _ Date: '6 a 9 0 - S 1 of a court Bebenek, & Eck BY THE CO P onotary , Ci ' sro Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff File No. 07-1 223 VS. GERALD L. HEICHEL , Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 186-56-0892 TO: Liana I. Laza, M.D., Pennsylvania _Neurological Associates. Ltd (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: _Complete cove of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, _correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994 through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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: Marv Lou Maierhofer ADDRESS:`Meyer, Darragh, Buckler, 120 Lakemont Park Blvd. Altoona, PA 16602 TELEPHONE: 814) 941-4600 SUPREME COURT ID # 6 217 5 ATTORNEYFOR Defendant Date: J?oZ9 O. ' Seal f th Court Bebenek, & Eck BY THE CO T: Pro notary visio Deputy COMMONWEALTH OF PENNSYLVANIA. COUNTY OF CUMBERLAND SHERI REED Plaintiff File No. 07-1223 VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR TIQNGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3 / 2 9 / 7 6 186-56-0892 TO: Margaret Copenhaver, PhD, L.P.C. (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: c'nn=ie cogy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994'through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 malting 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: Marv Lou Maierhofer ADDRESS:-,Meyer, Darragh, Buckler, 190 Lakemont Park Blvd Altoona, PA 16602 TELEPHONE: (81_4 941-4600 SUPREME COURT ID # 6 217 5 ATTORNEYFOR: Defendant Date: 549 0 'Seal of a Court Bebenek, & Eck BY THE C T: P thonotary, Ci ' vis n Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff VS. GERALD L. HEICHEL Defendant File No. 07-1223 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 186-56-0892 TO:_ Moose Family Fraternity, Chapter 2153, P.O. Box 597, Shippensburg, PA 17257 (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: Employment applications, work history, including attendance records, - - --doctor excuses, incident reports, employer physical exams, disability insurance benefits or applications, W2 forms, wage information, any and all documentation relating to workers compensation, notice o injury, statement of wages, benefits, etc. as well as a complete copy of'the personnel i e, frog t95M uhrough the . at 120 Lakemont Park Blvd, Altoona, PA 16602 (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.. Yu 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: Marv Lou Maierhofer ADDRESS:Meyer. Darragh. Buckler. 120 Lakemont Park Blvd A-31-QQZ12 RA 16609 TELEPHONEF (R14) 941-4600 SUPREME CO 62175- ATTORNEY FOR: Defendant _ Date S10191,02 'Se of Court Bebenek, & Eck BY THE URT: P onotary, Ci si Deputy COMMONWEALTH OF PENNSYLVANIA COUN'T'Y OF CUMBERLAND SHERI REED File No. 07-1223 Plaintiff VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 186-56-0892 TO: Moose Family Fraternity, Lodge 2500, 32 Walnut Bottom Road, Shippensburg, PA (Name of Person or Entity) 17257 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Employment applications, work history, including attendance records, - doctor excuses, incident reports, employer physical exams, disability insurance benefits or applications, W2 forms, wage information, any and all documentation relating to workers compensation, notice o injury, statement of wages,.benefits, etc. as well as a complete copy of'the personne Me, m 1994 rhrough the . at 120 Lakemont Park Blvd, Altoona, PA 16602 (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. '&u 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: Marv Lou Maierhofer ADDRESS:M_yer. Dafragh, Buckler. 120 Lakamnnr Park Blvd All-oona, PA -16602 TELEPHONE: SUPREME CO 6 217 5 ATTORNEY FOR Defendant Date: oZ 9 0? .Seal f the Court Bebenek, & Eck BY THE T: Othonoiti Cv1S1 Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff VS. GERALD L. HEICHEL Defendant File No. 07-122 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 186-56-0892 TO: Senior Life, 300 Red Brook Blvd, Owings Mills, MD 21117 (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: Employment applications, work history, including attendance records, --doctor excuses, incident reports, employer physical exams, disability insurance benefits or applications, W2 forms, wage information, any and all documentation relating to workers compensation, notice o injury, statement of wages, benefits, etc. as well as a complete copy of-the personnel at 120 Lakemont Park Blvd, Altoona, PA 16602 (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: Marv Lou Maierhofer ADDRESS:Meyer. Darragh. Buckler, 12 Ta amnnt Park Rlvd RA 166019 TELEPHONE: 941-460Q SUPREME CO 62175 ATTORNEY FOR. Defendant oZ D Date: 15 'Seal of d(e Court Bebenek, & Eck BY VOURT: othonota Di ion Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff File No. 07-1223 VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENT'S OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 16 1829/86-566-0892 TO: Well man Behavioral Health (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: Complete copy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994'through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 flings 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: Marv Lou Maierhofer ADDRESS:,Meyer, Darragh, Buckler, 120 Lakemont Park Blvd. Altoona, PA 16602 TELEPHONE: (814) 941-4600 SUPREME COURT ID #(1217 5 ATTORNEYFOR: Defendant Date: s A9 D 'Se of a Court lebenek, & Eck BY THE CO Proth otaM Civil Di Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED File No. 07-1223 Plaintiff , VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3 / 2 9 / 7 6 186-56-0892 TO: Social Security Administration, 50 N Third Street, Chambersburg, PA 17201 (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: An and all medical reports, x-ray/diagnostic reports, applications for benefits, any final determination decisions, any records o paymen s made, any correspondence, any copies of appeals or reconsideration, vocational reports and hearing testimony. Please release all records. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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: Marv Lou Maierhofer ADDRESS: Meyer, Darragh, Buckler, 120 Lakemont Park Blvd Altoona, PA 16602 TELEPHONE: (814) 941-4600 SUPREME COURT ID # 62175 ATTORNEY FOR: Defendant Date: 9 bo -SeEnoftf, a Court Bebenek, & Eck BY THE UR sion P!Fothon Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff File No. 0 7 -1 9 VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3 / 2 9 / 7 6 186-56-0892 TO: Jason K. Bosko, D.C., Chambersburg Chiropractic (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: complete copy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994 through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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: Marv Lou Maierhofer ADDRESS: Meyer, Darragh, Buckler, 170 Lakemont Park Blvd Altoona, PA 16602 TELEPHONE: (814) 941-4600 SUPREME COURT ID #' 6 217 5 ATTORNEYFOR: Defendant Date: 5'6C 'Seal of the Court Bebenek, & Eck BY THE T: P thonotary, Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff File No. C7-1 223 VS. , GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3 / 2 9 / 7 6 186-56-0892 TO:Norland Avenue Pharmacy, 757 Norland Avenue, Chambersburg, PA 17201 (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 bungs: Complete copy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994'through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 malting 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: Marv Lou Maierhofer ADDRESS:Meyer, Darragh, Buckler, 120 Lakemont Park Blvd Altoona, PA 16602 TELEPHONE: (814) 941-4600 SUPREME COURT ID # 62175 ATTORNEY FOR: nefendant Date: CO9 og ' Seat of a Court Bebenek, & Eck BY THE CO T: P onotary , Ci ' sion Deputy . ` " ya IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Gerald L. Heichel, Defendant, certifies that: (1) a notice of intent to serve the subpoenas with a copy of the subpoenas attached thereto was mailed or delivered to each party 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, are attached to this certificate, (3) no objection to the subpoenas has been received, and (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. MEYER, R, BEBENEK & ECK, PLLC BY: MARY ER, ESQUIRE Counse or erald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 (814) 941-4600 I.D. #62175 Date: July 10, 2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, CIVIL DIVISION No. 07-1223 vs. GERALD L. HEICHEL, Defendant. JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant, Gerald L. Heichel, intends to serve subpoenas identical to the ones that are attached to this notice upon Chambersburg Hospital; Cinda A. Liggon, M. D.; Connexus Pharmacy System, Wal-Mart Pharmacy; Cumberland Valley Family Physicians; Eckerd Drugs # 6664; Giant Pharmacy #61; IESI; Larry D. Walker, PhD; Liana I. Laza, M.D.; Margaret Copenhave r, PhD, L.P.C.; Moose Family Fraternity, Chapter2153; Moose Family Fraternity, Lodge 2500; Senior Life; Wellspan Behavioral Health; Social Security Administration; Jason K. Bosko, D.C., Chambersburg Chiropractic; and Norland Avenue Pharmacy. 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 objection is made the subpoenas may be served. MEYEI /P , (f?G / J,UCKLER, BEBENEK & ECK, PLLC BY: M M I OFER, ESQUIRE Counsel for erald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 (814) 941-4600 I.D. #62175 Date: June 19, 2008 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff File No. 07-1223 VS. , GERALD L. HEICHEL , Defendant SUBPOENA. TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 186-56-0892 TO: Cbambersburg Hospital (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: S; = ete copy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994:through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 parry serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOVONG PERSON: NAME: Marv Lou Maierhofer ADDRESS:',Meyer, Darragh, Buckler, 120 Lakeviont Park Blvd Altoona, PA.16602 TELEPHONE: (814) 941-4600 5UPREME COURT ID# 69175 ATTORNEY FOR: D e f en rant Date: 51-19 Los, ' Sea of the Court Bebenek, & Eck BY THE 771 Proth notary, Civil Div' Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff MONO. 07-1223 VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENT'S OR THINGS RE: Sheri Reed 3/29/76 FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/7-0892 TO: -i_nda A. Liggon, M.D., 533 South Main Street, Chambersburg, PA 17201 (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: c'onjete copy of your entire chart for the above-named individual including, but not limited to; any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of .other health care providers, etc., from 1994'through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 coanpehling you to comply with it. THIS SUBPOENA WAS ISSUED AT TDB REQUEST OF TIDE FOLLOWING PERSON: NAME: Marv Lou Maierhofer ADDRESS:'',Meyer, Darragh, Buckler, 120 T akeniont Park Blvd- Altoona.' PA 16602 TELEPHONE: ($14) 941-4600 SUPREME COURT ID # 6 1 7 5 ' ATMRNEYFOR Defendant _ Date: 5 a 0 'Seal o the Court Bebenek, & Eck 13Y THE CO Pronotary, Ci ' -1910 Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff File No._()7-1223 VS. GERALD L. HEICHEL Defendant TO: SUBPOENA TO PRODUCE. DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 RE: Sheri Reed 3/29/76 186-56-0892 (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: ('omple nnv of our entire chart for the above named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care roviders, etc., from 1994 :through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 maldng 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 Ply 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: Mary Lou Maierhofer ADDRESS:,Mever, Darragh, Buckler, 120 Takamont Park Blvd Altoona PA 16602 - TELEPHONE: (814) 941-4600 SUPREME COURT ID #_6 217 5 ATTORNEYFOR: Def ndant _ Date: ? 9109 eal f the Court Bebenek, & Eck BYTHECOUR,ni Proth otary, Civil Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff File No, 07-1223 VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 186-56-0892 TO: C mberland Valley Family Physicians (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: Co=lete copy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994:through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 brings 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: Marv Lou Maierhofer ADDRESS:,Meyer, Darragh, Buckler, 120 Lakemont Park Blvd. Altoona, PA 16602 TELEPHONE: (R14,) 941-4600 SUPREME COURT ID # 62175 ATTORNEY FOR: Defendant _ Date: 51-11107 ' Se of ffie Court Debenek, & Eck BY THE CO Pro notary, Ci Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff VS. GERALD L. HEICHEL Defendant File No. 07_j773 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22' Sheri Reed 3/29/76 TO: Eckerd Dr„¢s I hif6fi64 300 South Fayette St Shinnensburc, PA 182576-0892 (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: ComRlete _0nV of your entire chart for the above named individual including, but not limited to, any and all medical records, reports, _correspondence- diagnostic studies, telephone logs, records of other health care roviders, etc., from 1994:through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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: Mary Lou Maierhofer ADDRESS:Mever, Darragh, Buckler, 17n Takes ont Park Blvd Altoona PA 16602 TELEPHONE: (814)' 941-4600 SUPREME COURT ID # fi'71 7 5 ATTORNEY FOR: _De f endan t Date: QQ D Se of the court Bebenek, & Eck BY THE CO T: Pr onotary, Ci ' szo Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBEp LAND SHERI REED Plaintiff _ VS. File No D7-i22 3 - GERALD GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 RE: Sheri Reed 3/29/76 TO: Giant Pharmacy #61, 186-56-0892 y 397 Baltimore Road, Shipp•ensburg, PA 17257 (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: ComnlPra conv of vour entire chart for the above -named individual including, but not limited to, any and all medical records, reports, _correspondence, diagnostic. studies, telephone logs, records of other health care roviders, etc., from 1994'through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 mating 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 seep a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON. NAME:_Mary Lou Maierhofer ADDRESS:Weyer, Darragh, Buckler, 190 T.akemont Park Blvd _ Altoona PA 16602 TEIEPHONE;1814) 941-4600 SUPREME COURT ID # 1 7 5 ATTORNEY FOR De f_endan t _ Date: 5 d' 9 08 • 'S01 1 o the Court Bebenek, & Eck BY THE T. thono Divi on Deputy COMMONWEALTH OF PENNSYLVANIA. COUNTY OF CUMBERLAND SHERI REED Plaintiff VS. GERALD L. HEICHEL Defendant File No. 07-1223 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 18.6-56-0892 TO: IESI, P.O. Box 399, Scotland, PA 17254 (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: Employment applications work history, including attendance records, - doctor excuses, incident reports, employer physical exams, disability insurance benefits or applications, W2 forms, wage information, any and all documentation relating to x-iorkers compensation, notice o in ury, statement of wages,.benefits, etc. as well as a complete copy of'the personne l e, ig 1994 u . at 120 Lakemont Park Blvd, Altoona, PA 16602 (Address) T 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 alidi eE V-6u have the right m 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: Mary Lou Maierhofer ADDRESS:Meyer. Dai?ragh Buckler, 110Takamont Park Rlyd A l *oaa,r-FA-16642 ;TELEPHONE: SUPREME CO - T 6 217 5 ATTORNEY FOR. Mef endant Date: 5 9 ,A ne 'Se of tfie Court Bebenek, & Eck BY THE CO zzo Pro onotary, Civil Di Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED ' Plaintiff File No. n7-j22 3 - VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3 / 2 9 / 7 6 186-56-0892 TO:Larry D. Walker. PhD 3544 North Progress Ave-, Suite 110, Harrisburg, PA (Name of Person or Entity) 17110 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: __ rcmpJPfie cony of your entire chart for the above named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic, studies, telephone logs, records of other health care providers, .etc., from 1994:through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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. TICS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Mary Lou Maierhofer ADDRESS:,Meyer, Darragh; Buckler, 190 L wont Park Blvd Altoona PA 16602 _ TELEPHONE: _(8 4) 941-4600 SUPREME COURT ID# 2 t 7 5 ATTORNEY FOR: -DP fendan t _ Date: 5- a 9 p 8 S. of ffie Court Debenek, & Eck 7Pr 4ono,*___v Ci ' isio Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff File No. 07-1723 VS. GERALD L. HEICHEL , Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3 / 2 9 / 7 6 186-56-0892 TO: Liana I. Laza, M.D., Pennsylvania Neurological Associates, Ltd _ (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: Complete cony of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994'through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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: Marv Lou Maierhofer ADDRESS:,Meyer, Darragh, Buckler, 190 Lakemont Park Blvd. Altoona, PA 16602 TELEPHONE: (814) 941-4600 SUPREME COURT ID # 6 917 5 ATTORNEY FOR: -De ndant _ Date: 5; a9 0* Seal f th court Bebenek, & Eck BY THE CO T: Pro' 0notary Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMEMLA.ND SHERI REED Plaintif f FiL-No. 07-1 . 3 vs. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE : Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3 / 2 9 / 7 6 186-56-0892 TO:_Margaret Copenhaver, PhD, L.P.C. (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: Complete cove of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994-'through the present. . at 120 Lakemont Park Blvd, Altoona, PA 16602 (Address) You may deliver or mail legiNe 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 parry serving this subpoena may seek a court order compelling you to comply with it. TMS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Marv Lou Maierhofer ADDRESS:,Meyer, Darragh, Buckler, 120 Takemont Park Blvd Altoona, PA 16602 TELEPHONE: (814) 941-4600 SUPREME COURT 1D # 6 17 5 ATTORNEYFOP Defendant _ Date: 5/.2 9 08 'Seal of tlie Court Bebenek, & Eck BY THE C T: thonotary, Ci vis on Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED FilaNo. 07-1223 Plaintiff VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 186-56-0892 TO: Moose Family Fraternity, Chapter 2153, P 0 Box 597, Shippensburg, PA 17257 (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: Emplo.vment applications work history, including attendance records, -doct=ar excuses, incident reports, employer physical exams, disability insurance benefits or applications, W2 forms, wage information, any and all documentation relating to workers compensation, notice o injury, statement of wages,-benefits, etc. as well as a complete copy of"the personne i e, m 1994 u . at 120 Lakemont Park Blvd, Altoona, PA 16602 (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: Marv Lou Maierhofer ADDRESS-Meyer Darragh Buckler IM Lakem(ant Park Blvd Al ta R A__165609 ;TELEPHONE: 4 600- SUPREME CO? 217 5 - ATTORNEY FOR Def ei dant _ Date: o? -Se of the Court Bebenek, & Eck BY THE URT P othonotary, Ci si Deputy COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLAND SHERI REED File No. 07-1223 Plaintiff VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3 / 2 9 / 7 6 186-56-0892 TO: Moose Family Fraternity, Lodge 2500, 32 Walnut Bottom Road, Shippensburg, PA (Naas; of Person or Entity) 17257 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Employment applications, work history, including attendance records, -doctor excuses, incident reports, employer physical exams, disability insurance benefits or applications, W2 forms, wage information, any and all documentation relating to workers compensation, notice of injury, statement-of wages,.benefits, etc. as well as a complete copy of'the personne Title, r through 1994 at 120 Lakemont Park Blvd, Altoona, PA 16602 (Address) You may deliver or mail legrHe copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party malting this request at the address listed above, Y-ou 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 TEM SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Marv Lou Maierhofer ADDRESS;Meyer. Darragh Buckler, 19(1 T.akemnnt park Blvd _ -°1 t-a ,--PA--16602 TELEPHONE: ?g 09- SUPREME COURT 62175 ATTORNEY FOR Me f endant Date: o7g Seal fthe Court Bebenek, & Eck BY THE T: othonotary, visi Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff VS. GERALD L. HEICHEL Defendant File No. 07-1223 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 186-56-0892 TO: Senior Life, 300 Red Brook Blvd, Owings Mills, MD 21117 (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: Employment applications, work history, including attendance records, --duct.-or-excuses, incident reports, employer physical exams, disability insurance benefits or applications, W2 forms, wage information, any and all documentation relating to workers compensation, notice o injury, statement of wages, benefits, etc. as well as a complete copy of"the personnel i e, from t994 through present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 malting 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: Marv Lou Maierhofer ADDRESS;Meyer. Darragh, Buckler 120 Lnkamont Park Blvd A_jteena,--PA 1b6OZ TELEPHONE: SUPREME COURT lb ff 62175 ATTORNEY FOR: Defendant Date: 5 02 p 'Seal of e Court Bebenek, & Eck BY OURT; 4250- -AdLdn o/oVfothc?no pal Di ion Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff File No. 07-1221 VS. GERALD L. HEICHEL , Defendant SUBPOENA TO PRODUCE DOCUMEN'T'S OR TffiNGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009,22 186-566 186-56-0892 TO: WellGnan Behavioral Health (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: Complete cony of your entire chart for the above-named individual including, but not limited to; any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994'through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (Address) You may deliver or mail legele copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party malting 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 conWIling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Marv Lou Maierhofer ADDRESS:',Meyer, Darragh, Buckler, 120 Lakemont Park Blvd Altoona,-PA 16602 TELEPHONE: 814) 941-4600 SUPREME COURT ID # h 217 5 ATTORNEY FOR Defendant Date: -5 029 D "Seal of he Court Bebenek, & Eck BY THE CO Protho otary, Civil Div- Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff File No. 07-122 VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3/29/76 18.6-56-0892 TO: Social Security Administration, 50 N Third Street, Chambersburg, PA 17201 (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: Any and all medical repot benefits, any final deter made, any correspondence, ts, x-ray/diagnostic reports, applications for mination decisions, any records o paymen s any copies of appeals or reconsideration, vocational reports and hearing testimony-.- Please release all records. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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:' Marv Lou Maierhofer ADDRESS:Meyer, Darragh, Buckler, 120 Lakemont Park Blvd Altoona, PA 16602 TELEPHONE:-(814) 941-4600 SUPREME COURT ID # 6 217 5 ATTORNEY FOR: Defendant Date: 6 Zq p Se of tfie Court Bebenek, & Eck BY THE UR : rothonota ision Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED ' Plaintiff File No. 07-1 23 VS. - GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT' TO RULE 4009.22 RE: Sheri Reed 3/29/76 TO: Jason K. Bosko D.C. Chambersbur Chiropractic 186-56-0892 (Nance 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: ('omplete couv of vour entire chart for the above named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care roviders, etc., from 1994 through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (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 courtorder compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME:-Mary Lou Maierhofer ADDRESS: Meyer, Darragh, Buckler, 120 L•akemont Park Blvd Altoona, PA 16602 _ TELEPHONE: (g14), 941-4600 SUPREME COURT ID #' F 91 7 5 ATTORNEY FOR: Defendant Date: 502 'Seal of a Court Bebenek, & Eck BY THE T: P thonotary, Ci isi Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED Plaintiff File No. 07-1 223 VS. GERALD L. HEICHEL Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS RE: Sheri Reed FOR DISCOVERY PURSUANT TO RULE 4009.22 3 / 2 9 / 7 6 186-56-0892 TO:Norland Avenue Pharmacy, 757 Norland Avenue,'Chambersburg, PA 17201 (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: complete copy of your entire chart for the above-named individual including, but not limited to, any and all medical records, reports, correspondence, diagnostic studies, telephone logs, records of other health care providers, etc., from 1994:through the present. at 120 Lakemont Park Blvd, Altoona, PA 16602 (Address) You inay 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 fait 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: Marv Lou Maierhofer ADDRESS:-,Meyer, Darrakh, Buckler, 120 Lakemont Park Blvd Altoona, PA 16602 TELEPHONE: (814) 941-4600 SUPREME COURT ID # ATTORNEY FOR: T), f Date- 019 S 'S of e Court Bebenek, & Eck BY THE CO T: Pr onotary, Ci ion Deputy F' ,f=t f ? y ?. T-n .? '< of .. MLM/msp/US-111296 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. PRAECIPE FOR WITHDRAW/ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Meyer, Darragh, Buckler, Bebenek & Eck, PLLC, as counsel for Defendant, Gerlad L. Heichel, in the above-captioned matter. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED MEYER, DARRAG ER BEBENE LC Y: WSON, ESQ 4850 US Steel Tower 600 Grant Street Pittsburgh, PA 15219 Phone No.: (412) 261-6600 I D # 38562 --------------------------------------------------------------------- TO THE PROTHONOTARY: Please enter my appearance as counsel for Defendant, Gerald L. Heichel, in the above- captioned matter. MARGOLIS E611USTEIN / s BY: Couibbel f r Def ndant/G`erald L -Heichel P.O. Box 28 Hollidaysburg, PA 16648 Phone No.: (814) 695-5064 Fax No.: (814) 695-5066 ID # 62175 ,, '` CERTIFICATE OF SERVICE I, Norman D. Callan, Esquire, of the law firm of Meyer, Darragh, Buckler, Bebenek & Eck, PLLC, hereby certify that on this 13th day of August, 2008,1 have served a true and correct copy of the Praecipe for Withdrawal/Entry of Appearance upon all counsel/parties of record, by mailing same by United States first class mail, postage prepaid and addressed as follows: Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC BY: NORMAN D. CAL-LAN, ESQUIRE 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No. (814) 941-4600 PA I. D. #23518 rv r r i-c I G M Mme, GJ ?? v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, CIVIL DIVISION Plaintiff, No. 2007-01223 vs. GERALD L. HEICHEL, NOTICE OF DEPOSITION Filed on Behalf of Defendant, Gerald L. Defendant. Heichel Counsel of Record for this Party: MARY LOU MAIERHOFER, ESQUIRE PA. I.D. #62175 MARGOLIS EDELSTEIN P.O. Box 628 Hollidaysburg, PA 16648 (814) 695-5064 (814) 695-5066 (FAX) I.D. #62175 JURY TRIAL DEMANDED v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. To: Wendy Oster 243 West North Street Carlisle, PA CIVIL DIVISION No.2007-01223 JURY TRIAL DEMANDED NOTICE OF DEPOSITION PLEASE TAKE NOTICE that the deposition of Wendy Oster, will be taken for the purpose of discovery and for use at trial, pursuant to Rule 4007.1 et seq, of the PA Rules of Civil Procedure, as amended, before an Official Court Reporter on Tuesday. November 18, 2008, at 5:00 p.m. at The Blaine Room, Comfort Inn, 10 South Hanover Street, Carlisle, PA 17013, at which time and place you are invited to appear and take such part as shall be fitting and proper. MARGOLIS BY: Coun*1 for INefeni P.O. Box 628 Hollidaysburg, PA (814) 695-5064 I.D. #62175 DFER, ESQUIRE Gerald L. Heichel 16648 cc: Stephen G. Held, Esquire Sargent's Court Reporting COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERI REED, Plaintiff vs. 07-1223 GERALD L. HEICHEL, Defendant File No. SUBPOENA TO ATTEND AND TESTIFY TO: 43 West Nnrth Street, l 1-A PA- 17013 1. You are ordered by the court to come to Blaine Room, Comfort Inn, 10 South Hanover Street, Carlisle, PA 17013 (Specify Courtroom or other place) at 5: 00 Ply County, Pennsylvania, on November 1 4, 2008 at o'clock, M,. to testify on behalf of Pa r t i e G involved in this casell in the above case, and to remain until excused. 2. And bring with you the following: NIA If you fail to attend or to produce the documents or things required by this subpoena, you may be subject to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Civil Procedure, including but not limited to costs, attorney fees and imprisonment. REQUESTED BY A PARTY/ATTORNEY IN COMPLIANCE WITH Pa.R.C.P.No.234.2(a): Name: Marv Trni Malerhofer_ Frznujre Address: 170 T a1cPmnnt Park Rigri _ Altoona, PA 16602 Telephone: 814-941-4600 Supreme Court ID # 62175 BY THE CO T: thono Division Date: S al f the Court Deputy Official Note: This form of subpoena shall be used whenever a subpoena is issuable, including hearings in connection with depositions and before arbitrators, masters, commissioners, etc. in compliance with Pa. R.C.P.No.234.1. If a subpoena for a production of documents, records or things is desired; complete paragraph 2. (Eff. 7/97) V, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, VS. GERALD L. HEICHEL, Defendant. TO THE PROTHONOTARY: CIVIL DIVISION No.2007-01223 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Mary Lou Maierhofer, Esquire, of the law firm of MARGOLIS EDEDLSTEIN hereby certify that on this 20 th day of October, 2008, I have served the foregoing Notice of Deposition on behalf of Defendant, Gerald L. Heichel, upon all counsel/parties of record, by mailing a true and correct copy of same by United States first class mail, postage prepaid as follows: Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 MARGOLI EDEDLSTEIN a BY: Uy ' ' I ROFER, ESQUIRE sei for fendant, Gerald L. Heichel P.O. Box 62 Hollidaysburg, PA 16648 (814) 695-5064 I.D. #62175 4J"# ': R ? # ' f y n --C C:? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 2007-01223 CERTIFICATE OF SERVICE FOR DEFENDANT'S ANSWERS TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND ANSWERS TO PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS Filed on Behalf of Defendant, Gerald L. Heichel Counsel of Record for this Party: MARY LOU MAIERHOFER, ESQUIRE PA. I.D. 462175 MARGOLIS EDELSTEIN P.O. Box 628 Hollidaysburg, PA 16648 (814) 695-5064 (814) 695-5066 (FAX) I.D. #62175 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. TO THE PROTHONOTARY: CIVIL DIVISION No.2007-01223 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Mary Lou Maierhofer, Esquire, of the law firm of MARGOLIS EDEDLSTEIN hereby certify that on this 4TH day of November, 2008, I have served the foregoing Defendant's Answers to Plaintiff s First Set fo Interrogatories and Defendant's Answers to Plaintiff's Request for Production of Documents on behalf of Defendant, Gerald L. Heichel, upon all counsel/parties of record, by mailing a true and correct copy of same by United States first class mail, postage prepaid as follows: Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 MARGOLIS EDEDLS BY: Counsel for Defendant, Gerald L. Heichel P.O. Box 628 Hollidaysburg, PA 16648 (814) 695-5064 T.D. 462175 - ,.?_? <_ ±`° c y? i ,?;,-?. ..-q " „? t? `- ? ? , -t- -;t .j :}`?,? Cam.,: .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, VS. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 2007-01223 PETITION FOR A STATUS CONFERENCE Filed on Behalf of Defendant, Gerald L. Heichel Counsel of Record for this Party: MARY LOU MAIERHOFER, ESQUIRE PA. I.D. #62175 MARGOLIS EDELSTEIN P.O. Box 628 Hollidaysburg, PA 16648 (814) 695-5064 (814) 695-5066 (FAX) I.D. #62175 JURY TRIAL DEMANDED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, VS. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED PETITION FOR A STATUS CONFERENCE NOW COMES the Defendant, Gerald L. Heichel, by and through his counsel, MARGOLIS EDELSTEIN and files this Petition for a Status Conference of which the following is a statement: Plaintiff commenced this personal injury action by filing for a Writ of Summons on or about February 11, 2005 in Franklin County and subsequently transferred this litigation to Cumberland County. 2. This litigation arises out of an incident that occurred on or about June 5, 2004 at Defendant's wife's home during their wedding reception. 3. Plaintiff alleges that the Defendant physically picked her up and flipped her over, then dropped her on her head. 4. Defendant alleges that he went to hug the Plaintiff, lost his balance and they both fell with the Defendant hitting the ground and Plaintiff falling on top of Defendant. 5. The parties have been actively exchanging discovery. 6. The parties' depositions have been completed. 7. The last deposition in this matter was taken in February of 2009 by the Defendant. 8. The only discovery outstanding is the documentation and lien information from Plaintiff regarding her receipt of Medicare benefits through her Social Security disability and her expert reports. 9. Due to the somewhat complex medical conditions of the Plaintiff, due to her pre- existing medical conditions and subsequent incidents that are unrelated to the claims set forth by Plaintiff in her Complaint, Defendant cannot determine what or how many experts may be needed in this case. 10. It is in the interest of both parties that deadlines be established. 11. It is requested that this Honorable Court schedule a status conference to set deadlines in this matter. 12. A telephone message was left with Plaintiffs counsel regarding his position on the filing of this Petition on May 13, 2009. As of the date of the filing of this Petition, Counsel for the Plaintiff has not returned the phone call. WHEREFORE, Defendant, Gerald L. Heichel, respectfully requests that this Court enter an Order scheduling a Status Conference in this matter. MARGOLIS BY: Y IOU MAIERHOFER, ESQUIRE Counsel r Defendant, Gerald L. Heichel P.O. Box 628 Hollidaysburg, PA 16648 (814) 695-5064 I.D. #62175 Date: May 19, 2009 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Mary Lou Maierhofer, Esquire, of the law firm of MARGOLIS EDELSTEIN, hereby certify that on this 19th day of May, 2009, I have served the foregoing Petition for a Status Conference on behalf of Defendant, Gerald L. Heichel, upon all counsel of record, by mailing a true and correct copy of same by United States first class mail, postage prepaid as follows: Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 MARGOLIS EDEDLSTEIN BY: MWV%q, U NLVERHOFER, ESQUIRE Counsel r Defendant, Gerald L. Heichel P.O. Box 28 Hollidaysburg, PA 16648 (814) 695-5064 I.D. #62175 'OT OT -ARY 2999 rr Y 21 Fi-i 1 ?, T fs _ _ A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, CIVIL DIVISION Plaintiff, No. 2007-01223 vs. AMENDMENT TO THE PETITION FOR GERALD L. HEICHEL, A STATUS CONFERENCE Defendant. Filed on Behalf of Defendant, Gerald L. Heichel Counsel of Record for this Party: MARY LOU MAIERHOFER, ESQUIRE PA. I.D. #62175 MARGOLIS EDELSTEIN P.O. Box 628 Hollidaysburg, PA 16648 (814) 695-5064 (814) 695-5066 (FAX) I.D. #62175 JURY TRIAL DEMANDED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, VS. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED AMENDMENT TO THE PETITION FOR A STATUS CONFERENCE NOW COMES the Defendant, Gerald L. Heichel, by and through his counsel, MARGOLIS EDELSTEIN and files this Amendment to the Petition for a Status Conference of which the following is a statement: 1. No Judge has ruled upon any issue the same or similar as to the Petition and relief requested by the Defendant. 2. A telephone message was left with Plaintiff's counsel regarding his position on the filing of this Petition on May 13, 2009. As of the date of the filing of this Amendment, Counsel for the Plaintiff has not returned the phone call. It is assumed that Plaintiff concurs with the filing of this Petition since no objection has been received. WHEREFORE, Defendant, Gerald L. Heichel, respectfully requests that this Court enter an Order scheduling a Status Conference in this matter. MARGOL,IS EDED BY: Mk'?' I V1AI 0'>?1 ', ESQUIRE Counsel f rl/?Defend t, Gerald L. Heichel P.O. Box 628 Hollidaysburg, PA 16648 (814) 695-5064 I.D. #62175 Date: June 4, 2009 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, VS. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Mary Lou Maierhofer, Esquire, of the law firm of MARGOLIS EDELSTEIN, hereby certify that on this 4t" day of June, 2009, I have served the foregoing Amendment to the Petition for a Status Conference on behalf of Defendant, Gerald L. Heichel, upon all counsel of record, by mailing a true and correct copy of same by United States first class mail, postage prepaid as follows: Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 EDED BY: Counsel fdr Defeh4 P.O. Box 628 Hollidaysburg, PA (814) 695-5064 I.D. 462175 WMASQUIRE Gerald L. Heichel 16648 ALED--?::? R,E OF TNc PROTHIC,NOTARY 2609 JUN -8 Ph 4: i '7 PEN NS'tlVA-,'N' JUN 0 2 2009: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, VS. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. 07-1223 JURY TRIAL DEMANDED ORDER NOW THIS _#?day of 2009, upon Petition by the Defendant Gerald L. Heichel for the scheduling of a Status Conference in the above referenced matter, it' is hereby ordered, directed and decreed, a status conference will be held on the day of ? rS a* 9.'00 A ? 2009, in Courtroom No. m front of the Honorable BY THE COURT: J. FILCG?-??;= '?JE OF THE F',;? .,???AAY 2009 JUN I I AID 10' 0 4 P0": f, ?}`yy`•? ? ?? ?iV I 1J ?Y? ti ? e4 k s. SHERI REED, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. GERALD L. HEICHEL, DEFENDANT NO. 07-1223 CIVIL IN RE: CASE MANAGEMENT ORDER OF COURT AND NOW, this 21St day of August, 2009, upon consideration of the case management conference held with counsel, IT IS HEREBY ORDERED AND DIRECTED that: 1. All remaining depositions required for this case shall be completed on or before September 30, 2009. 2. Plaintiff shall identify and submit curriculum vitae and expert reports of all expert witnesses intended to testify at trial no later than October 16, 2009. 3. If it is necessary to schedule an independent medical examination of the Plaintiff, the examination shall be scheduled on or before November 19, 2009. 4. Defendant shall identify and submit curriculum vitae and expert reports of all expert witnesses intended to testify at trial no later than December 18, 2009. 5. All Pre-Trial motions shall be filed by January 28, 2010, and scheduled for Argument Court on February 17, 2010. 6. A Pre-Trial Conference shall be held on June 9, 2010. 7. The case shall be listed for Trial to begin Monday, June 21, 2010. Counsel shall consider themselves attached. By the Court, ?Stephen G. Held Esquire Attorney for Plaintiff Mary Lou Maierhofer, Esquire Attorney for Defendant Court Administrator - &'S g1>>V? bas Co?c mss' ma<<? M. L. Ebert, Jr., J. Wit- T4 P 141 'NOTARY 2009 AU0 21 PM 12: 00 Stephen G. Held Attorney ID# 72663 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiff(s) Fax : (717) 233-3029 E-mail: Held@hhriaw.com Sheri Reed : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE COUNTY, PENNSYLVANIA V. Plaintiff(s) : NO. 07-1223 : CIVIL ACTION - LAW Gerald L. Heichel Defendant(s) : JURY TRIAL DEMANDED PRAECIPE FOR DISCONTINUANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Please mark the above-captioned matter settled and discontinued with prejudice. Respectfully Submitted, HANDLER, HENNING& ROSENBERG, LLP Dated: 1112/09 41a Step a Id Attorney for Plaintiff(s) FILED ,R r?r THi : 2009 V 10 all`t ron: 10 IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No. -2996 00380 01-/2A3 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE TO THE PROTHONOTARY: I, Mary Lou.Maierhofer, Esquire, of the law firm of MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, Pt,LC, hereby certify that on this 12' day of February, 2008, 1 have served the foregoing First Supplemental Request for Production of Documents Directed to Plaintiff on behalf of Defendant, Gerald L. Heichel, upon all counsel/parties of record, by mailing a true and'norrect copy of same by United States first class mail, postage prepaid as follows: Stephen G. Held, Esquire Handier, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 MEYER, DARRAf',,BUCKLERIAEBENEK & ECK, PLLC BY: MAR1f6100y MAIERReFER, ESQUIRE Counsel fdr Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No. (814) 941-4600 PA I. D. #62175 az? 0 F IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, No. *005-005 o7- «z.3 vs. CIVIL DIVISION NOTICE OF DEPOSITION GERALD L. HEICHEL, Filed on Behalf of Defendant, Gerald L. Defendant. Heichel Counsel of Record for this Party: MARY LOU MAIERHOFER, ESQUIRE PA. I.D. #62175 MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, P.L.L.C. 120 Lakemont Park Boulevard Altoona, PA 16602 Telephone No.: (814) 941-4600 Fax No.: (814) 941-4605 JURY TRIAL DEMANDED MLM/c1c/US-111296 IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, CIVIL DIVISION No. 2005-00380 vs. GERALD L. HEICHEL, Defendant. JURY TRIAL DEMANDED NOTICE OF DEPOSITION To: Sheri Reed c/o Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 PLEASE TAKE NOTICE that the deposition of Sheri Reed, will be taken for the purpose of discovery and for use at trial, pursuant to Rule 4007.1 et seq, of the PA Rules of Civil Procedure, as amended, before an Official Court Reporter on Friday, April 25. 2008, at 11:00 a.m. at Franklin County Courthouse, Conference Room A, 3`d Floor located at 157 Lincoln Way East, Chambersburg, PA 17201, at which time and place you are invited to appear and take such part as shall be fitting and proper. MEYER, DARRAGH, BUCKLER, BEBENEK & ECK BY: I/MAKY LO MAIERHOFER, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 (814) 941-4600 I.D. #62175 cc: Heather G. Boring, Boring Court Reporting IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, CIVIL DIVISION No. 2005-00380 vs. GERALD L. HEICHEL, Defendant. JURY TRIAL DEMANDED CERTIFICATE OF SERVICE TO THE PROTHONOTARY: I, Mary Lou Maierhofer, Esquire, of the law firm of MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, hereby certify that on this 51' day of March, 2008, 1 have served the foregoing Notice of Deposition on behalf of Defendant, Gerald L. Heichel, upon all counsel/parties of record, by mailing a true and correct copy of same by United States first class mail, postage prepaid as follows: Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 MEYER, DARRA , B KLER, BEBENEK & ECK, PLLC BY: 144F -' #RYFLQUMAIERHOFER, ESQUIRE C un el for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No. (814) 941-4600 PA I. D. #62175 Q C f cn -?? r IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. CIVIL DIVISION No.299 00'3W . e NOTICE OF DEPOSITIO i Filed on Behalf of Defendant, ldrj? Heichel ca Counsel of Record for this Party: MARY LOU MAIERHOFER, ESQU IRE PA. I . D. #62175 MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, P.L.L.C. 120 Lakemont Park Boulevard Altoona, PA 16602 Telephone No.: (814) 941-4600 Fax No.: (814) 941-4605 JURY TRIAL DEMANDED MLM/dc1US-111296 IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, CIVIL DIVISION No. 2005-00380 vs. GERALD L. HEICHEL, Defendant. JURY TRIAL DEMANDED NOTICE OF DEPOSITION To: Brian Ray Reed c/o Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 PLEASE TAKE NOTICE that the deposition of Sheri Reed, will be taken for the purpose of discovery and for use at trial, pursuant to Rule 4007.1 et seq, of the PA Rules of Civil Procedure, as amended, before an Official Court Reporter on Friday, ARril 25, 2008, at 1:30 R.M. at Franklin County Courthouse, Conference Room A, 31 Floor located at 157 Lincoln Way East, Chambersburg, PA 17201, at which time and place you are invited to appear and take such part as shall be fitting and proper. MEYER, DARRAGH, BUCKLER, BFBENEK & ECK BY: MA`RYYOU MAIER`FIOFER, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 (814) 941-4600 I.D. #62175 cc: Heather G. Boring, Boring Court Reporting IN THE COURT OF COMMON PLEAS OF FRANKLIN COUNTY, PENNSYLVANIA SHERI REED, Plaintiff, vs. GERALD L. HEICHEL, Defendant. TO THE PROTHONOTARY: CIVIL DIVISION No. 2005-00380 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Mary Lou Maierhofer, Esquire, of the law firm of MEYER, DARRAGH, BUCKLER, BEBENEK & ECK, PLLC, hereby certify that on this Wh day of March, 2008, 1 have served the foregoing Notice of Deposition on behalf of Defendant, Gerald L. Heichel, upon all counsel/parties of record, by mailing a true and correct copy of same by United States first class mail, postage prepaid as follows: Stephen G. Held, Esquire Handler, Henning and Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 MEYER, DAR)RAOH, BY: & ECK, PLLC f Ajt)VLQU`MAIERHOFER, ESQUIRE Counsel for Defendant, Gerald L. Heichel 120 Lakemont Park Boulevard Altoona, PA 16602 Phone No. (814) 941-4600 PA 1. D. #62175 f ? `? ? r '? : r ;? ?.'. ? ;???-t-: ? 'Za ??i' :? N ? m