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5, Pluintiff did not rcccive any unsw,"'rs/doeuments within thc 30-day period 01'
objections to discovery,
6, On June 24, 1998 und .July 15, 1998, I'luintifl's counscl wrote to Defendant's
counsel requesting production of the forcgoing discovery answcrs/documcnts,
7, On or about July 15. 1998, Plaintiffs eounscl rcceived Defendunt's answcrs to
Intcrrogatories but did not recei ve uny response to the Request i'i.lr Production of Documents,
8, The Defendunt admitted ncgligenec in his depositicn and the issues largely
involve the question of injuries/damages, On the issue of injuries/damages, Defendant is largely
relying on a medical report from Richurd A, Close, M,D" FACS duted February 22, 1998
following a record review,
9, The Defendant answered Interrogatories No, 31 through 33 as "undetermined" or
"unknown" even though these questions go directly to the basis of Dr. Close's opinion,
10, In addition, Deti:ndant answered Interrogatories No, 36 ami 38 as unknown or
undetermined even though the questions went directly to causation of the injuries and damuges,
11, As far as the answer to the Request fell' Production of Documents. Plaintiff's
counsel has forwarded to Defendant's counsel fivc more letters requesting that the answer with
the attached documents be immediately forwurdcd, In addition. the I'luintiff hus now reserved
the right to redepose the Defendant since Defendant's counsel did not fCJI'Ivard the answer to the
Request for Production of Documents before a schmluled deposition,
12, Defendant's counsel hus provided to Plaintiffs counsel some documents on
August 12, 1998. August 17, 1998 and August 24, 1998 but has not prepared a formalized
verified answer or provided the complete documents requested,
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f)OCIIfIWIlI N. l-IfJ690
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13. As a dircct and proximatc rcsult of the aforesaid collision, ncgligcncc,
carelessness and reckl(lssness of Defcndant, Plaintiff has and will suffer, a sevcre loss of earnings
and impairment of earning capacity which has exceeded, 01' may cxceed, the sum recovcrablc
undcr thc Pennsylvania Motor Vehicle Financial Responsibility Law, and will, or may, continu"
in the future,
14, As a direct and proximate result of the aforesaid collision, negligence,
carelessness and recklessness of Defendant, Plainti 1'1' has undergone, and in the future may
undergo, great mental and physical pain and suffering, mental unguish, emblllTassment and
humiliation, loss of life's pleasures, discomfort, inconvenicncc, distress and scvcre limitation in
his pursuit of daily activitics, all te his great loss and dctrimcnt.
15. As a direct and proximate result of the aforesaid collision, negligence,
carelessncss and recklessness of Defendant, Plaintiff has bccn disfigured and scarred, or may be
disfigured and scamd,
16, As a direct and proximate result of the aforesaid collision, negligence,
carelessness and recklessness of Defendant, Plaintifrs vehicle sustained $4,042.44 of property
damage,
.4.
{Jocllmelll /I: 131174
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THOMAS. THOMAS & HAFER, LLP
Jeffrey B, Rettig, E:squire
IDENTIFICATION NO,: 19616
305 North Front Street
P,O, Box 999
Harrisburg, PA 17108,0999
(117) 255-1839
Attorney for Delendont
RONALD ZEIGLER,
IN THE COURT OF COMMON PLEAS
OF
CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 1213 -1998
Plaintiff
v,
MATTHEW LE,
CIVIL ACTION - LAW
Defendant
JURY TRIAL DEMANDED
NOTICE TO PLEAD
TO: Plaintiff and Clark DeVere, Esquire, Plaintiff's attorney:
You are hereby notified to plead to the enclosed New Matter within twenty (20)
days from the date of service hereof 01' a default judgment may be entered against you,
Respectfully submitted,
THOMAS. THOMAS & HAFER. LLP
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By:. . f.'/L ~
"-~e I' B. 'Rettig, E. ui e
l ,#19616 .
, 5 North FrQnt Street
P,O, Box 999
Harrisburg, PA 17101-0999
(717) 255-7639
DATE: )/7/~'j
Attorneys for Defendant
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