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Home My WebLink About07-1124SCHMIDT KRAMER PC BY: Gerard C. Kramer, Esquire Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Fax No. (717) 232-6467 Attorney for Plaintiff gkramerO-schmidtkramer.com IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. -- Civil Action (X) Law () Equity LORNE K. JUMPER 342 S. Washington Street Mechanicsburg, PA 17055 Plaintiff(s) & Address(es) KENNETH L. FRY, JR. 12 Adams Road Carlisle, PA 17013 : Defendant(s) 8s Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Writ of Summons in the above-captioned action. X A Writ of Summons shall be issued and forwarded to ( ) Attorney (X) Sheriff. Gerard C. Kramer, Esquire Schmidt Kramer PC 209 State Street Harrisburg, PA 17101 (717) 232-6300 Date. lJ6 /0'1 .Signature of Attorney 'r Supreme Court I.D. No. 44715 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Date: Pro hono By: Deputy ) Check here if reverse is issued for additional information lJ a SHERIFF'S RETURN - REGULAR CASE NO: 2007-01124 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JUMPER LORNE K VS FRY KENNETH L JR MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon FRY KENNETH L JR the DEFENDANT at 0721:00 HOURS, on the 9th day of March , 2007 at 12 ADAMS ROAD CARLISLE, PA 17013 KENNETH FRY JR by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 4.80 Postage .63 Surcharge 10.00 R. Thomas Kline 00 3?d?la? 9, 33.43 03/12/2007 SCHMIDT KRAMER 17v//?-Iz?? V Sworn and Subscibed to By: before me this day of A.D. SCHMIDT KRAMER PC BY: Gerard C. Kramer Attorney at Law Attorney ID No.: 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Fax (717) 232-6467 gkrame cgschmidtkramer.com Attorney for Plaintiff LORNE K. JUMPER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : No. 0 7 411 t Y C t u, l le-111") KENNETH L. FRY, JR., : CIVIL ACTION -LAW Defendant : JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE 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 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 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes pdginas, 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 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA 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 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 SCHMIDT KRAMER PC BY: Gerard C. Kramer Attorney at Law Attorney ID No.: 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Fax (717) 232-6467 gkramer@schmidtkrwner.com Attorney for Plaintiff LORNE K. JUMPER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. '7 KENNETH L. FRY, JR., CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED COMPLAINT COUNT I NEGLIGENCE AND NOW, comes the Plaintiff, Lorne K. Jumper, by and through his attorneys, Schmidt Kramer PC, and respectfully sets forth as follows: 1. Plaintiff Lorne K. Jumper is an adult individual currently residing at 342 S. Washington Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant Kenneth L. Fry, Jr. is an adult individual currently residing at 12 Adams Road, Carlisle, Cumberland County, Pennsylvania, 17013. 1 3. On April 14, 2005, at approximately 1:10 p.m., Plaintiff Lorne K. Jumper was operating a 2003 Ford Mustang traveling west on East Trindle Road near Manor Drive in Hampden Township, Cumberland County, Pennsylvania. 4. Plaintiff Lorne K. Jumper had brought the 2003 Ford Mustang to a complete stop because the traffic in front of him had stopped. 5. Plaintiff's vehicle was struck from behind by a 1999 Ford Expedition SUV, Pennsylvania Registration No. EWA2761, owned by Pamela L. Dixon and operated by Defendant Kenneth L. Fry, Jr.. 6. Defendant Kenneth L. Fry, Jr. was following Plaintiff's vehicle too closely, in violation of the Pennsylvania Motor Vehicle Code, which resulted in Defendant being unable to stop and striking Plaintiffs vehicle. 7. The accident was caused solely by the negligence of the Defendant and was in no way the responsibility of the Plaintiff. 8. The negligence and carelessness of Defendant Kenneth L. Fry, Jr. consisted of: a. following another vehicle more closely than was reasonable and prudent under the conditions, in violation of the Pennsylvania Motor Vehicle Code, 75 Pa. C.S. § 3310. b. inattentiveness; C. distraction; d. failing to have his vehicle under proper and adequate control; 2 e. negligently applying the brakes; f. failing to apply the brakes in time to avoid the collision; g. failing to observe the vehicle driven by Plaintiff Lorne K. Jumper; h. failing to operate the vehicle in accordance with existing traffic conditions and traffic controls; i. failing to keep a reasonable lookout for other vehicles lawfully on the roadway; and j. operating his vehicle in a manner that created a dangerous situation for other vehicles on the roadway. 9. As a, factual result of the accident, Plaintiff Lorne K. Jumper suffered injuries which are severe and believed to be permanent. These injuries include the following: a. neck muscle inflammation and spasms b. cervical strain and radiculitis c. posterior occipital headaches d. bilateral shoulder strain e. costochondritis f. hand numbness g. compression of his cubital tunnel 10. As a factual result of the accident, Plaintiff Lorne K. Jumper has incurred medical expenses to date and will continue to incur medical expenses into the future, and thus, a claim for these expenses is made. 3 11. As a factual result of the accident, Plaintiff Lorne K. Jumper has been advised and therefore avers that the aforementioned injuries may be permanent in nature and effect, and thus, a claim for these injuries is made. 12. As a factual result of the accident, Plaintiff Lorne K. Jumper has undergone in the past, and will continue to undergo in the future, great pain and suffering, and thus, a claim for these injuries is made. 13. As a factual result of the accident, Plaintiff Lorne K. Jumper has been obliged to spend various sums of money and to incur various expenses for the injuries that he has suffered and may continue to incur the same in the future, and thus, a claim for these losses is made. 14. As a factual result of the accident, Plaintiff Lorne K. Jumper suffered a loss of earnings and an impairment of his earning power and capacity in the future, and thus, a claim for these losses is made. 15. As a factual result of the accident, Plaintiff Lorne K. Jumper suffered a permanent diminution of his ability to enjoy life and life's pleasures, and thus, a claim for these losses is made. 4 WHEREFORE, Plaintiff Lorne K. Jumper demands judgment against Defendant Kenneth L. Fry, Jr. in an amount in excess of the compulsory arbitration limits for Cumberland County. Respectfully submitted, SCHMIDT KRAMER PC Dated: "/ Y-OO By Gerard C. Kramer Attorney at Law Attorney ID No.: 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff 5 VERIFICATION BASED UPON PERSONAL KNOWLEDGE AND INFORMATION SUPPLIED BY COUNSEL I, Lorne K. Jumper, verify that I am the Plaintiff in this action and that the foregoing Complaint is based upon the information which has been gathered by my counsel in preparation of this lawsuit. The language of the Complaint is that of counsel and is not mine. I have read the Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the contents of the Complaint are that of counsel, I have relied upon counsel in making this Verification. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications made to authorities. LORNE K. JUM R CERTIFICATE OF SERVICE AND NOW, this day of _7?MaA- ,L , 2008, I, Gerard C. Kramer, Esquire, hereby certify that I have this day served a true and correct copy of the COMPLAINT by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Kenneth L. Fry, Jr. 12 Adams Road Carlisle, PA 17013 Respectfully submitted, SCHMIDT KRAMER PC DATED: ` h 7lob By: erard C. Kramer Attorney at Law Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff c`` r-,)' -,-] co Johnson, Duffle, Stewart & Weidner Attorney for Defendant . By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com (717) 761-4540 LORNE K. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO: 07-1124 CIVIL TERM CIVIL ACTION - LAW KENNETH L. FRY, JR., Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: PLEASE enter the appearance of the undersigned on behalf of the Qpfendant,in the above-captioned matter. t JOHNSON, DUFFIE, STEWART & WEIDNER DATE:,V/ or Jk4Z,6.4 A, 1,41 . '? P06r'son J. Shipman, squire 1. D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109. Attorneys for Defendant IL CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on April 3, 2008: Gerard C. Kramer, Esquire Schmidt Kramer, P.C. 209 State Street Harrisburg, PA 17101 Attorneys for Plaintiff 328737 JOHNSON, DUFFIE, STEWART & WEIDNER 4 efferson J. Shipman, Esquire . D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Defendant -R f't ETI " t7 RIM -.J t y r MS O -,- C Ln C7 Johnson, Duffle, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Phone: (717) 761-4540 E-mail: jjs@jdsw.com Attorney for Defendant LORNE K. JUMPER, Plaintiff V. KENNETH L. FRY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-1124 CIVIL TERM JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Gerard C. Kramer, Esquire Schmidt Kramer 209 State Street Harrisburg, PA 17101 YOU ARE REQUIRED to plead to the within Answer and New Matter within 20 days of service hereof or a default judgment may be entered against you. , DUFFIE, STEWART & WEIDNER Date: June 13, 2008 effer oon J. Shipman, Esquire D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Defendant Johnson, Duffie, Stewart & Weidner Attorney for Defendant By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Phone: (717) 761-4540 E-mail: jjs@jdsw.com LORNE K. JUMPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-1124 CIVIL TERM KENNETH L. FRY, JR., Defendant JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT AND NOW, comes the Defendant, Kenneth L. Fry, Jr., by and through his counsel, Johnson, Duffle, Stewart & Weidner, and Jefferson J. Shipman, Esquire, and files the following Answer and New Matter to Plaintiffs Complaint: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. after reasonable investigation, Mr. Fry is without sufficient knowledge or information to form a belief as to the truth of the averments in Paragraph 4 and the same are therefore denied. ..n- .. .. ? •r ?r,r.••-. t, 5. Admitted in part, denied in part. It is admitted that there was contact between the Fry and Jumper vehicles. After reasonable investigation, Mr. Fry is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 5 and the same are therefore denied as stated. 6. Denied. The averments contained in Paragraph 6 are°coholusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. 7. Denied. The averments contained in Paragraph 7 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. 8. Denied. The averments contained in Paragraph 8, and subparagraphs a. through j., are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained in Paragraph 8 and each and every subparagraph a. through j. are specifically denied. a. Denied. It is specifically denied that Mr. Fry was following another vehicle more closely than was reasonable and prudent under the conditions, in violation of the Pennsylvania Motor Vehicle Code, 75 Pa. C.S.A. §3310. b. Denied. It is specifically denied that Mr. Fry was inattentive' C. Denied. It is specifically denied that Mr. Fry was distracted; d. Denied. It is specifically denied that Mr. Fry failed to have his vehicle under proper and adequate control; .c, ? - e. Denied. It is specifically denied that Mr. Fry negligently applied. the brakes; f. Denied. It is specifically denied that Mr. Fry was negligent in allegedly failing to apply the brakes in time to avoid the collision; g. Denied. It is specifically denied that Mr. Fry was negligent in-allegedly failing to observe the vehicle driven by Plaintiff; h. Denied. It is specifically denied that Mr. Fry failed to operate the vehicle in accordance with existing traffic conditions and traffic control; i. Denied. It is specifically denied that Mr. Fry failed to keep a reasonable lookout for other vehicles on the roadway; and j. Denied. It is specifically denied that Mr. Fry operated his vehicle in a manner that created a dangerous situation for other vehicles on the roadway. 9. Denied. After reasonable investigation, Mr. Fry is without sufficient knowledge or information to form a belief as to the truth 'of the averments contaifd in Paragraph 9, relating to Plaintiffs alleged injuries, and the same are therefore denied and strict proof demanded at the time of trial. 10. Denied. After reasonable investigation, Mr. Fry is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 10, relating to Plaintiff's alleged medical expenses; and the same are therefore denied and strict proof demanded at the time of trial. .,? I 11. Denied. After reasonable investigation, Mr. Fry is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 11, relating to Plaintiffs alleged injuries, and the same are therefore denied and strict proof demanded at the time of trial. 12. Denied. After reasonable investigation, Mr. Fry is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 12, relating to Plaintiff's alleged injuries, and the same are therefore denied and strict proof is demanded at the time of trial. 13. Denied. After reasonable investigation, Mr. Fry is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 13, relating to Plaintiff's alleged expenses for injuries claimed, and the same are therefore denied and strict proof is demanded at the time of trial. 14. Denied. After reasonable investigation, Mr. Fry is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 14, relating to Plaintiff's alleged loss of earnings and impairment of earning power and capacity, and the same are therefore denied and strict proof is demanded at the time of trial. 15. Denied. After reasonable investigation, Mr. Fry is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 15, relating to Plaintiff's alleged diminution of his ability to enjoy life and ' - f ? .., pleasures, and the same are therefore denied and strict proof is demanded at the time of trial. WHEREFORE, the Defendant, Kenneth L. Fry, Jr., respectfully requests that judgment be entered in his favor and that Plaintiffs Complaint be dismissed with prejudice. NEW MATTER By way of additional answer and reply, the Defendant interposes the following New Matter defenses: 16. That the Plaintiffs alleged cause of action may be barred in whole or in part by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 17. That the Plaintiff's alleged cause of action may be barred in whole or in part by the Limited Tort Option. 18. That if it should be found that there was any negligence on the part of the answering Defendant, which is denied, then in that event any such negligence was not a factual cause, nor substantial factor to Plaintiff's accident and atteged injuries. 19. That the Plaintiffs alleged cause of action may have been caused by third parties or entities not presently involved in this action. 24. That the Plaintiffs alleged cause of action may be barred in whole or in part by the Pennsylvania Comparative Negligence Act and by the Plaintiffs own negligence. WHEREFORE, the Defendant, Kenneth L. Fry, Jr., respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER Jeff rson J. Shipma ,Esquire Attorney I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Date: June 13, 2008 329103 VERIFICATION I, Kenneth L. Fry, Jr., have read the foregoing Answer with New Matter and hereby affirm that it is true and correct to the best of my personal knowledge, or information and belief. This Verification and statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities; I verify that all the statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa. C.S. §4804. /ev M 'k Ken L. Fry, DATE: 329120 i . 46 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Answer and New Matter has been duly served upon the following, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on June 13, 2008: Gerard C. Kramer, Esquire Schmidt & Kramer 209 State Street Harrisburg, PA 17101 Attorneys for Plaintiff JOHNS, DUFFIE, STEWART & WEIDNER Je so7i J. Shipman! Esquire Att rney I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 ? ? ? ?.?r K,y ? ? ? {? w ?a.? „ ^ V _. ?? ` "L7 ? >, c? ?? ? SCHMIDT KRAMER PC BY: GERARD C. KRAMER, ESQUIRE Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Fax No. (717) 232-6467 Attorneys for Plaintiffs gkramer(@schmidtkramer.com LORNE K. JUMPER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. 07-1124 KENNETH L. FRY, JR., CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED PLAINTIFF'S RESPONSE TO DEFENDANT'S NEW MATTER AND NOW, comes the Plaintiff, Lorne K. Jumper, by and through his attorneys, Schmidt Kramer PC, and respectfully responds to the New Matter as follows: 16. Paragraph 16 is a conclusion of law to which no responsive pleading is necessary. 17. Paragraph 17 is a conclusion of law to which no responsive pleading is necessary. 18. Paragraph 18 is a conclusion of law to which no responsive pleading is necessary. 1 19. Paragraph 19 is a conclusion of law to which no responsive pleading is necessary. 20. Paragraph 24 is incorrectly numbered as 24; however, it is a conclusion of law to which no responsive pleading is necessary. WHEREFORE, Plaintiff respectfully requests that the New Matter be dismissed. Dated: 'd By Respectfully submitted, SCHMIDT KRAMER PC 9?6rard C. Kramer Attorney at Law Attorney ID No.: 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff 2 ATTORNEY VERIFICATION I, Gerard C. Kramer, Esquire, verify that I am attorney of record for the Plaintiff. I verify that the facts contained in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsifications to authorities. Date CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Response to New Matter has been duly served upon the following, by depositing the same in the United States Mail, postage pre-paid, in Harrisburg, Pennsylvania, on-70-Ae 26, 2008: Jefferson J. Shipman, Esquire Johnson, Duffie, Stewart & Weidner 301 Market Street PO Box 109 Lemoyne, PA 17043-0109 SCHMIDT KRAMER PC Dated: 6O /-Z6 /08 By Berard C. Kramer Attorney at Law Attorney ID No.: 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff t+..,,7 _,., c-? ?:? l ? . ? iis?_ _?? ? ?-a .. ? _i :? ?:?' Johnson, Duffie, Stewart & Weidner Attorney for Defendant By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com (717) 761-4540 LORNE K. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO: 07-1124 CIVIL TERM CIVIL ACTION -- LAW KENNETH L. FRY, JR., Defendant : JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 TO: Gerard C. Kramer, Esquire Schmidt Kramer, P.C. 209 State Street Harrisburg, PA 17101 Attorneys for Plaintiff As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas attached thereto, was mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoenas were sought to be served; (2) A copy of the Notice of Intent including the proposed subpoenas, is attached to this Certificate; (3) No objection to the subpoenas has been received, the waiting period for objections was waived; and (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. JOHNSON, DUFFIE, STEWART & WEIDNER By J erson J. Shipman, Esquire I.D. #: 51785 P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com Attorneys for Defendant Telephone: 717-761-4540 DATE: /aV 30I0$" CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following counsel of record, by depositing the same in the United States Mail, first class mail, postage prepaid, in Lemoyne, Pennsylvania, on December 30, 2008: Gerard C. Kramer, Esquire Schmidt Kramer, P.C. 209 State Street Harrisburg, PA 17101 Attorneys for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER By Jefferson J. Shipman, Esquire I. D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Defendant Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com (717) 761-4540 IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA LORNE K. JUMPER, V. KENNETH L. FRY, JR., Attorney for Defendant NO: 07-1124 CIVIL TERM CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO Gerard C. Kramer, Esquire Schmidt Kramer, P.C. 209 State Street Harrisburg, PA 17101 Attorneys for Plaintiff PLEASE TAKE NOTICE that Defendants intend to serve ten (10) subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of records and serve upon the undersigned objections to the subpoenas. If no objections are made, the subpoenas may be served. DATE: I D/ fa10$ JOHNSON UFFIE, STEWART & WEIDNER By f Jefferson J. Shipman, Esquire I.D. #: 51785 P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com Attorneys for Defendant Telephone: 717-761-4540 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following counsel of record, by depositing the same in the United States Mail, certified mail, postage prepaid, in Lemoyne, Pennsylvania, on December 12, 2008: Gerard C. Kramer, Esquire Schmidt Kramer, P.C. 209 State Street Harrisburg, PA 17101 Attorneys for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER By Jeffe son J. Shipman, Esquire I . D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Defendant COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lorne K. Jumper Plaintiff vs. Kenneth L. Fry, Jr., Defendant File No. 07-1124 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Bowmansdale Family Practice (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 records, reports, correspondence, diagnostic test results pertaining to Lorne K Jumper DOB: 8/29/64 SSN: 192-60-8653 at Johnson Duffle Stewart & Weidner, 301 Market Street, P.O. Box 109, Lemoyne, PA 17043. 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: Jefferson J. Shipman, Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: P thonotary/Cle , Civil ' on Deputy DATE: /o2?/D?Og Seal of the Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lorne K. Jumper Plaintiff vs. Kenneth L. Fry, Jr., Defendant File No. 07-1124 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 T0: Holy Spirit 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: any and all medical records reports correspondence diagnostic test results pertaining to Lorne K Jumper DOB: 8/29164 SSN: 192-60-8653 at Johnson Duffie Stewart & Weidner, 301 Market Street P.O. Box 109, Lemoyne, PA 17043. 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: Jefferson J. Shipman, Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE. 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: Pr thonotary/ evil ? ision Deputy DATE: /02 O 08 Seal oft e Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lorne K. Jumper Plaintiff vs. Kenneth L. Fry, Jr., Defendant File No. 07-1124 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Orthopedic Institute of Pennsylvania (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 records reports correspondence diagnostic test results pertaining to Lorne K Jumper DOB: 8/29/64 SSN: 192-60-8653 at Johnson Duffie Stewart & Weidner, 301 Market Street P.O. Box 109, Lemoyne, PA 17043. 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: Jefferson J. Shipman, Esquire ADDRESS: 301 Market Street Lemoyne. PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: Prot onotary/C , evil Divi ion Deputy DATE: /,g- /0 - O Seal oft e Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lorne K. Jumper Plaintiff vs. Kenneth L. Fry, Jr., Defendant File No. 07-1124 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Orthopaedic Surgeons of Central Pennsylvania (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 records reports correspondence diagnostic test results pertaining to Lorne K Jumper DOB: 8/29/64 SSN: 192-60-8653 at Johnson Duffie Stewart & Weidner, 301 Market Street P .O. Box 109, Lemoyne, PA 17043. 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: ADDRESS: TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: Jefferson J. Shipman, Esquire 301 Market Street Lemovne. PA 17043 717-761-4540 51785 Defendant BY THE COURT: P onotar c-Civil vision Deputy DATE: /QZ /D 08 Seal thC- Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lorne K. Jumper Plaintiff vs. Kenneth L. Fry, Jr., Defendant File No. 07-1124. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dr. Michael F Lupinacci (a PRISM (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 records reports correspondence, diagnostic test results pertaining to Lorne K Jumper DOB: 8/29/64 SSN: 192-60-8653 at Johnson Duffie Stewart & Weidner, 301 Market Street P .O. Box 109. Lemoyne, PA 17043. 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: ADDRESS: TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: Jefferson J. Shipman, Esquire 301 Market Street Lemoyne, PA 17043 717-761-4540 51785 Defendant BY THE COURT: P thonota ivil ivision DATE: _ Aa 116 /108 Seal o the( Court Deputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lorne K. Jumper Plaintiff vs. Kenneth L. Fry, Jr., Defendant File No. 07-1124 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Neuro Care (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 records reports correspondence, diagnostic test results pertaining to Lorne K Jumper DOB: 8/29164 SSN: 192-60-8653 at Johnson Duffie Stewart & Weidner, 301 Market Street P O Box 109, Lemoyne, PA 17043. 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: Jefferson J. Shipman, Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: Prot notar ivil DiI on Deputy DATE: Allo o$ Seal o t Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lorne K. Jumper Plaintiff vs. Kenneth L. Fry, Jr., Defendant File No. 07-1124 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Heritage Pediatrics (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 records reports correspondence, diagnostic test results after January 1 2000 pertaining to Lorne K Jumper DOB: 8/29/64 SSN: 192-60-8653 at Johnson Duffie Stewart & Weidner, 301 Market Street P.O. Box 109, Lemoyne, PA 17043. 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: Jefferson J. Shipman, Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: Proth otary/ , i it ivisi DATE: 1.7-116109 Seal oft Court Deputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lorne K. Jumper Plaintiff vs. Kenneth L. Fry, Jr., Defendant File No. 07-1124 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Black Landscape Contractin (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 emplovment records personnel file medical records as an employee workers' compensation file pertaining to Lorne K Jumper DOB: 8/29/64 SSN: 192-60-8653 at Johnson Duffie Stewart & Weidner, 301 Market Street P.O. Box 109 Lemoyne, PA 17043. 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: Jefferson J. Shipman Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant DATE: /.2//o oCourt BY THE COURT: Pr onotary/CI i it vision Deputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lorne K. Jumper Plaintiff vs. Kenneth L. Fry, Jr., Defendant File No. 07-1124 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: _ Giant Food Stores (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 employment records personnel-file, medical records as an employee, workers' compensation file pertaining to Lorne K Jumper DOB: 8/29/64 SSN: 192-60-8653 at Johnson, Duffe, Stewart & Weidner, 301 Market Street P.O. Box 109, Lemovne PA 17043. 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: Jefferson J. Shipman Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-.761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: Pro onotary/CI iviI ision DATE: Io /O Seal of e Court Deputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lorne K_ Jumper Plaintiff vs. Kenneth L. Fry, Jr., Defendant File No. 07-1124 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 T0: McCov Brothers. Inc. (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 employment records, personnel file, medical records as an employee, workers' compensation file pertaining to Lorne K. Jumper DOB: 8/29/64 SSN: 192-60-8653 at Johnson, Duffie, Stewart & Weidner, 301 Market Street, P.O. Box 109, Lemoyne PA 17043. 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: ADDRESS: TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: Jefferson J. Shipman. Esauire 301 Market Street Lemovne. PA 17043 717-761-4540 51785 Defendant BY THE COURT: Pr onotarylC ivil ivision DATE: /'-7- !o Seal f We Court Deputy (Eff. 7197) r.... P .. ^<; SCHMIDT KRAMER PC BY: Gerard C. Kramer, Esquire, ESQUIRE I.D. #44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorneys for Plaintiff(s) gkramerAschmidtkramer com LORNE K. JUMPER, Plaintiff V. KENNETH L. FRY, JR., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : No. 07-1124 CIVIL ACTION - LAW 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, Plaintiff certifies that: (1) A Notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoena is sought to be served; (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate; (3) no objection to the subpoena has been received; and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. By: Respectfully submitted, SCHMIDT KRAMER PC Gerard C. Kramer, Esquire ID # 44715 209 State Street Harrisburg, PA 17101 717-232-6300 Attorney for Plaintiff Date• 19 Mr. Jefferson J. Shipman, Esquire Johnson Duffie 301 IVlarl>ct. Street Lemovne, PA 17043-1628 Re: Lorne K. Jumper v. Kenneth L. Fry, Jr. No. 07- T 124 Civil Term, Cumberland County Dear Jeff: With regard to the above rnatter, please find enclosed a Notice of intent to a subpoena to the Motorist Mutual Insurance Company. Please advise if you would waive the twenty (20) day waiting period. If you have any questions, please feel free to call or v"rite. Veil, truly -yours, SCHMIDT KRAMER PC Grc' card C. IKrai-ncr ?Attorr?ev at La \v n.closLa-c BY.Dl-d#I"d 44/15 209 State Street 11?TT"iSbLli'`?, T'A 1 1:11 (7.1 /) 2 .2-x»00 - - 1{I"?ITTei(18(71--1InjdtV_ LORNE K. UMPFR. --- Plaintiff V. KENNETH L. FRY, JR. Defendant Attorneys tut PI?urltili(si aN TFf COURT CAF r-0,?'t]` ON PLP.A CUMBERLAND COUNTY, No. CJ7- 1124 CIVIL ACTION -LAW : JURY TRIAL DEMANDED N,_.-_-----CE OF INTENT TO S__-ERV ; SUgpOEN4, LO2 ne K• Jumper, intend(s) to serve a subpoe2?a ide ntrcal to t11e one that is attached to this Notices you have t«'enty (20) days fro m the date listed below which 10 file of record and serve upon the and ersigned an obj.ection to the° subpoer.?-.. If no objection is made, the subpoena ma y l)e served. Pespectfully su ,muted. SCHMIDT KRA74ER PC Da te: ( 1 Gerard C. KI-am(°r, F:,uirf 1.D• No. 44715 ?,C9 State Sircet Harrisburg, PA 17 10 1 1 ?) 2?2--6:?C Attorney for Plaintiff(s) sCHMIDT KRAMER PC 13Y. Cierard C. KrIamer, Fs..;uife, 7 JU }<t: T rl u / .1 C i . ?J . tt -t , t i 209 :state Street H- irrisniirg. PA 1 71() 1 (7i,7) 2132-6310( i c r ?r rrl l7) f ri ("`,1"! I7't ] !?l i k 1- ?i l"I"} `- r . r ?l ?l? LORNE K. JUMPER., iLi l iti\'S ii t i f1(s IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. KENNETH L. FRY, JR., Defendant No. 07-1124 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Motorists Mutual Insurance Company 2674 Monroeville Blvd. Monroeville, PA 15146-2544 Within t? enty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documerits or things at the late offices ,! SCI IMIDT KRAMER PC, 209 `?tatc. Street, 1-larrisburJ, PA 17101- I . The first party file and any other file concerning the accident of April 14, 2005 under Policy Number A and/or C]aim Number ?.- 750409. Also include high quality, color photographs oil colored reproductions. You imajl deliver or ?mail legible cop es of Uht documents or produce thing:; requested by this Subpoena, together %N.,ith the Certificate of Compliance, to the party making this reauest at the address listed above. You have the right 0, seek, iii advance, 1-lie reasonable cost of preparing the col)ies or producing 1.11c thirngs sought. if ' you fail to produc:e the docurnents cr things required by this Subpoena.. I. ithm twenty (20) days after its service, the party '301-vil-W this Subpoena seek a Court Order compelling you i.) coml_?1,% ?.?ith it. This subpoena was issued at the request of the. 1011o,vving person: Ge-)rd C. Kramer, Esquire SCHMIDT KRAMER PC (717) 232-6300 Supreme Court I.D. 4471 Attorney for Plaintiff(s) BY THE COURT: DATE: Sea! of the Court Prothonotal v / Clerk, Civil Division Deputy CERTIFICATE OF SERVICE AND NOW, this K0? day of _ v u-1- 2009, I, Gerard C. Kramer, Esquire, hereby certify that I have this day served a true and correct copy of the CERTIFICATE OF PREREQUISITE TO SERVICE OF A SUBPOENA by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Jefferson J. Shipman, Esquire Johnson Duffie 301 Market Street Lemoyne, PA 17043-1628 Respectfully submitted, SCHMIDT KRAMER PC By Gerard C. Kramer Attorney at Law Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff S R t??u J.;, 23 f' v !JF TT-!? n"N"OTARY Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com LORNE K. JUMPER, V. Plaintiff KENNETH L. FRY, JR., Defendant 2010 MAR 19 Ali 3.- 32 e: Attorneys for Dew iaft?t, , tp ?r° r J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1124 CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY: Please mark the above captioned action settled and discontinued, including all counterclaims, crossclaims and joinders of additional parties. SCHMIDT KRAMER, PC By: Gerard C. Kramer JOHNSON, DUFFIE, STEWART & WEIDNER f By: ff n ?JShi an DISCONTINUANCE CERTIFICATE :394575 AND NOW, this day of , 2010, suit has been marked as above directed. PROTHONOTARY CERTIFICATE OF SERVICE AND NOW, this Z 7- day of March, 2010, the undersigned does hereby certify that she did this date serve a copy of the foregoing praecipe upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Gerard C. Kramer, Esquire Schmidt Kramer, P.C. 209 State Street Harrisburg, PA 17101 JOHNSON, DUFFIE, STEWART & WEIDNER By: Michelle H. Spangler 394575