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HomeMy WebLinkAbout98-00065 .... .... \l .3 ~ .. ~. ~ ~ ~ ~ ,> .... ( ... ~ - . , .;) .. ~ ~ " u:. ~ . ~ DlMITRIOS SLIOUPKIDIS , GEORGlOS SLIOUPKIDIS, and ASPASIA SLIOUPKIDIS. Plaintiffs IN TIlE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 98-65 CIVIL ACTION - LAW JOEL A. BRIDWELL Defendant JURY TRIAL DEMANDED PI.AINTIFFS' PRETRIAl. MEMORANDUM 1. STATEMENT OF THE BASIC FACTS AS TO LIABILITY: On November I, 1997 PlaintiffDimitrios Slioupkidis was operating his vehicle, in which Plaintiff Georgios Slioupkidis was a passenger, on Simpson Ferry Road in Mechanicsburg when Defendant Joel A. Bridwell went through a red light at the intersection with AlIendale Road striking Plaintiffs' vehicle and causing their injuries. 2. STATEMENT OF THE BASIC FACTS AS TO DAMAGES: Both Plaintiffs were transported to the Hershey Medical Center from the accident scene in Mechanicsburg and after emergency room treatment were admitted into the hospital for the following three days. PlaintiffGeorgios Slioupkidis suffered fractures to several facial bones, specifically, the supra orbital ridge of his right eye, frontal sinus and maxillary sinus; lacerations to his forehead; glass particles embedded in and about his eye and injuries to his left shoulder and neck. He was further diagnosed with CS-C6 radiculopathy, spondylosis and left shoulder bursitis, which necessitated several courses of extensive physical therapy, and many courses of medication. He still suffers from frequent headache pain and pain and numbness in his neck, left shoulder and arm and radiating numbness in his left leg. PlaintilTDimitrios Slioupkidis sulTcrcd multiplc facial fracturcs and Inccrations; a pncumothorax "collapscd lung"; a pulmonary contusion; atrinl fibrillation; and contusions und pain in his ncck, right shouldcr, and right kncc, 3. STATEMENT OF PRINCIPAl. ISSIlES OF I.JARIJ.JTY ANn nAMAGES Liability is not an issue as the responsibility for the accident has been conceded by thc Defendant. The only issue as to damages is the value ofthc compensation for samc. 4. SIIMMARY OF LEGAl. ISSIlES None 5. WITNESSES ~~riOS Slioupkidis 2. -"eorgios Slioupkidis 3. Aspasia Slioupkidis 4. Joel A. Bridwell 5. Ambulance persoMel from Lower Allen Township EMS and/or West Shore EMS. .......... Medical Witnesses for Georgios S/iollpkdis -~. .-8aniel E. Gelb, M.D. - Hershey Medical Center ~7. B~m.is R. Banducci, M.D. - Hershey Medical Center ~ 8. N"i1 M. Vora, M.D. - Hershey Medical Center j.~.- l.9. Stanley Smith, M.D. - Hershey Medical Center jIfJIf 10 ~. Bair, P.T. - Penn's Wood Physical Therapy I 1 ~ opher Fisher, P.T. - Alexander Spring Rehab. /12: 111 Potokar, P.T. - Lakewood Hospital Physical Therapy (Ohio) ~ 13. Santhas A. Thomas, D.O. - Cleveland Clinic (Ohio) . Medical Witnesses for Dimitrios S/iollpkidis _14. Sanjiv H. Naidu, M.D. - Hershey Medical Center IS. Neil M. Vora, M.D. - Hershey Medical Centcr 16. Stanley Smith, M.D. - Hershey Medical Center 17. Russell Pole, P.T. - Keystone Physical Therapy 18. Joseph Buleton, P.T. - Alexander Spring Rehab. 6. LIST OF RXHIRITS I. Medical records of Georgios Slioupkidis 2. Medical records of Dimitri os Slioupkidis 3. Photographs of Georgios Slioiupkidis 4. Photographs of Dimitri os Slioupkidis 5. Photographs ofautomobile 7. STATES OF SRTTl.RMRNT NRr;OTIATIONS Plaintiffs have demanded Defendant's policy limits of One Hundred Thousand Dollars ($100,000.00); Defendants have offered Twenty Thousand Dollars ($20,000.00) in settlement of the claim of Georgi os Slioupkidis and Twenty-five Thousand Dollars ($25,000.00) in settlement of Dimitri os Slioupkidis. Respectfully submitted, COSTOPOULOS, FOSTER & FIELDS CQJ2 ~'-b By: . '~, David J. Foster, Esquire I.D. No.: 23151 Leslie M. Fields, Esquire I.D. No.: 29411 831 Market Street Lemoyne, PA 17043 Phone: (717) 761- 2121 COUNSEL FOR PLAINTIFFS Date: June 14,2001 , ~ 26 Hoffer DIMITRIOS SLIOUPKIDIS, GEORGIOS SLIOUPKIDIS, and ASPASIA SLIOUPKIDIS, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-65 CIVIL TERM V JOEL A. BRIDWELL, Defendant JURY TRIAL DEMANDED IN RE: PRETRIAL CONFERENCE A pretrial conference was held before the Honorable George E. Hoffer, President Judge, on Wednesday, June 20, 2001. In this auto accident case, David J. Foster, Esquire, represents the plaintiffs, and Matthew R. Gover, Esquire, represents the defendant. The negligence claim of plaintiff Aspasia has been settled. The claim of her husband, Georgios, and her son, Dimitrios, remain for trial. The three plaintiffs were in an automobile on Simpson Ferry Road traveling east through a green lighted intersection, when the defendant went through a red light and struck plaintiffs broadside. Liability is, admitted by the defendant and causation is admitted by the defendant. The damage case can be tried in a day and a half with four challenges each. The defendant has examined ~ ~ .."..... . " 98-65 Civil Pretrial Conference Page 2 the witness list of the plaintiff and expresses no problem to the Court with witnesses or exhibits. However, depositions remain to be taken on all plaintiffs' medical witnesses and plaintiffs' counsel tells the Court that he is attempting to accomplish this by the trial week of July 9th, and if that is not possible, that he will subpoena the medical people from the Hershey Medical Center to appear live at trial. By the Court, .J. David J. Foster, Esquire For the Plaintiffs Matthew R. Gover, Esquire 2411 N. Front Street Harrisburg, Pa. 17110 For the Defendant Court Administrator Prothonotary :mtf "1 i;," :1, I I' 1,_, '; "tf' 'J'.I ! .:f\111 Inl JI'" 'I', i/ 1,1 (.: '1/ 'I)' I '/ ~,., j . '. cu"'.. ' ., ""'/"JY "'/.,~;,l \/..';. It.) ~~U 't' I'tNNSYLI:'WI;\ .....' ~ " . DIMITRIOS SLlOUPKIDIS, GIORGIOS SLIOUPKIDIS, AND ASPASIA SLlOUPKIDIS, PLAINTIFFS V, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JOEL A. BRIDWELL, DEFENDANT NO, 98-65 CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED DEFENDANT'S PRE-TRIAL STATEMENT I, Backqround. , This action arises from an automobile accident that took place on November 1, 1997 at the intersection of Allendale Road and Route 2014 (East Simpson Street) in Mechanicsburg, Cumberland County, Pennsylvania. Dimitrios Slioupkidis was operating his automobile eastbound on Route 2014 when he was struck on the right side by a vehicle operated by Defendant, Joel A, Bridwell. Bridwell ran the red light at . " 'I the time of the collision causing the accident in question. Negligence in this case is not { , , in dispute. II. Damaqes. Not applicable. III. Witnesses. A. Parties to the case; " B. Physicians identified by Plaintiff; C. Physical therapist identified by Plaintiff; D. All medical records custodians; E. This will be reasonably supplemented prior to trial. . IV, Exhibits, The Defendant intends to use medical records as exhibits and will have those pre-marked at the time of trial. V. Written Reports, Not applicable. VI. Stipulations. Defendant would request a stipulation as to the authenticity of all medical records exchanged in discovery. VII. Settlement Authoritv. A. Defendant has previously made an offer to Plaintiffs' counsel in the amount of $25,000 for Dimitrios and $20,000 for Giorgios. Plaintiffs have not accepted that offer. B. Trial time: 2-3 days. Respectfully submitted, NEALON & GOVER, P.C. Date: &~c-(!fJ( By: dAI/ wrzS)!j ~_ Matthew R. Gover, Esquire J.D. #: 47593 2411 North Front Street Harrisburg, PA 17110 717/232-9900 ~ ~'S , '...; ;';, ,,' , 2 . . . CERTIFICATE OF SERVICE AND NOW, this 14'h day of June, 2001, I hereby certify that I have served the foregoing DEFENDANT'S PRE-TRIAL STATEMENT on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: David J. Foster, Esquire COSTOPOULOS, FOSTER & FIELDS 831 Market Street P.O. Box 222 Lemoyne, PA 17043 ~ DIMITRIOS SLIOUPKIDIS, GIORGIOS SLlOUPKIDIS, AND ASPASIA SLIOUPDIDIS, PLAINTIFFS V. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 98-65 : CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED JOEL A. BRIDWELL, DEFENDANT 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, Joel A. Bridwell, 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 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. DATE: 10/29/99 MA HEW R. GOVER, ESQUIRE ATTORNEY FOR DEFENDANT 1<& Nealon ~:~GoYer M ... ATTORNEYS AT LAW JOI MARKET STREET' 9~ FLOOR r.o. BOX 865 HARRISBURG, rA 17108 1717)1JH900 FAX'1717)1J6.9119 JAMES G. NEALON. III MATTHEW R. GOVER ORlAN W. rERRY DAVID J, FREED CHRISTorHER J. KNIGHT October 29, 1999 Dr. Bruce Bailey Belvedere Medical Center 850 Walnut Bottom Road Carlisle, PA 17013 In Re: Dimitrios Slioupkidis Social Securily #: 272-80-7877 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, r;~b~~ ~~ Barbara Baker, Paralegal NEALON & GOVER Ibjb Enclosures DIMITRIOS SLlOUPKIDIS, GIORGIOS SLlOUPKIDIS, AND ASPASIA SLlOUPDIDIS, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 98-65 CIVIL ACTION . AT LAW JOEL A. BRIDWELL, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dr. Bruce Bailey Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 91h Floor, Harrisburg, PA 17101. 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 abDve. 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 fDllowing person: Matthew R. Gover, Esquire 301 Market Street, 9th Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: Seal of the Court DATED: /0 -/f- tjtj . r -'I ,~' ( ':", , \; ;: ,~} ,;~ DIMITRIOS SLIOUPKIDIS, GIORGIOS SLlOUPKIDIS, AND ASPASIA SLlOUPDIDIS, PLAINTIFFS V. JOEL A. BRIDWELL, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-65 : CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED NOTICE TO: Dr. Bruce Bailey , You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 , I I, Records Custodian for Dr. Bruce Bailey, certify to the best of my j I , knowledge, Information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. ~ I I ) if " l~ .. Ii , DATE: Records Custodian it ,. Ii Nealon ~~G~ytt~ ATTORNEYS AT LAW JOI MARKET STREET' 9" FLOOR r.o. BOX 865 IIARRISBURG, rA 17108 171711Jl.9900 FAX, (71711J6.9119 JAMES G. NEALON, III MATTIIEW R. GOVER BRIAN W. rERRY DAVID J, FREED CHRISTorHEl1 J, KNIGIlT October 29, 1999 Dr. Dennis Diaz Belvedere Medical Center 850 Walnut Bottom Road Carlisle, PA 17013 In Re: Dimitrios Slioupkidis Social Security #: 272-80-7877 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, ~~~~~ Barbara Baker, Paralegal ' NEALON & GOVER Ibjb Enclosures DIMITRIOS SLlOUPKIDIS, GIORGIOS SLIOUPKIDIS, AND ASPASIA SLIOUPDIDIS, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO, 98-65 CIVIL ACTION - AT LAW JOEL A. BRIDWELL, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dr. Dennis Dlaz Within twenty (2.9) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & GDver, 301 Market Street, 9'h Floor, Harrisburg, PA 17101, You may deliver or mall 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 fall to produce the documents or things required by this SubpDena within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you tD comply with it. This Subpoena was issued at the request of the following person: Matthew R. Gover, Esquire 301 Market Street, 91h Floor Harrisburg, PA 17101 717.232.9900 Attorney for Defendant BY THE COURT: DATED: iD - fIr - 11 Seal of the Court d ~7IJ+~ EX PLANA TION OF REQUIRED RECORDS TO: Custodian of Records For: Dr. Dennis Dlaz Entire personnel file, Including but not limited to applications for employment, correspondence, memorandum, health records, payroll records or other documents pertaining to: DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present Dimitrios Slioupkldis 272-80-7877 '10/17/63 ....... DIMITRIOS SLIOUPKIDIS, GIORGIOS SLIOUPKIDIS, AND ASPASIA SLlOUPDIDIS, PLAINTIFFS V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JOEL A, BRIDWELL, DEFENDANT NO. 98-65 : CIVIL ACTION - AT LAW : JURY TRIAL DEMANDED NOTICE TO: Dr. Dennis Dlaz You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 j . I, Records Custodian for Dr. Dennis Diaz, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. ., DATE: Records Custodian ~ ...... D/MITRIOS SLIOUPKID/S, GIORGIOS SLIOUPKIDIS, AND ASPASIA SLIOUPDIDIS, PLAINTIFFS V. JOEL A. BRIDWELL, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 98.65 : CIVIL ACTION. AT LAW : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ones that are attached to this Notice. You have twenty (20) days from the date listed Defendant, Joel A. Bridwell, intends to serve Subpoenas identical to the 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. Date: 10/7/99 mriU kj)U'\ (~fL~JY ~w R. Gover, EsqUIre Attorney for the Defendant CERTIFICATE OF SERVICE AND NOW, this 29th day of October, 1999, I hereby certify that I have served the foregoing Certificate Prerequisite to Service of a Subpoena on the fOllowing by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Leslie M. Fields, Esquire 831 Market Street P.O. Box 222 Lemoyne, PA 17043 ~~ESq~.~~I~ :l- J ~ .... .. C;; ... "C <oJ ~J . ~ . ~ en e ~ e. ..:J ~ d"i \' '" r .. ,. ~ ... ,. , ~ g: c~~ Po 0 :;;: , If c,~ I r- ,.~ .... I :5- , kU :;c Hj~ I: '. F "'t ~ ~~ -, lOo.. o::l ::i! , 0 ::5 V) en U . ~ '~ Iol q ~ '" ~~ I:: ~ i:ll:S III < ~!;( ~~~ ~~ ~~~ urz ~ ~ en 0" <OZ ..l2 ::Eo.:ffi =q::;; - ~ It'< 1Xl ur ~ ~ 8 ~ < . .' , . DIMITRIOS SLIOUPKIDIS, G10RGlOS SLIOUPKIDIS, and ASPASIA SLIOUPKIDIS, Plblntlffs vs. IN THE COURTOF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. qp- (.~- ~U T~ JOEL A. BRIDWELL, Defendant CIVIL ACTION - LAW 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 Libertry A venue Carlisle, PA 17013 Phone: 1-717-249-3166 NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ~ D1MITRlOS SLIOUPKIDlS, GIORGIOS SLIOUPKIDlS, and ASPASIA SLIOUPKIDIS. Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. tj i- (,~; e.;,u -r~ vs. CIVIL ACTION. LAW JOEL A. BRIDWELL, Defendant JURY TRIAL DEMANDED COMPLAINT AND NOW come the Plaintiffs, Dimitrios Slioupkidis, Giorgios Slioupkidis and Aspasia Slioupkidis, by and through their attorney, Leslie M. Fields, Esquire, and respectfully represent as follows: 1. Plaintiffs, Dimitrios Slioupkidis, Giorgios Slioupkidis and Aspasia Slioupkidis are adult individuals residing at 244 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Joel A. Bridwell, is an adult individual residing at 6109 Haymarket Way, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The events giving rise to this cause of action occurred on or about November 1. 1997, on Allendale Road and Route 2014 (East Simpson Street) in Mechanicsburg, Cumberland County, Pennsylvania. 4. At the aforesaid time and place, Plaintiff, Dimitrios Slioupkidis was operating a 1989 Nissan Sentra automobile, with Plaintiffs Giorgios Slioupkidis and Aspasia Slioupkidis as passengers, travelling eastbound on Route 2014 when they were struck on the right side by the vehicle operated by Defendant, Joel A. Bridwell, who was travelling northbound on Allendale Road. 5. At the aforesaid time and place, Plaintiffs, Dimitrios Slioupkidis, Giorgios Slioupkidis and Aspasia Slioupkidis, were caused to sustain severe injuries to their persons, hereinafter more fully described. 6. At the aforesaid time and place, the collision and injuries resulting therefrom were caused by the negligent, careless andlor reckless actions of Defendant, Joel A. Bridwell, in that he: (a) failed to obey the traffic signal; (b) failed to stop before causing an accident; (c) failed to keep a proper lookout; (d) failed to see what he should have seen; (e) failed to notice the imminence of an accident and to take the necessary steps to avoid the same; (h) failed to maintain his vehicle under proper and adequate control; (h) operated his vehicle too fast for conditions; and (i) acted without regard for the safety and rights of Plaintiffs. 7. As a direct and proximate result of the negligent, careless andlor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiffs, Dimitrios Slioupkidis; Giorgios Slioupkidis and Aspasia Slioupkidis have suffered injuries which were and are severe, painful, serious and pennanent as set forth in greater detail below. 8. Plaintiffs Dimitrios Slioupkidis, Giorgios Slioupkidis and Aspasia Slioupkidis, are covered by a policy of insurance containing a full tort election. COUNT I - Dlmilrlos SlIounkldls v. Joel A. Bridwell 9, The allegations set forth in paragraphs I through 8 arc incorporated herein by reference as if fully set forth. 10. As a direct and proximate result of the negligent, careless and/or reckless acts of the Defe-ndant, Joel A. Bridwell, the Plaintiff, Dimitrios Slioupkidis, has suffered injuries which were and are severe, painful, serious and pennanent including, but not limited to a right anterior pneumothorax, a right pulmonary contusion, multiple facial fractures and lacerations, and an atrial fibrillation. II. As a further direct and proximate result of the negligent, careless andlor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiff, Dimitrios Slioupkidis, has been obligated to receive and undergo medical attention, care and expenses for the injuries he has suffered and may be obligated to continue to incur such expenses for an indefinite time in the future. . I 12. As a further direct and proximate result of the negligent, careless andlor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiff, Dimitrios Slioupkidis, has suffered a loss j of earnings andlor impainnent of his earning capacity and power. 13. As a further direct and proximate result of the negligent, careless andlor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiff, Dimitrios Slioupkidis, has suffered medically determinable physical impainnents which have prevented him from perfonning all of the nonnal acts and duties which constitute his usual and customary daily activities. 14. As a further direct and proximate result of Defendant's conduct as described in I detail above, Plaintiff sustained disfiguring and painful scarring and in the future may continue to so suffer. '~ ~ 15. As a further dlrcet and proximate rcsult uf the negllgcnt, carclcss and lor rccklcss acts of the Defcndant, Joel A, Bridwcll, the Plaintiff, Dlmitrios Slioupkidis, has experlenccd severe pain and suffering, mental anguish and humiliation, and In the future may continue to so experience. 16. As a further direct and proximate rcsult of the negligent, careless and lor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiff, Dimitrios Slioupkidis, has suffered a loss of life's pleasures and in the future will continue to suffer a loss of life's pleasures. WHEREFORE, Plaintiff, Dimitrios Slioupkidis, demands judgment against Defendant, Joel A. Bridwell, in an amount in excess of the compulsory arbitration limits plus costs and interest as provided by law. COUNT 2 - Dimitrios Sliouokidis v. Joel A. Bridwell -Negligent Infliction of Emotional Distress 17. The allegations set forth in paragraphs I through 16 are incorporated herein by reference as if set forth in full. 18. At the time of the aforesaid accident, Dimitrios Slioupkidis was the son of Giorgios and Aspasia Slioupkidis. 19. At the time of the aforesaid accident, Dimitrios Slioupkidis eyewitnessed the automobile the injuries being caused to his parents. 20. As a direct and proximate result of the negligent, careless andlor reckless actions of Defendant, and Dimitrios Slioupkidis's sensory and contemporaneous observation of the accident and the injuries sustained by his father and mother, Dimitrios Slioupkidis has experienced severe emotional impact and suffered significant mental pain and suffering, emotional distress, anguish, anxiety and various physical injuries resulting therefrom including, " but not limited to, nausea, headaches, nervousness, sleeplessness and lack of appetite. WHEREFORE, Plaintiff, Dimitrios Slioupkidis, demands judgment against Defendant, Joel A. Bridwell, In an amount in excess of the compulsory arbitration limits plus costs and Interest as provided by law, COUNT 3 - Geon!ios SliouDkldis v. Joel A. Bridwell 21. The allegations set forth In paragraphs 1 through 20 are incorporated herein by reference as if fully set forth. 22. As a direct and proximate result of the negligent, careless andlor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiff, Georgios Slioupkidis, has suffered injuries which were and are severe, painful, serious and permanent Including, but not limited to multiple facial fractures and laceration. 23. As a further direct and proximate result of the negligent, careless andlor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiff, Georglos Slioupkidis, has been obligated to receive and undergo medical attention, care and expenses for the Injuries he has suffered and may be obligated to continue to Incur such expenses for an Indefinite time in the future. 24. As a further direct and proximate result of the negligent, careless andlor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiff, Georgios Slioupkidis, has suffered medically determinable physical Impairments which have prevented him from performing all of ~ the normal acts and duties which constitute his usual and customary daily activities. II I 25. As a further direct and proximate result of the negligent, careless andlor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiff, Georglos Slioupkidis, has experienced severe pain and suffering, mental anguish and humiliation, and in the future may continue to so I. , ! j .~'~ '". experience. 26. As a further direct and proximate result of Defendant's conduct as described in detail above, Plaintiff sustained disfiguring and painful scarring and in the future may continue to so suffer. 27. As a further direct and proximate result of the negligent, careless andlor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiff, Georgios Slioupkidis, has suffered a loss of life's pleasures and in the future will continue to suffer a loss of life's pleasures. WHEREFORE, Plaintiff, Georgios Slioupkidis, demands judgment against Defendant, Joel A. Bridwell, in an amount in excess of the compulsory arbitration limits plus costs and interest as provided by law. COUNT 4 - Geon!ios Sliouokidis v. Joel A. Bridwell-Negligent Infliction of Emotional Distress 28. The allegations set forth in paragraphs 1 through 27 are incorporated herein by reference as if set forth in full. 29. At the time of the aforesaid accident, Georgios Slioupkidis was the father of Dimitrios Slioupkidis and the husband of Aspasia Slioupkidis. 30. At the time of the aforesaid accident, Georgios Slioupkidis eyewitnessed the automobile the injuries being caused to his family members. 31. As a direct and proximate result of the negligent, careless andlor reckless actions of Defendant, and Georgios Slioupkidis's sensory and contemporaneous observation of the accident and the injuries sustained by his wife and son, Georgios Slioupkidis has experienced severe emotional impact and suffered significant mental pain and suffering, emotional distress, anguish, anxiety and various physical injuries resulting therefrom including, but notlim!ted to, ,". nausea, headaches, nervousness, sleeplessness and lack of appetite. WHEREFORE, Plaintiff, Georgios Slioupkidis, demands judgment against Defendant, Joel A. Bridwell, in an amount in excess of the compulsory arbitration limits plus costs and interest as provided by law. COUNT 5 - Georl!ios Sliouokidis v. Joel A. Bridwell -Loss of Consortium 32. The allegations set forth in Paragraphs 1 through 32 are incorporated herein by reference as if fully set forth. 33. At all relevant times herein, Plaintiff, Georgios Slioupkidis, and Plaintiff, Aspasias Slioupkidis, were lawfully married. 34. As a direct and proximate result of the negligent acts and conduct of Defendant, the Plaintiff, Plaintiff, Georgios Slioupkidis, has suffered a loss of consortium, society and companionship of his wife, Aspasias Slioupkidis. WHEREFORE, Plaintiff, Georgios Slioupkidis, demands judgment against Defendant, Joel A. Bridwell, in an amount in excess of the compulsory arbitration limits plus costs and interest as provided by law. COUNT 6 - Asoasia Sliouokidis v. Joel A. Bridwell 35. The allegations set forth in paragraphs 1 through 34 are incorporated herein by reference as if fully set forth. 36. As a direct and proximate result of the negligent, careless andlor reckless acts of I " the Defendant, Joel A. Bridwell, the Plaintiff, Aspasia Slioupkidis, has suffered injuries which were and are severe, painful, serious and pennanent including, but not limited to multiple traumatic injuries. 37. As a further direct and proximate result of the negligent, careless andlor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiff, Aspasia Slioupkidis, has been obligated to receive and undergo medical attention, care and expenses for the injuries she has suffered and may be obligated to continue to incur such expenses for an indefinite time in the future. 38. As a further direct and proximate result of the negligent, careless andlor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiff, Aspasia Slioupkidis, has suffered medically determinable physical impairments which have prevented her from performing all of the normal acts and duties which constitute her usual and customary daily activities. 39. As a further direct and proximate result of Defendant's conduct as described in detail above, Plaintiff sustained disfiguring and painful scarring and in the future may continue to so suffer. 40. As a further direct and proximate result of the negligent, careless andlor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiff, Aspasia Slioupkidis, has experienced severe pain and suffering, mental anguish and humiliation, and in the future may continue to so experience. 41. As a further direct and proximate result of the negligent, careless andlor reckless acts of the Defendant, Joel A. Bridwell, the Plaintiff, Aspasia Slioupkidis, has suffered a loss of life's pleasures and in the future will continue to suffer a loss of life's pleasures. WHEREFORE, Plaintiff, Aspasia Slioupkidis, demands judgment against Defendant, Joel A. Bridwell, in an amount in excess of the compulsory arbitration limits plus costs and interest as provided by law. \:, ~..;-:l;...-:-- m,UNT 7 - Asoasia Slioupkldis v. Joel A. Brldwcll - NCl!lh!entlnfliction of Emotional Distrcss 42. Thc allcgations set forth In paragraphs 1 through 53 arc incorporated hcrcin by refercnce as if set forth in full, 43. At the time of the aforesaid accident, Aspasia Slioupkidis was the mother of Dimitrios Slioupkidis and the wife of Giorgios Slioupkldis. 44. At the time of the aforesaid accident, Aspasia Slioupkidis eyewitnessed the automobile the injuries being caused to her family members. 45. As a direct and proximate result of the negligent, careless andlor reckless actions of Defendant, and Aspasia Slioupkidis's sensory and contcmporaneous observation of the accident and the injuries sustained by her husband and son, Aspasia Slioupkidis has experienced severe emotional impact and suffered significant mental pain and suffering, emotional distress, anguish, anxiety and various physical injuries resulting therefrom including, but not limited to, nausea, headaches, nervousness, sleeplessness and lack of appetite. WHEREFORE, Plaintiff, Aspasia Slioupkidis, demands judgment against Defendant, Joel A. Bridwell, in an amount in excess of the compulsory arbitration limits plus costs and interest as provided by law. COUNT 8 - ASDasias SIiOUDkidis v. Joel A. Bridwell -Loss of Consortium 46. The allegations set forth in Paragraphs 1 through 33 are incorporated herein by reference as if fully set forth. 47. At all relevant times herein, Plaintiff, Aspasia Slioupkidis, and Plaintiff, Georgios Slioupkidis, were lawfully married. 48. As a direct and proximate result of the negligent acts and conduct of Defendant, ", 0' . . the Plaintiff, Plaintiff, Aspasla SlIoupkidls, has suffered a loss of consortium, society and companionship of her husband, Georgios SlIoupkldls. WHEREFORE, Plaintiff, Aspasia SlIoupkidis, demand judgment against Defendant, Joel A. Bridwell, in an amount in excess of the compulsory arbitration limits plus costs and interest as provided by law. RESPECTFULLY SUBMITIED: (/' . / r:~'~ :) .,~ /' ~ / 'L-t.-LJ'..LI . ' ~sHe M. Fields, Esquire cOstOPOULOS, FOSTER & FIELDS 831 Market Street/P.O. Box 222 Lemoyne, PA 17043 Phone: (717) 761-2121 A TIORNEY FOR PLAINTIFFS VERIFICATION I verify that the statements made in the foregoing documents are true and correct. , I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. Section 4904, relating to unsworn falsification to authorties. G~"Z..,f.{<tJJ. ~.E{'''''''PKfd.() Giorgios Slioupkidis Daqed: 1?/1R/Q7 VERIFICATION I verify that the statements made in the foregoing documents are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. Section 4904, relating to unsworn falsification to authorties. Oi~~~ l\uf~'4 Dimitrios Slioupkidis Dated: 12/1 B/97 VERIFICATION I verify that the statements made in the foregoing documents are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. Section 4904, relating to unsworn falsification to authorties. -W {( (i etI. 6'(' a. i/Jad<r ttY Aspasia Slioupkidis D~ted: 12/1 B/97 SHERIFF'S RETURN - REGULAR CASE HOI 1998-00055 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SLIOUPKIDIS DIMITRIOS ET AL VS. BRIDWELL JOEL A ROBERT L. FINK. SR. CUMBERLAND County, Pennsylvania, who to law, says, the within COMPLAINT . Sheriff or Deputy Sheriff of being duly sworn according was served upon BRIDWELL defendant, at 19~ at 6109 MECHANICSBURG. JOEL A 1655:00 HOURS, on the ~ day of January HAYMARKET WAY PA 17055 , CUMBERLAND the County, Pennsylvania, by handing to JOEL BRIDWELL a true and attested copy of the COMPLAINT together with NOTICE and at the same time directing His attention to the contents thereof, Sheriff's Costs: Docketing Service Af:fidavit Surcharge 18.00 6.20 .00 2.00 So answers~~~ R. Thomas Kl1ne, Sher111 $~6.~0 COSTOPOULOS FOSTER & FIELDS 01/22/~:98~~~qz~~ Sworn and sUbscribeyto before me this ~ .:2,^,,",,-day of _!H"'""" I 19 rH' A. D, q!,~ () ")"",00.., IO"z;;' I Vrotr,.o"il2itaryl , .: I D1MITRIOS SLIOUPKIDlS, GIORGIOS SLIOUPKIDlS, and ASPASIA SLIOUPKIDIS, Plaintiffs vs. IN THE COURTOF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. 1%- 0J C!J~ CIVIL ACTION - LAW JOEL A. BRIDWELL, Defendant JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE COUNTS SIX AND SEVEN OF THE COMPLAINT TO THE PROTHONOTARY: Please mark Counts Six and Seven of the above captioned action settled and discontinued. Thank you. Respectfully submitted, ~ fl.Lt,L Leslie M. Fields, Esquire COSTOPOULOS, FOSTER & FIELDS 831 Market Street/P.O. Box 222 Lemoyne, Pennsylvania 17043 Phone: (717) 761-2121 ATTORNEY FOR THE PLAINTIFF Dated: s/, /w- . ,{ it .'1 ,.,- "~1 )~ ~ " " I.D ~ C- eo - :t: ::;:l .,- "'QiiJ ",. ~~ n'lr>. -< ~fJJ I :rJ6 "o..~ c.n 0 (f),_,,,, ~.". =P-:'d '<: c:' -0 1.:~C) ::>: Oh (..:l.") (.0) iSm J;--.C .. -='I ~ r. ~ :;:- -< DIMITRIOS SLIOUPKIDIS, GIORGIOS SLIOUPKIDIS, AND ASPASIA SLlOUPDIDIS, PLAINTIFFS V, JOEL A. BRIDWELL, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . . : NO. 98-65 : CIVIL ACTION - AT LAW . . : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Joel A. Bridwell, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER By: 7f~4~., Matthew R. Gover, Esquire Attorney I.D. #47593 301 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this 24th day of June, 1999, I hereby certify that I have served the foregoing Praecipe on the following by depositing a true and correct copy of same In the United States mails, postage prepaid, addressed to: Leslie M. Fields, Esquire COSTOPOULOS, FOSTER & FIELDS 831 Market Street P.O. Box 222 Lemoyne, PA 17043 71~~ Matthew R. Gover Esquire DIMITRIOS SLIOUPKIDIS, GIORGIOS SLlOUPKIDIS, AND ASPASIA SLlOUPDIDIS, PLAINTIFFS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 98-65 : CIVIL ACTION .AT LAW JOEL A. BRIDWELL, DEFENDANT : JURY TRIAL DEMANDED ANSWER TO COMPLAINT AND NOW comes Joel A, Bridwell, by his attorneys; NEALON & GOVER, and files the following Answer to Plaintiffs' Complaint: 1 - 3. Admitted. 4. It is admitted that the Plaintiff, Dimitrios Slioupkidis, was operating a 1989 Nissan Sentra automobile, with Plaintiffs Giorgios Slioupkidis and Aspasia Slioupkidis as passengers, traveling eastbound on Route 2014, and that a vehicle traveling northbound on Allendale Road, being driven by the Defendant, Joel A. Bridwell, came into contact with the Slioupkidis vehicle. 5 - 7. Denied pursuant to Pa.R.Civ.P * 1029(e). 8. Denied. After reasonable investigation, Defendant Is without knowledge or information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. COUNT 1 - DIMITRIOS SLlOUPKIDIS v. JOEL A. BRIDWELL 9. Paragraphs 1 through 8 of Plaintiffs' Complaint are Incorporated herein by reference hereto. 10 -16. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. COUNT 2 . DIMITRIOS SLlOUPKIDIS v. JOEL A. BRIDWELL NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS 17. Paragraphs 1 through 16 of Plaintiffs' Complaint are incorporated herein by reference hereto. 18 - 20. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. COUNT 3 . GEORGIOS SLlOUPKIDIS v. JOEL A. BRIDWELL 21. Paragraphs 1 through 20 of Plaintiffs' Complaint are incorporated herein by reference hereto. 22 - 27. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. COUNT 4 - GEORGIOS SLlOUPKIDIS v. JOEL A, BRIDWELL NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS 28, Paragraphs 1 through 27 of Plaintiffs' Complaint are incorporated herein by reference hereto. 29 - 31. Denied. After reasonable investigation, Defendant is without knowledge or Information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. COUNT 5 . GEORGIOS SLlOUPKIDIS v. JOEL A. BRIDWELL LOSS OF CONSORTIUM 32. Paragraphs 1 through 31 of Plaintiffs' Complaint are incorporated herein by reference hereto. 33 - 34. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. COUNT 6 - ASPASIA SLlOUPKIDIS v. JOEL A. BRIDWELL 35. Paragraphs 1 through 34 of Plaintiffs' Complaint are incorporated herein by reference hereto. 36 - 41. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. COUNT 7 - ASPASIA SLIOUPKIDIS v. JOEL A. B~~E~ELL NEGLIGENT INFLICTION OF EMOTIONAL DIS ~ 42. Paragraphs 1 through 41 of Plaintiffs' Complaint are Incorporated herein by reference hereto. 43 - 45. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. COUNT 8 - DIMITRIOS SLlOUPKIDIS v. JOEL A. BRIDWELL LOSS OF CONSORTIUM 46. Paragraphs 1 through 45 of Plaintiffs' Complaint are incorporated herein by reference hereto. 47 - 48. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter asserted and proof is demanded at trial. WHEREFORE, Joel A. Bridwell respectfully would request that the Complaint be dismissed with costs of this action. NEW MATTER 49. Paragraphs 1 thiOugh 48 of Plaintiffs' Complaint are incorporated herein by reference hereto. 50. Plaintiffs' claims are barred in whole or in part by the Pennsylvania Motor Vehicle Financial Responsibility Act. '~ , .\1' fS.' if. ,. ,- WHEREFORE, Joel A. Bridwell respectfully would request that the Complaint be dismissed with costs of this action. Respectfully submitted, NEALON & GOVER a& wnC1~ Matthew R. Gover, Esq. Atty.I.D.#47593 301 Market Street - 9th Floor PO Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 , :: ;(:~:. :' ", ~'I :~. ", '. ~ I, Joel A, Bridwell, verify that the statements made in the foregoing Answer to Compleint is true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unswom falsification to authorities. Dated: ~~ (0 ,19~ ~ ~L . BRIDWE AND NOW, this 13th day of July, 1999 I hereby certify that I have served the foregoing Answer to Plaintiffs' Complaint on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Leslie M Fields, Esquire COSTOPOULOS, FOSTER & FIELDS 831 Market Street P.O. Box 222 Lemoyne, PA 17043 #~~ Matthew R. Gover Esquire Dated: 9(i~ /5,1777 DIMITRIOS SLlOUPKIDIS, GIORGIOS SLlOUPKIDIS, AND ASPASIA SLlOUPKIDIS, PLAINTIFFS V. JOEL A. BRIDWELL, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 98-65 : CIVIL ACTION. AT 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, Defendant, Joel A. Bridwell, 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 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. DATE: 10/5/00 'iY\ ~ 1<, b (j-Y'€J".J61 MATTHEW R. GOVER, ESQUIRE ATTORNEY FOR DEFENDANT Nealon ~.over 2411 North Pront Street lIARRISnURG, PA 11110 (111) 23209900 PAX, (111) 23&.9119 ]AMI!S G. NEALON,/JI MA11'HEW R. GOVI!R nRlAN W. PERRY DAVlD].PREED CHRlSTOPHI!R]. KNIGHT October 5, 2000 Stuart A. Hartman, D.O. 2645 North 3rd Street Harrisburg, PA 17110 In Re: Glorglos SlIoupkldis Social Security #: 272-80-7664 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place In'dicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation In this matter Is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, j ~~c-'-__ r;~ Barbara Baker, Paralegal NEALON & GOVER r:' '. ,. ~-J ~; Ibjb Enclosures ,:,;. '.... DIMITRIOS SLIOUPKIDIS, GIORGIOS SLIOUPKIDIS, AND ASPASIA SLIOUPDIDIS, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 98-65 CIVIL ACTION - AT LAW JOEL A. BRIDWELL, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Stuart A. Hartman, 0,0, Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9th Floor, Harrisburg, PA 17101. You may deliver or mall legible caples 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 fall to produce the documents or things required by this SubpDena within twenty (20) days after Its service, the party serving this Subpoena may seek a Court Order compelllng you to comply with It. This Subpoena was issued at the request of the following person: Matthew R. Gover, Esquire 301 Market Street, 9th Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED:~ ~ Seal of the Court ~(L-It';') p~ Ip THONOTARY b ~2. ~ If'fJ EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Stuart A. Hartman, D,O. ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present Glorglos SlIoupkldls 272-80-7664 2/24/27 DIMITRIOS SLlOUPKIDIS, GIORGIOS SLlOUPKIDIS, AND ASPASIA SLlOUPKIDIS, PLAINTIFFS V. JOEL A. BRIDWELL, DEFENDANT TO: Stuart A. Hartman, 0,0. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . . : NO. 98-65 : CIVIL ACTION. AT LAW : JURY TRIAL DEMANDED NOTICE You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 , ,I I, Records Custodian for Stuart A. Hartman, D.O., certify to the best of my knowledge, Information and belief that all documents or things required to be produced pursuant to the Subpoena issued on DATE: j have been produced. Records Custodian ~ 'M' - Nealon ~'.oYer 1411 North Pront Street HARRISBURG, PA 17110 (717) 2J1099OO PAX, (717) 2J6-9II9 ]AMES G, NEALON, 11/ MA 1THEW R. GOVl!l\ BRIAN W. PI!IlIlY DAVlD].PREED CHRISTOPHER]. KNIGHT October 5, 2000 Hershey Medical Center 500 University Drive Hershey, PA 17033 In Re: Dlmltrlos SlIoupkldls Social Security #: 272-80-7877 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to In the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may In advance of the deposition date send us photocopies of the records. With such photocopies, please Include your statement for the cost of preparing the same, which we will promptly pay, In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, ~~'^-^-"'- ~ c.J~ Barbara Baker, Paralegal NEALON & GOVER Ibjb Enclosures DIMITRIOS SLIOUPKIDIS, GIORGIOS SLIOUPKIDIS, AND ASPASIA SLIOUPDIDIS, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO, 98-65 CIVIL ACTION . AT LAW JOEL A, BRIDWELL, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Hershey Medical Center Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9'" Floor, Harrisburg, PA 17101. You may deliver or mall 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 caples or producing the things sought. If you fall 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 I, j " 'I " l )~ It. This Subpoena was Issued at the request of the following person: Matthew R, Gover, Eequlre 301 Market Street, 9"' Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: .{ , II' ,. ' I, , : ,., . .'1 ;\ : OATEO:Sf:....-J. I Seal of the Court 146'~.>y4- Ip THONOTARY ~27f~~ .. i, .J~ owod , EXPLJ\NA:rION OF REQUIRED RECORD.S TO: Custodian of Records For: Hershey Medical Center ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present Dlmltrlos SlIoupkldls 272-80-7877 10/17/63 '". - 9Ji DIMITRIOS SLlOUPKIDIS, GIORGIOS SLIOUPKIDIS, AND ASPASIA SLIOUPKIDIS, PLAINTIFFS V. JOEL A. BRIDWELL, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 98.65 : CIVIL ACTION. AT LAW . . : JURY TRIAL DEMANDED NOTICE TO: Hershey Medical Center You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 , I I, Records Custodian for Hershey Medical Center, certify to the best of my knowledge, Informatlon and belief that all documents or things required to be produced pursuant to the Subpoena Issued on have been produced. DATE: j" Records Custodian i~. "' " '~'\ , 1411 North Frool Slrrct IIARRlSBURG, FA 11110 (111) 13209900 FAX, (111) 2J6.9119 ]AMES G. NEALON, III MATTHEW R. GOVI!R BRIAN W, FERRY DAVID]. FIU!J!D CHRlSTOFHER]. KNIGHT October 5, 2000 Alexander Spring Rehab 27 Brockwood Avenue Carlisle, PA 17013 In Re: Dimitrios SlIoupkidis Social Security #: 272-80-7877 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to In the Subpoena for examination by the undersigned at the time and place Indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn, Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, PJ~~~ ~~ Barbara Baker, Paralegal NEALON & GOVER IbJb Enclosures DIMITRIOS SLIOUPKIDIS, GIORGIOS SLIOUPKIDIS, AND ASPASIA SLIOUPDIDIS, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA .. ".,-..-......",-.. V. NO. 98-65 CIVIL ACTION - A T LAW JOEL A. BRIDWELL, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Alexander Spring Rehabilitation Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following dDcuments or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. You may deliver or mall 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 caples Dr producing the things sought. If you fall 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 CDUrt Order compelling you to comply with It. This SUbpoena was Issued at the request of the following person: Matthew R. Gover, Esquire 301 Markot Street, 9'" Floor HarrIsburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: J'iE.r.,..J. Seal of the Court ffI f2-k) 12. ~ 'P OTHONOTARY" ..-- ~~.7r~~ ,J.:) .;tDaD , EXPLANATION OF REQUIRED RECORO,S TO: Custodian of Records For: Alexander Spring Rehabilitation ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present Dlmltrlos SlIoupkldls 272-80-7877 10/17/63 DIMITRIOS SLlOUPKIDIS, GIORGIOS SLlOUPKIDIS, AND ASPASIA SLlOUPKIDIS, PLAINTIFFS V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA JOEL A. BRIDWELL, DEFENDANT : NO. 98.65 : CIVIL ACTION. AT LAW : JURY TRIAL DEMANDED NOTICE TO: Alexander Spring Rehabilitation You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009,23 I, Records Custodian for Alexander Spring Rehabilitation, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian Nealon r.over , 1411 North Pronl 51_ IIARRI5UURG, PA 17110 (717) 2)1.9900 I'AX. (717) 2J6.9119 ]AMES G. NEALON, IJJ MAmll!W R. GOVER URIAN W, PERRY DAVID]. PREEn CHRISTOPHER], KNIGHT October 5, 2000 Keystone Rehabllltallon Center 1521 Cedar Cliff Drive Camp Hili, PA 17011 In Re: Dlmltrlos SlIoupkldls Social Security #: 272-80-7877 Dear Records CustodIan: You are beIng served with a Notice and Subpoena for you to bring the records referred to In the Subpoena for examination by the undersigned at the time and place Indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure, A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plalnllff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may In advance of the deposition date send us photocopies of the records. With such photocopies, please Include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperallon in this matter is apprecIated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, ~o..J>~__ ~~ Barbara Baker, Paralegal NEALON & GOVER IbJb Enclosures DIMITRIOS SLIOUPKIDIS, GIORGIOS SLlOUPKIDIS, AND ASPASIA SLlOUPDIDIS, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 98-65 CIVIL ACTION - AT LAW JOEL A, BRIDWELL, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Keystone Rehabilitation Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEe ATTACHED at the Dffices Df Nealon & Gover, 301 Market Street, 9" Floor, Harrisburg, PA 17101. You may deliver or mall 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. YDU 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: Matthew R. Gover, Esquire 301 Market Street, 9th Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: .Qf'+- .l~. .Jr:lOO Seal of the Court ~f( fL.-/;;, 1 l' ~ 'p OTHONOTARY, ::\ ~~ ~~lJl't7- ~"" ;., , TO: Custodian of Records For: Keystone Rehabilitation ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: , SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present Dlmltrlos SlIoupkldls 272-80-7877 10/17/63 DIMITRIOS SLIOUPKIDIS, GIORGIOS SLIOUPKIDIS, AND ASPASIA SLlOUPKIDIS, PLAINTIFFS V. JOEL A. BRIDWELL, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA , . : NO. 98.65 : CIVIL ACTION. AT LAW . . : JURY TRIAL DEMANDED NOTICE TO: Keystone Rehabilitation You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Keystone Rehabilitation, certify to the best of my knowledge, Information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: I ;~ I . i I; I Records Custodian ,,:.1 , 1411 North I',ont St,<<1 IIAI\RISnUJ\G, rA 17110 (717) 132."00 PAX, (717) 236.,." lAMI!S G, N'~LON, III MArnll!W JI. GOVEI\ URIAN VI, PERRY VA VID J. PJ\EI!D CIIRISTOPIII!RJ. KNIGHi October 5, 2000 Alexander Spring Rehab 27 Brockwood Avenue Carlisle, PA 17013 In Re: Glorglos SlIoupkidis Social Security #: 272-80-7664 Dear Records custodian: You are being served with a Notice and subpoena for you to bring the records referred to in the subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records, With such photocopies. please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, ~~~,,'- ~~ Barbara Baker, Paralegal NEALON & GOVER IbJb Enclosures [' ! \1 , , '". DIMITRIOS SLIOUPKIDIS, GIORGIOS SLlOUPKIDIS, AND ASPASIA SLIOUPDIDIS, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 98.65 CIVIL ACTION. AT LAW JOEL A, BRIDWELL, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Alexander Spring Rehabilitation Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street. 9~ Floor, Harrisburg, PA 17101. You may deliver or mall 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 fall 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: Matthew R. Gover, Esquire 301 Market Street, 9"' Floor Harrisburg, PA 17101 717-232.9900 Attorney for Defendant BY THE COURT: DATED:~ 01..:2, :>c.Y'b Seal of the Court (f tL-b))2,~ /p OTHONOTARY {) ~Q.77?~rg- ~ATION QE REQUIRED RECORDS TO: Custodian of Records For: Alexander Spring Rehabilitation ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and InclUding the Present Glorglo8 SlIoupkldls 272-80-7664 2/24/27 DIMITRIOS SLlOUPKIDIS, GIORGIOS SLlOUPKIDIS, AND ASPASIA SLIOUPKIDIS, PLAINTIFFS V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . . : NO. 98.65 : CIVIL ACTION. AT LAW : JURY TRIAL DEMANDED JOEL A. BRIDWELL, DEFENDANT NOTICE TO: Alexander Spring Rehab You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Alexander Spring Rehab, certify to the best of my knowledge, Information and belief that ali documents or things required to be produced pursuant to the Subpoena Issued on have been produced. DATE: Records Custodian Nealon [:?Gover , 1411 Nllrth 1""11I Hlrrel IIAIIIIIHIIUIIO, I'A 17110 (717) m.9900 "AX, (717) 116.9119 jAMI!S 0, NI!AI.ON, III MAlTlIl!W R. GOV".R URIAN W, "l!IIRY Dh VIlJ j, "Rl!I!/) CIIRIHTOI'IIItRj. KNIGIIT October 5, 2000 Penns Wood Physical Therapy 425 Stonehedge Drive Carlisle, PA 17013 In Re: Glorglos SIIoupkldls Social Security #: 272-80-7664 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to In the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may In advance of the deposition date send us photocopies of the records, With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, Ibjb Enclosures ~~C~<- 0;~ Barbara Baker, Paralegal NEALON & GOVER DIMITRIOS SLIOUPKIDIS, GIORGIOS SLIOUPKIDIS, AND ASPASIA SLlOUPDIDIS, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO, 98-65 CIVIL ACTION. AT LAW JOEL A. BRIDWELL, DEFENDANT JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Penns Wood Physical Therapy Within twenty (20) days after service of this Subpoena, you are ordered by the Court tei produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9'" Floor, Harrisburg, PA 17101. You may deliver or mall 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 caples or producing the things sought. If you fall 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: Matthew R. Gover, Esquire 301 Market Street, 9th Floor HarrIsburg, PA 17101 717-232.9900 Attorney for Defendant BY THE COURT: DATED: ~71 .J~;;kx:lo Seal of the Court "'6 (!---h. ;) 'j) ~ 'PR THONOTARY ~~, ~llJf'<l J:XPLANATION OF REQUIReD RECORDS TO: Custodian of Records For; Penns Wood Physical Therapy ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present Glorglos SlIoupkldls 272-80-7664 2/24/27 >.-' DIMITRIOS SLIOUPKIDIS, GIORGIOS SLlOUPKIDIS, AND ASPASIA SLlOUPKIDIS, PLAINTIFFS V. JOEL A. BRIDWELL, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO, 98.85 : CIVIL ACTION. AT LAW , . : JURY TRIAL DEMANDED NOTICE TO: Penns Woods Physical Therapy You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Penns Wood Physical Therapy, certify to the best of my knowledge, Information and belief that all documents or things required to be produced pursuant to the Subpoena issued on DATE: .."'I....'...~"'A" have been produced. Records Custodian . ; ~ " ,', DIMITRIOS SLIOUPKIDIS, GIORGIOS SLIOUPKIDIS, AND ASPASIA SLIOUPDIDIS, PLAINTIFFS V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA , , : NO. 9B-65 : CIVIL ACTION. AT LAW JOEL A. BRIDWELL, DEFENDANT , . : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOI3 DISCOVERY PURSUANT TO RULE 4009.21 Defendant, Joel A. Bridwell, intends to serve 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 record and serve upon the undersigned an objection to the Subpoenas. If no objection is made the Subpoenas may be served. Date: 9/12/00 Matth w R. Gover, Esquire Attorney for the Defendant AND NOW, this 5111 day of October, 2000, I hereby certify that I have served the foregoing Certificate Prerequisite to Service of a Subpoena on the following by depositing a true and correct copy of same In the United States malls, postage prepaid, addressed to: Leslie M. Fields, Esquire 831 Market Street P,O. Box 222 Lemoyne, PA 17043 U~~.G~ Matthew R. Gover, Esquire 1'll,U:ClI'to: to'OIl LISTING CASto: to'Oll TIUAL (Mllftl hc tYflcwrlllclllllld ftllhmlllcd III (1IIpllclltc) TO 'I'm: 1'1l01'1I0NO'l'AllV/0J0' CUMIlJo:IlI,ANU COUNTY l'lcllftc list thc Iilllowlnll cnsc: (Check one) (x) for JURY trial allhc@term of civil court. ( ) fDr trial without ajury. CAPTION OF CASE (entire eaptiDn must be stated in full) (check one) D1MITRIOS SLIOUPKIDlS, GEORGIOS SLlOUPKIDlS, and ASPASIA SLlOUPKIDIS ( ) Assumpsit ( ) Trespass (x ) Trespass (Motor Vehicle) ( ) (other) (Plaintiffs) vs. JOEL A. BRIDWELL (Defendant) vs. Trials will commence: onJuly 9, 2001 beginning at 9:30 a,m. Pretrial conference will be held on June 20, 2001 beginning Ilt 9:30 a.m. No.: 98-65 Civil Term Indicate the attorney who will try case for the party who files the praecipe: David J. Fosler. Esoulre. 831 Market Street. Lemovne. PA 17043./717\761-2121 Indicnte trial counsel for other parties if known: Matthew R. Gover. Esouire. 2411 North Front Street. Harrishurl'. PA 17111./717\232-9900 This case is ready for trial. Signed: ~ Print Name: David J. Foster. Esouire .~> Date: 5/15/01 Attorney for: Plnintiffs 0 ,-, 0 c: " ~r " ,,~ .'. ,",i;J.:.! -:::. :1t;:(! rnrr' -: !:: z...., - ".1 -:;;-r" '::.: 1,:1 u]~: 0' ,") J.. CC ',~,,\l ::s -r..H 'i> . -, ~,.;- ...0 .-" ;":.{ , /- '") ~., r""j(n ~?::: .. :;...! -". ~ :;:J :0:1 ('0 -< DIMITRIOS SLlOUPKIDIS, GIORGIOS SLIOUPKIDIS, AND ASPASIA SLlOUPKIDIS, PLAINTIFFS V. JOEL A. BRIDWELL, DEFENDANT . .' : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA , , : NO, 98-65 , , : CIVIL ACTION. AT LAW , , : JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Joel A. Bridwell, In the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. B~ vv-- Chri opher J. Knight, Esquire I.D.#:80058 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this 2t' day of July, 2001, I hereby certify that I have served the foregoing Praecipe for entry of Appeerance on the following by depositing a true and correct copy of same in the United States mall, postage prepaid, addressed to: David J. Foster, Esquire Costopoulos Foster & Fields 831 Market Street PO Box 222 Lemoyne, Pa 17043 AI/orney for Plaintiffs ~/"'l~ Chri op' er J. Knight, Esquire '" ~ "".."",;,'" . . " > .~ , , , t r, ~ ,~~ n !Tt ;~: [; ~:,~. ..;{ "':'-'- ~ (-. , -'f- ~n (':-1 t'..., c '.,., . (;1 .,,;' -~. ::-') 1.::J ..:,; :~ 26. Dimitrios SliouJlkidis, Gcorgios SliouJlkidis IInd AsplIsill Slioupkidis : IN TIlE COURT or COMMON PLEAS or : CUMBERLAND COUNTY, PENNSYLVANIA v Jocl A. Bridwcll : NO. 98.65 CIVIL TERM ORDER OF COIJRT AND NOW, July 12,2001, upon rclation ofthc Court Administrator that this casc cannot be rcached this trial tenn duc to thc number of cases on thc lriallist, IT IS HEREBY ORDERED AND DIRECTED that this casc be continued until the SeptemberlO, 2001 trial tenn. The Prothonotary is directed to relist this case for the SeptmeberlO, 2001 trial tenn. Counsel is notified that they need not attend the Call of the List and no additional Pretrial Conference will be scheduled unless requested by either party. This case will be given preference and placed at the head of the list. By the Court David J. Foster, Esquire For the Plaintiff Matthew R. Gover, Esquire For the Defendant ~i.<"? VV\~'I\eA "1'\LP ,0\ :bb (') c. " S , ~:~ ""r1;.l .,- [i)C:: -. , ",__,I' --, c: L (/1 .~.J -~ , - ~-: L' ;,;. - ~~:~ , :;~ :~:: C'l :1) -<. oJ ..:. .'.:!Ul"'OCl-01 09: 04 P,O~ - 1'----... .......-...,.. ., ! NEAlON~l.)'! iGOVER,~.1 i An?~~~,~~_L..AW .. . 2.. 11 Nomfl'MUNT STRFf. r HARR1.~"URU, PA 17110 TFI F.I'"UN~ (717) 132.9900 t'ACSIMILE ('(I f) ~Jb-\lII\I MATIllF.W K. Govu nl".l\llvcr@ncalon-govcr.cxnn July 6. 200 I VIA "'ACSIMIL~ Thc Honorable: Georl.le E. Hoffcr, President Judl.lc CUMBERLAND (;(')lJNTY enl JRTH()l JSF One L'ourthOURC S'luare Carli&I~. PA 17013 ~'Ilullp"'''ls, /It ul. l'. Brld II Cumhcrhtnd County 98-65 Civil Term , e have rise:n severnl cont1iel~ in my sehe j"h wnlTantthc n!a.signment or the ahnve ml\ltc l\nulhl!r ]lIwyer in my 011- pp~nred on hehalf of the Dcl,mdunt at the Pre- 'frial Conference. ' Istophcr Knight to try this mutter in my uhsence. I huye discussed this lIlollel willi AlIuruey Fusler and he has no llbjectlon. Furlher. many ur the depusiliuns have heen complcted. Mr. Knight wnuld be fully familiar with Ihe file and be prepared to try Ihis casc. He hus tried many cases inthll pas!. l.neAt rllh~~ nlwiullsly tlktnle thAt the nllllmey assigned to thu ell.e appear otlhe Pre ,"('dnl Cllnft!renee. 1 am requesling penni.s;un for MI'. Knighlt~l try this mnller und would nppredute hcoring fmm th~ Court should there he UIlY issuc with respect to this j'ca~sigllll'O;:III. Vcry lIuly yours, N~f:-J & GOVER, p.e. .../(/V(~f-:J MAtthcw R. (1uver MR(;:nls cc: Riehanl J. Picrce (via lhcsilllih:) l)uvid J. Fusler. Esquirc (via facslmilc) , , - . \{' ,',{,.... '\ , \,IJ'i r/>: 1~!}.s~IN:!d .' ''''71nO ~! I :~~ ; 1 ! () I 'iili~ : ~ ) '. ..' il'r , ..:Juh,OO-01 09,1:>4 P.Ol 241 1 NOIth Front Sb'OCI HantobU'll, PA 17l 10 7171232.9900 11112>>8118 (fa.) MgovOfGI\uuluft Huvm,l"tm NEALON & GOVER, P.C_ Fax 'IDI ThA Hnnn~AhlA r,AnroA F Hoffer "rom. MllUnllW R. Gov.r F... 717/240-6462 p...... 2 "'-- 71?~2 11Io1... July 6, 2001 Hal S1loupkldls v. Br1dwell . c-nta: f'Iease see llle fOllOWing. \. .~ ~ GEORGIOS SLlOUPKIDIS Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . : NO. 98-65 CIVIL TERM V. . . : CIVIL ACTION - LAW JOEL A. BRIDWELL Defendant VERDICT SLIP 1. What amount do you award the Plaintiff, Georgios Slioupkidis for damages? $ I ~ S'tJtJ 1/11/0; (Date) . T:' " .- . ldr ~ Day -If,',,! CASE NO,: .:#3 ~lirl/~~lr\ h DOCKET NO,: qg'-ft-.!)' Q't.af VS DATE: Juror /I Nama Random No, -,-------*---------_.._- . ~&.I 118 r..u..h......, PI.IIII' A ]U!ffo0'71 r~ - O~ GUY. Willi.", T _IQ'~).2.15 116 Minnick, Sandra J -1857446194 109 Ginter, Robin J -1765469612 t>l 85 Qrn..... Allllttle -n397946112 " J>'L llJ thlRIY. I-aft h ---1635443944 " 106 Bailey, James L -1337220055 X 1>'1 188 RUI..n. ~.rl,.", -132404907S- , 'Pi II NlllnA. P8l1f ~ -113I1Ull!%- 111 108 Wetzler, Karen A -10697004ll1 \\ 114 Stank, Pew L .1044556999 12 93 Power, Suzanne T -766839029 I~ 117 Herold, Ted J -602014153 11 99 Hart, Lynnlece R -463417860 l~ 107 Mlchels-WlIS7II1er, Maureen -267865802 j(, 87 Meek, Calhy A -231657457 17 114 Snyder, Lisa J 83799968 1 X 91 McClure, Joyce J 460255445 1 'I i>3. 94 I.A"., "'NU", LYIIB 4845~~R'16- '1I'f\1.. 18S 1l.t'1I.....I......... J......- P Ir CACA'1"'12R - 21 98 Sullivan, Donald E 780862919 " 82 Carver, Kimberly F 914846931 , 102 Willis, Micbael M 942855306 21 92 Afarava, Roy G 1260368754 " 118 Cummins, Ricbard L 1584077228 ... ~IJ 97 Poston, James S 1645252254 ," 113 Steinkamp, Mary Betb 1786214523 ." 2:) 115 Gravley, Raymond G 2056167201 ~l) 103 Kintz, Jeffrey A 2086885443 ,;11 112 Santellses, Marla L 2112819362 ~~~::.o;,"',g~~(i\;~;(:~~;j~l~/IT~.~~;~;\:.;.:;.,:,%r,..gs!r~~?Titi:?Tt2.:~;~;I;/~E:.~~.;~~~:',:~~V:~I~~~~i~~;TIf~~:~"f~1~~:~ ~~.llI...~u.;L;;:u.\......\ I.~. ~".,,,,,, Uo...."., 1... .,....,."-"-.._..Il ....., ., .~....L_ _.....~. ",....h,___ ."_." ...___, .,~.t. ~iol"""'""~""""_,.~,<"",,,,, w....~~J \