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KENNY R. JOHNSON
V.
APR 2 7 199~
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, P A
CIVIL ACTION - LAW
NO. 98 - 1792 CML TERM
ROGER D, RUNNlNGER, in
his capacity as Administrator
of the ESTATE OF MICHAEL P.
RUNNlNGER, Deceased
JURY TRIAL DEMANDED
PLAINTIFF'S PR~TRIAL MEMORANDUM
1. A statement of the basic facts a~ to liab~
This case arises as a result of a motor vehicle accident which occurred on
August 31, 1996, at approximately 6:30 A.M. The plaintiff, Kenny R. Johnson, in
the course and scope of his employment with the Middlesex Township Police
Department, was in the process of writing a ticket to a Charles 1', Lafferty, Jr.
The plaintiff was sitting in his police car on the berm of Interstate 81 when he
was struck in the rear by 20-year-old Michael P. Runninger, who was legally
intoxicated at the time of the accident. Mr. Runninger had a BAC of 0,100. Mr,
Runninger died as a result of the injuries he sustained in the accident. Mr.
Runninger had an open container of vodka and orange juice located immediately
behind the driver's seat of his vehicle,
2. A statement of the basic facts of damage,
As a result of the accident, the plaintiff suffered injury to his back for
which he has continuously treated with 01'. Thomas A. Boeh, a chiropractor here
in Carlisle. At one point in time, he was referred by his family physician, Dr,
Diane Ceruzzi, to Dr. Stephen Powers, Hershey medical Center, for a
neurological evaluation.
On December 26, 1997, the plaintiff was again rearended by a vehicle
while sitting at a traffic light. This second accident aggravated his pre-existing
condition from the August 31,1996, accident.
The plaintiff was off work from August 31, 1996, to November 11, 1996,
He returned to work and continues to work. However, the police chief was kind
enough to modify his work duties so he did not have to spend a full day riding
in the car, but, instead, he comes in and spends several hours doing paperwork
in the office and other light-duty functions.
As far as physical activity, since the accident he has been extremely
limited due to chronic back problems. He is unable to play softball, go skiing,
can't go bowling, and lifting and working around the house has been hampered
to a great extent. He has difficulty lifting and carrying his children.
.
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ATTORNI!Y8 AND COUN9i!1.0A9 A'Y LAW
"0' PIN II 91f\IU!T
p,O, 00>< 932
HAAAISBUfIla, PINNSYLVANIA 11108.0937-
TIlLIIP~~ONtI (717) ',36-3200
COMMONWEALTH OF PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERl~D COUNTY
KENNY R. JOHNSON,
Plaintiff
No. 98-1792 Civil
v.
CIVIL ACTION - ~W
ROGER D. RUNNINGER,
in his capacity as
Administrator of the Estate
of Michael P. Runninger,
Deceased,
JURY TRIAL DEMANDED
Defendant
PRE-TRIAL CONFERENCE MEMORANDUM
OF DEFENDANT, ROGER D. RUNNINGER,
in his capacity as Administrator of the
Estate .QL Mi chael P. RunninQer. DeQeased
I. statement of-Facts as to Liability
This action ar ises out of a rear end motor vehicle
accident which occurred on August 31, 1996, on Interstate 81 south,
in Middlesex Township, cumberland county, pennsylvania.
. :t:I. ptatement of the Facts as to Dl\maqes
Plaintiff claims, as a result of th;,S rear end accident,
that he sustained the injuries set forth in his complaint.
III. ?tatement of, Issues
Defendant admits the negligence of the decedent, Michael
p, Runninger, and accordinglY, the issues are limited to
substantial factor and damages.
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IV. Summary of Legal Issues
There are no unusual legal issues regarding admissibility
of testimony, exhibits or other matters.
V. List of Wi tnesselii
Defendant may call one or more of the following:
A. . Plaintiff, as on cross examination;
B. Chief Barry L. Sherman, Middlesex
Township Police Department;
C, Diane M. Ceruzzi, D.O.; and
D. Stephen K. Powers, M.D.
Defendant further reserves the right to call any other
person(a) identified in Plaintiff's Pre-trial Memorandum or
witnesses necessary for the purposes rebuttal.
VI. List of Exhibits
Defendant may utilize one or more of the following:
A...._ Records of.:
1. Middlesex Township Police Department. ;
2. Erie Insurance Group;
3 . Selective Insurance Group;
4. Diane M. Ceruzzi, D.O. ;
5. Hershey Medical Center;
6. Cum~~rlQ~a County District Attorney's office;
7. Allstate Insurance Company;
- 2 -
truth of the averments oontained in this paragraph and, therefore,
they are denied.
4. Denied as stated.
Qount L_~U,g~
5. Denied. The allegations contained in this paragraph
state a legal conclusion to which no response is necessary.
6(a) - (d). Denied. The allegations contained in this
paragraph state a legal conclusion to which no response is
necessary.
7. Denied. The allegations contained in this paragraph
state a legal conclusion to which no response is necessary. By way
of further answer, with respeot to any allegation that Plaintiff
sustained personal injury as a result of the motor vehicle
accident, after reasonable investigation Defendant is without
knowledge or information suffioient to form a belief as to the
truth of said averments and, therefore, they are denied.
8. Denied. The answer contained in paragraph 7 hereof
is inoorporated herein by referenoe as if set forth .i.n its
entirety.
9. Denied. The answer contained in paragraph 7 hereof
is inoorporated herein by reference as if set forth in its
entirety.
- 2 -
10. Denied. The anywer oontained in paragraph 7 hereof
is inoorporated herein by referonoe as if set forth in its
entirety.
WHEREFORE, Defendant, Roger O. Runninger, in his capaoity
as Administrator of the Estate of Michael P. Runninger, Deceased,
demands judgment in his favor and against Plaintiff.
QQunt II - am.ill..'l.lL.D~
11. The answers contained in paragraphs 1 through 10
hereof are incorporated herein by reference as if SElt forth in
their entirety.
12. Denied. The allegations contained in this paragraph
state a legal conclusion to which no response is necessary.
13. Denied. The answer contained in paragraph 7 hereof
is incorporated herein by reference as if set forth in its
entirety.
WHEREFORE, Defendant, Roger D. Runninger, in his capaoity
as Administrator of the Estate of Michael P. Runninger, Deceased,
demands judgment in his favor and against Plaintiff.
NEW MATTER
14. The answers contained in paragraphs 1 through 13
hereof are incorporated herein by reference as if set forth in
their entirety.
- 3 -
KENNY R. JOHNSON
V.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
ROGER D, RUNNINGER, in
his capacity as Administrator
of the ESTATE OF MICHAEL P. :
RUNNINGER, Deceased
NO. 98 - 1792 CIVIL TERM
JURY TRIAL DEMANDED
.REPLY TO NEW MATTE~
14. The allegations of the original Complaint are incorporated
herein and reference is made thereto, as if set forth in their entirety.
15. Denied as a legal conclusion to which no response is necessary.
DOUGLAS, DOUGLAS & DOUGLAS
June 30, 1998
\.
By ~L ~,~~
William P. Douglas, Esquire
Atty. I.D. # 37926
27 West High Street
P.O. Box 261
Carlisle, PA 17013
717-243-1790
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COMMONWEALTH OF PENNSYLVANIA
IN THE COURT OF' COMMON PLEAS OF CUMBERLAND COUNTY
KENNY R. JOHNSON,
Plaintiff
No. 98-1792 Civil
v.
ROGER D. RUNNINGER,
in his capacity as
Administrator of the Estate
of Miohael P. Runninger,
Deoeased,
CIVIL ACTION - LAW
Defendant
JURY "1'RIAL DEMANDED
SUBPOENA ~O PRODUCE DOCUMENTS OR THIUGS.
TO: Records Custodian for Spring Road Family Praotice
Within twenty (20) days after service of this subpoena,
you are ordered by the court to p:r.oduce at the offices of ReynOlds
& Havas, A Professional Corporation, 101 Pine Street, Harrisburg,
Pennsylvania 17101 the fOlloWing documents or things relating to
K~nny ~ay JOhns~n (~~~te~7~~OI:t{ ~~~~~~/~:~~~~~ rneo~o;~:~5~~:::;~
~-~;~~ ~~d~~;' ~;~;; diaan~;tj~ fj~i~s. ;~~~~~~a~~~. results of
l1i..A.gnostic studies. correapondence. a~d all else relating to
Mr. Johnaon.
You may deliver or mail legible oopies of the doouments
or produoe 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 advanoe 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:
Stephen L. Banko, Jr., I.D. No. 41727
Reynolds & Havas
Post Office Box 932
Harrisburg, Pennsylvania 17108-0932
(717) 236-3200
Attorney for Defendant, Roger D. Runninger, in his capacity
as Administrator of the Estate of Michael P. kunninger, Deceased
BY THE COURT:
Date:
(Seal of the Court)
4041-1
(Prothonotary)
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COMMONWEAL'J'H OF' PENNS\'LVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERI,AND COUNTY
KENNY R. JOHNSON,
Plaintiff
No. 98-1792 civil
v,
ROGER D. RUNNINGER,
in his capacity as
Administrator of the Estate
of Michael P. Runninger,
Deceased /
CIVIL ACTION - LAW
Defendant
JURY TRIAL DEMANDED
CERTIFICATE PREREQUISITE 'J'O SERVICE
Qf. A SUaP~ PURSUANT TO RULE~09.22
As a prerequisite to service of subpoenas for documents
and things pursuant to Rule 4009.22, Defendant, Roger D. Runninger,
in his capacity as Administrator of the Estate of Michael P.
Runninger, Deceased, certifies that
(1) a Notice of Intent to serve subpoenas with
copies of the subpoenas attached thereto was mailed or
delivered to each party at least twenty (20) days prior
to the date on which the subpoenas are sought to be
served;
(2) a copy of the Notice of Intent, including the
proposed subpoenas, is attached to this certificate;
(3) no objection to the subpoenas has been
rece i ved; and
(4 ) the subpoenas which will be served are
identical to the subpoenas which are attaohed to the
Notice of Intent to serve the subpoenas.
"
REYNOLDS & HAVAS
A Professional Corporation
Date: 7~J.- 3 ~0
By: ,J .
t n ~. Banko, Jr,
Attorney I.D. #41727
101 Pine Street
HarriSburg, PA 17108-0932
(717) 236-3200
Counsel for Defendant,
Roger D. Runninger, in his capacity
as Administrator of the Estate of
Michael P. Runninger, Deceased
COMMONWEALTH OF PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
KENNY R. JOHNSON,
Plaintiff
No. 98-1792 civil
v.
ROGER D. nUNNINGER,
in his capacity as
Administrator of the Estate
of Michael P. Runninger,
Deceased,
CIVIL ACTION - LAW
Defendant
JURY TRIAL DEMANDED
SUBPOENA TO PRQUUCE DOCUMENTS OR THINGS
TO: Records Custodian for Middlesex Township Police Department
Within twenty (20) days after service of this subpoena,
you are ordered by the court to produoe at the off ices of Reynolds
& Havas, A Professional Corporation, 101 Pine street, Harrisburg,
Pennsylvania 17101 the following documents or things relating to
Kenny Ray Johnson (SS NO'L-.1~9-5a-6965) all Dersonnel reoords
includinli/ applications. attenda~c; r,:!cOrds (sick leave/vacation,
etc.). e~ployee evaluations. phv~!gal examinations, workers
oompensation claims. disciplinary r~cordsr oorrespondence. and all
else relating to Mr. Johnson's employment.
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 tbings required
by this subpoena within twenty (20) days after its ser.vice, the
party serving this subpoena may seek a court order compelling you
to comply with it.
This subpoena was issued at the request of:
Stephen L. Banko, Jr.
Attorney 1.0. No. 41727
Reynolds & Havas
Post Office Box 932
HarriSburg, Pennsylvania 17108-0932
(717) 236-3200
Attorney for D~fendant, the Estate of Michael P. Runninger
BY THE COURT:
Date:
(Seal of the Court)
4041-1
(Pr.othonotary)
COMMONWEALTH OF PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERtAND COUNTY
KENNY R. JOHNSON,
PlaJ.ntiff
No. 98-1792 civil
v.
ROGER D. RUNNINGER,
in his capacity as
Administrator of the Estate
of Michael P. Runninger,
Deceased,
CIVIL ACTION - LAW
Defendant
JURY TRIAL DEMANDED
SUBPOENA TO PROQUCE DOCUMENTS OR THINGS
TO: Reoords custodian for Cumberland County District Attorney
Within twenty (20) day~ after service of this subpoena,
you are ord~red by the court to produce at the offices of Reynolds
& Havas, A Professional corporation, 101 Pine Street, Harrisburg,
Pennsylvania 17101 the fOllowing documents or things relating to
Kenny Rav Johnson (55 No. 359-58-6965) all personnel records
including applications. attendance records (sick leave/vacation.
etc.), employee evaluations. disciplinary records. olaims for
worker fl. compensation. oorrespondence. and all else relating to
Mr. Johnson' s employment as...an.. incoII\i ng prisoner processor.
You may deliver or mail legible copies of the documents
or produce things requested by this subpoena, together with the
certificate of oomp1iance, 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:
stephen L. Banko, Jr.
Attorney I.D. No. 41727
Reynolds & Havas
Post Office Box 932
Harrisburg, Pennsylvania 17108-0932
(717) 236-3200
Attorney for Defendant, the Estate of Michael P. Runninger
BY THE COURT:
Date:
(Seal of the Court)
4041-1
(Prothonotary)
COMMONWEALTH OF PENNSYLVANIA
IN THE COUR'r OF COMMON PLEAS OF CUMBERLAND COUNTY
KENNY R. JOHNSON,
Plaintlff
No. 98'-1792 civil
v.
ROGER D. RUNNINGER,
in his capacity as
Administrator of the Estate
of Michael P. Runninger,
Deceased,
CIVIL ACTION - LAW
Defendant
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
TO: Records Custodian for Allstate Insurance Company
within twenty (20) days after service of this subpoena,
you are ordered by the court to produce at the offices of Reynolds
& Havas, A Professional Corporation, 101 Pine street, Harrisburg,
Pennsylvania 17101 the following documents or things relating to
the third Darty claim arisinQ out of a motor vehicle accident which
oQcurred on 12/26/97 involving your insured, SA~~Fannestock
(Claim No. 155297777703' and claimant Kenny Ray Johnson. inClUding
but not limited to all claim activity 10Qs. proQress rElport.L,.
payout sheets. accident reports. photoqraphB. correspondenoe.-AnQ
All-else relating to Mr. Johnson's claim.
You may deliver or mail legi.ble 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 advancQ the
reasonable cost of preparing the oopies 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:
Stephen L. Banko, Jr.
Attorney 1.0. No. 41727
ReynoldS & HaVaS
Post Office Box 932
Harrisburg, Pennsylvania 17108-0932
(717) 236-3200
Attorney for Defendant, the Estate of Michael P. Runninger
BY THE COURT:
Date:
(Seal of the Court)
4041-1
(Prothonotary)
COMMONWEA,LTH OF PENNSYLVANIA
IN THE COURT 0.' COMMON PLEAS OF CUMBERLAND COUNTY
RENNY R. JOHNSON,
Plaintiff
No. 98-1792 Civil
v.
ROGER D. RUNNINGER,
in his capaoity as
Administrator of the Estate
of Michael P. Runninger,
Deoeased,
CIVIL ACTION - LAW
Defendant
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THINQS
TO: Records Custodian for Erie Insurance Group
Within twenty (20) days after service of this subpoena,
you are ordered by the court to produce at the offices of Reynolds
lie Havas, A professional Corporation, 101 Pine Street, Harrisburg,
Pennsylvania 17101 the following doouments or th!ngs relating to
the first partv claim of Kenny Ray Johnson (Claim No. 010170342201,
QQ~: 12/26/97\ including but not limited to claim activity logs.
proQress re\)orts. pavout sheets. accident reports. Dhotographs.
correspondence. and all else relating to Mr. Johnson's claimL----
You may deliver or mail legible oopies of the dccuments
or produoe things requested by this subpoena, together with the
oertificate of compliance, to the party making this request at the
address listed above. You have the right to seek in advance the
reasonable oost of preparing the oopies or producing the things
sought.
If you fail to produce the doouments 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 oomply with it.
This subpoena was issued at the request of:
Stephen L. Banko, Jr.
Attorney 1.0. No. 41727
Reynolds lie Havas
101 Pine Street
Post Office Box 932
Harrisburg, Pennsylvania 17108-0932
(717) 236-3200
Attorney for Defendant, the Estate of Miohael P. Runninger
BY THE COURT:
Date:
(Ssal of the Court)
4041-1
(Prothonotary)
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COMMONWEALTH OF PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
KENNY R. JOHNSON,
Plaintiff
v.
ROGER D. RUNNINGER,
in his capacity as
Administ.rator of the Estate
of MiChael P. Runninger,
Deceased,
No. 98-1792 Civil
CIVIL ACTION - LAW
Defendant
JURY TRIAL DEMANDED
SUBPOENA TO PRODUCE DOCUMENTS OR THIHQS
TOI Records Custodian for Penn National Insurance Group
Wi,thin twenty (20) days after service of this subpoena,
you are ordered by t.he court to produce at the offices of ReynoldS
& Havas, A Professional Corporation, 101 Pine Street, HarriSburg,
Pennsylvania 171.01 the following documents or things relating to
the fh'st \)arty claim of Kennv Rav ~oh"-Aon (Claim !'io. 02456563:
DOL: 12/26/97) inclUding but not ~im1!~!Q Qlaim activity logs.
~r09ress reports. Dayout sheets. accide"-~ report~, photographs,
correspondence. and 011 else relatina to Mr. ~QhQ~Qn'~ Q!~!m~
You may deliver or mail legible copies of the documents
or produce things requested by this subpoena, together with the
certificate of compliance, to the party malting this request at the
address listed above. You have the right to seek in advance the
reasonable cost of preparing the copies or producing the things
sought.
If you fail to produce the documents or things required
by this subpoena within twenty (20) days after its service, the
party serving this subpoena may seek a court order compelling you
to comply with it.
This SUbpoena was issued at the request of:
Stephen L. Banko, Jr.
Attorney 1.0. No. 41727
ReynoldS & Havas
101 Pine street
Post Office Box 932
HarriSburg, Pennsylvania 17108-0932
(717) 236-3200
Attorney for Defondant, the Estate of Michael P. RUnninger
BY THE COURT:
Datel
(Seal of the Court)
4041-1
(Prothonotary)
, CERTIFrCA~'F. OF SE~VICE
I hereby certify that I have served a true and correct
copy of the foregoing document on all oounsel of record by placing
the same in the United states Mail
at Harrisburg, Pennsylvania,
'J' ,,to
..l:.-.:... ~'day of February, 1999,
first-Class pustage prepaid, on the
addressed as follows:
William P. Douglas, Esquire
Douglas, Douglas & Douglas
27 West High Street
Post Offioe Boy. 261
Carlisle, Pennsylvania 17013-0261
(Counsel for Plaintiff)
REYNOLDS & HAVAS
A Professional Corporation
By:
/' /7 t.
(i;,1 If ./"-(:;':f.
',J-.-rj',t'.. ..'~l'-.......- t.lf((( ~c/,
~haron Dell-Gallaghe ,
Secretary
CERTIFICATE OF SERVIC~
I hereby certify that I have served a true and correct
copy of the foregoing document on all counsel of record by placing
the same in the United States Mail at Harrisburg, Pennsylvania,
first-class postage prepaid, on the ,.~:1i!<(.day of February, 1999,
addressed as follows:
William P. Douglas, Esquire
Douglas, Douglas ~ Douglas
27 West High street
Post office Box 261
carlisle, Pennsylvania 17013-0261
(Counsel for Plaintiff)
REYNOLDS & HAVAS
A Professional Corporation
By:
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