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HomeMy WebLinkAbout07-1344SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff ASHLEY E. MCKEE, Plaintiff V. STACEY POWELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. (37 - J? q{ (S U lltc--?J-9 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 entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 1-800-990-9108 -1- Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 Tel. (717) 728-3200; Fax (717) 728-3400 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff ASHLEY E. MCKEE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. STACEY POWELL, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomaro medidas y puede entrar una orden contra usted sin previo aviso o notoficacaion y por cualquier queja o alivio que es pedido en la peticion do demanda. usted puede perder dinero o sus propiededas o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O Si NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 1-800-990-9108 -2- Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 Tel. (717) 728-3200; Fax (717) 728-3400 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ASHLEY E. MCKEE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07, 12gq 6.c L? STACEY POWELL, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, ASHLEY E. MCKEE, by and through her attorneys, SHOLLENBERGER & JANUZZI, LLP, and respectfully represents the following: FACTS APPLICABLE TO ALL COUNTS 1. Plaintiff, ASHLEY E. MCKEE, is an adult individual who currently resides at 1200 N. Middletown Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant, STACEY POWELL, is an adult individual whose last known address is 395 Peach Glen Idaville Road, Gardners, Adams County, Pennsylvania. 3. The facts and circumstances hereinafter set forth took place on April 25, 2006, at approximately 3:14 p.m. on Georgetown Road, Dickinson Township, Cumberland County, Pennsylvania. -3- Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 Tel. (717) 728-3200; Fax (717) 728-3400 4. At the aforesaid time and place, Plaintiff, ASHLEY E. MCKEE, was the operator of a 2005 Chevrolet Cavalier bearing Pennsylvania Registration Number FRM8666. 5. At the aforesaid time and place, Defendant, STACEY POWELL was the operator of a Blue Ford Ranger pick up truck. 6. At the aforesaid time and place, Plaintiff, ASHLEY MCKEE was operating the Cavalier in the northbound lane of Georgetown Road. 7. At the aforesaid time and place, Defendant, STACEY POWELL was operating the Blue Ford Ranger pick up truck in the southbound lane of Georgetown Road. 8. The Defendant was operating the Ranger pick up truck at a high rate of speed and in excess of the posted speed limit of 35 miles per hour. 9. The Ranger pick up truck crossed the center line of Georgetown Road into the northbound lane of travel whereupon the Plaintiff was forced to move the Cavalier onto the berm/ditch running along the east berm. The Cavalier then struck a drain pipe, rolled over and landed in the private driveway of a property on the east side of Georgetown Road. 10. As a result of the aforesaid collision, Plaintiff, ASHLEY E. MCKEE, has suffered serious and permanent injuries, including but not limited to the following: a) Severe degloving injury to the left upper extremity; b) Open left ulnar shaft fracture with significant tissue loss and degloving; -4- Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 Tel. (717) 728-3200; Fax (717) 728-3400 c) Severe shock to nerves and nervous system; and d) Anguish. 11. The aforesaid collision was the direct and proximate result of the negligence of Defendant, STACEY POWELL, in operating the Blue Ford Ranger pick up in a careless, reckless, and negligent manner as follows: a) In operating his vehicle at an excessive rate of speed under the circumstances; b) In failing to have his vehicle under proper and adequate control; c) In failing to yield the right-of-way to on-coming traffic; d) In failing to yield half of the highway to on-coming traffic; e) In failing to keep the vehicle within the proper lane; f) Failing to give at least one half of the main-traveled portion of the roadway to another vehicle being occupied/operated by the Plaintiff in violation of §3302 of The PA Motor Vehicle Code; and g) Failing to drive his vehicle as nearly as practicable entirely within a single lane on a roadway which had been divided in two or more clearly marked lanes for traffic and moving from the lane before he had first ascertained the movement could be made with safety in violation of §3309(1) of The PA Motor Vehicle Code. 12. As a direct and proximate result of the aforesaid injuries, Plaintiff, ASHLEY E. MCKEE, has undergone and in the future will undergo great pain and suffering for which damages are claimed. 13. As a further result of the aforesaid injuries, Plaintiff, ASHLEY E. MCKEE has suffered and may continue to suffer a loss of earnings for -5- Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 Tel. (717) 728-3200; Fax (717) 728-3400 which damages are claimed. 14. As a further result of the aforesaid injuries, Plaintiff, ASHLEY E. MCKEE, has and/or may in the future incur a loss of earning capacity for which damages are claimed. 15. As a further result of the aforesaid injuries, Plaintiff, ASHLEY E. MCKEE, has sustained scarring and disfigurement for which damages are claimed. 16. As a further result of the aforesaid injuries, Plaintiff, ASHLEY E. MCKEE, has sustained a permanent diminution in her ability to enjoy life and life's pleasures for which damages are claimed. 17. As a further result of this collision, Plaintiff, ASHLEY E. MCKEE, has and/or may incur reasonable and necessary medical and rehabilitative costs and expenses in excess of the amounts paid or payable pursuant to Subchapter B of the Pennsylvania Motor Vehicle Financial Responsibility Law, Workers' Compensation or any program, group contact, or other arrangement for payment of benefits as defined in 75 Pa. C.S.A. Section 1719. 18. As a further result of the aforesaid injuries, Plaintiff, Ashley E. MCKEE, has incurred or may hereinafter incur financial expenses and losses which exceed sums recoverable under the limitations and exclusions of the Pennsylvania Motor Vehicle Financial Responsibility Law for which damages are claimed. 19. Plaintiff, ASHLEY E. MCKEE, sustained a serious injury in this collision which has caused her a serious impairment of body function. Therefore, -s- Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 Tel. (717) 728-3200; Fax (717) 728-3400 Plaintiff, ASHLEY E. MCKEE, remains eligible to claim compensation for non economic loss and economic loss sustained in this collision pursuant to applicable tort law. 20. Plaintiff, ASHLEY E. MCKEE, sustained a serious injury in this collision which has caused her permanent serious disfigurement. Therefore, Plaintiff, ASHLEY E. MCKEE, remains eligible to claim compensation for non economic loss and economic loss sustained in this collision pursuant to applicable tort law. WHEREFORE, Plaintiff, ASHLEY E. MCKEE, demands judgment against Defendant, STACEY POWELL, for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP AttornV;4l ai ntiff Dated: 3.7-07 By &&Kl? imoth A. Shollenberger, Esq. Attorney I.D. #34343 2225 Millennium Way Enola, PA 17025 (717) 728-3200 (717) 728-3400 (fax) GATIM CASE FILES- OPEN\McKee, Ashley\Pleadings\030607 Complaint Uc].doc -7- Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 Tel. (717) 728-3200; Fax (717) 728-3400 1r? VERIFICATION 1,?1 hereby acknowledge that I am a Plaintiff in this action and that I have read the C(pYY1?IcLi V)?- and that the facts stated herein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. '441 E_ `Plc LDate: ?? (? G \GI.OEAL\WPDATAIDOCS111VITIAL CONSULT DOGS (SET-UPS)Wenficafion Wpd SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way. Enola. PA 17025 (717) 725 3200 • FAX (717) 726 3200 PQ , r °n 14 Vol J ww THOMAS, THOMAS & HAFER, LLP by: Brooks R. Foland, Esquire I.D. No. 70102 305 North Front Street 6m Floor POB 999 Harrisburg, PA 17108-0999 (717) 255-7626 ASHLEY E. MCKEE, Plaintiff vs. STACEY POWELL, Defendant Attorneys for Stacey Powell IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: matter. Please enter our appearance on behalf of Defendant Stacey Powell in the above Respectfully submitted, THOMAS, THOMAS & HAFER, LLP by: Brooks R. Folan , Es uire I.D. No. 70102 305 North Front Street, 6th Floor POB 999 Harrisburg, PA 17108-0999 (717) 255-7626 491505.1 ". • . 1 CERTIFICATE OF SERVICE 7// AND NOW, this ? day of , 20071, Coleen M. Polek, of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Timothy A. Shollenberger, Esq. Shollenberger & Januzzi, LLP 225 Millennium Way Enola, PA 17025 Coleen M. Polek ('1 ?? i? C,. ? -ri ??, -?' ?'' t.7 -AiC+ "" t{_} ' E _ "C? t. .? _ .? ...... ASHLEY E. MCKEE, Plaintiff vs. STACEY POWELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD You are hereby notified to plead to the enclosed Answer with New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. DEFENDANT'S ANSWER WITH NEW MATTER AND NOW, comes Defendant Stacey Powell, by and through his attorneys, Thomas, Thomas & Hafer, LLP, and files the following Answer with New Matter: 1. Denied. Defendant is without information or belief as to the truth of the averments of paragraph 1 of Plaintiffs Complaint and the same are therefore denied and proof thereof is demanded at time of trial. 2. Admitted. 3. Denied. Defendant is without information or belief as to the truth of the averments of paragraph 3 of Plaintiffs Complaint and the same are therefore denied and proof thereof is demanded at time of trial. 4. Denied. Defendant is without information or belief as to the truth of the averments of paragraph 4 of Plaintiffs Complaint and the same are therefore denied and proof thereof is demanded at time of trial. 5. Denied as stated. It is admitted only that Defendant Stacey Powell was operating a Ford Ranger pickup truck some minutes prior to Plaintiffs accident. 6. Denied. Defendant is without information or belief as to the truth of the averments of paragraph 6 of Plaintiffs Complaint and the same are therefore denied and proof thereof is demanded at time of trial. 7. Denied as stated. It is admitted only that Defendant Stacey Powell operated the Ford Ranger pickup truck in the southbound lane of Georgetown Road on the date of Plaintiff's alleged accident. Any and all other allegations contained in paragraph 7 are specifically denied and strict proof thereof is demanded at time of trial. 8. Denied. It is specifically denied that Defendant Stacey Powell was operating the Ranger pickup truck at a high rate of speed or in excess of the posted speed limit of 35 mph. 9. Denied. It is specifically denied that at any time material hereto that the Ford Ranger pickup truck crossed the center line of Georgetown Road and into the northbound lane of travel causing Plaintiff to move her vehicle onto the east berm of the road. Any and all other allegations contained in paragraph 9 are specifically denied and strict proof thereof is demanded at time of trial. 10. (a-d) Denied. Defendant is without information or belief as to the truth of the averments of paragraphs 10 (a-d) of Plaintiffs Complaint and the same are therefore denied and proof thereof is demanded at time of trial. 11. (a-g) Denied. The allegations contained in paragraphs 11 (a-g) are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 2 12. Denied. The allegations contained in paragraph 12 are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 13. Denied. The allegations contained in paragraph 13 are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 14. Denied. The allegations contained in paragraph 14 are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 15. Denied. The allegations contained in paragraph 15 are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 16. Denied. The allegations contained in paragraph 16 are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 17. Denied. The allegations contained in paragraph 17 are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 18. Denied. The allegations contained in paragraph 18 are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 3 19. Denied. The allegations contained in paragraph 19 are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 20. Denied. The allegations contained in paragraph 20 are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendant Stacey Powell respectfully requests that judgment be entered against his favor and against Plaintiff Ashley E. McKee. NEW MATTER 21. Some or all of Plaintiffs claims may be barred by Plaintiff's comparative and/or contributory negligence. 22. Plaintiffs claims may be barred by the expiration of the applicable statute of limitations. Plaintiffs claims may be barred or reduced by the applicable provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 23. Some or all of Plaintiffs injuries and/or damages, if any, may have been caused by parties other than Defendant. Respectfully submitted, THOMAS, TAWAS & HAFER, LLP by: -- 11-2-14-k 2C?-- Br6oks R. Foland, Esquire I.D. No. 70102 305 North Front Street, 6th Floor POB 999 Harrisburg, PA 17108-0999 (717) 255-7626 Attorneys for Defendant Stacey Powell 4 VERIFICATION I, Stacey Powell, have read the foregoing Answer with New Matter and hereby affirm that it is true and correct to the best of my personal knowledge, information and belief. This Verification and statement is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities; I verify that all the statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa.C.S. § 4904. ? tol'-Y Stacey Powell CERTIFICATE OF SERVICE ft, AND NOW, this -! day of '2o01, Coleen M. Polek, 7 U of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Timothy A. Shollenberger, Esq. Shollenberger & Januzzi, LLP 225 Millennium Way Enola, PA 17025 Coleen M. Polek av c°a C> ['? ? ?? -_-. ,r.? ?y?? y...lr 1-1? ..._ ?a w ? - _ ?.. - v? T i _ __ _ ? Iii ,Ir._ .& SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ASHLEY MCKEE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. STACEY POWELL, Defendant NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO NEW MATTER OF DEFENDANT STACEY POWELL AND NOW COMES THE PLAINTIFF, ASHLEY MCKEE, by and through her attorney, SHOLLENBERGER AND JANUZZI, LLP, files this Reply to New Matter of DEFENDANT, STACEY POWELL, and, in support thereof, respectfully represents the following: 21. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required, same is denied pursuant to Pa. R.C.P. 1029(e). 22. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required, same is denied pursuant to Pa. R.C.P. 1029(e). 23. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required, same is denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, the Plaintiff respectfully requests that the Defendant's New Matter be dismissed and judgment entered in favor of the Plaintiff as a matter of law. Respectfully submitted, BROLLNB?,U Zl, LLP Attorneys f i By: I.cf. E SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff ASHLEY MCKEE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. STACEY POWELL, Defendant NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, this 25th day of April 2007, 1 hereby certify that a true and correct copy of the foregoing Reply to New Matter has been served upon the following, Attorney for Defendant, via U.S. Mail: Brooks R. Foland Thomas Thomas & Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 SHOLLENBE By: A. & N We ber, r, , LLP u Y_ Fn w 0 THOMAS, THOMAS & HAFER, LLP by: Brooks R. Foland, Esquire I.D. No. 70102 305 North Front Street 6th Floor POB 999 Harrisburg, PA 17108-0999 (717) 255-7626 ASHLEY E. MCKEE, Plaintiff vs. STACEY POWELL, Defendant Attorneys for Stacey Powell IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant 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 in advance of this Certificate; 2. No objection to the subpoenas have been made; and 3. The subpoenas which will be served are identical to the subpoenas which are attached to this Notice. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP Date: ?'/np By: T-4 k BROM9-R. FOLAND, ESQUIRE 305 N. Front Street, P.O. Box 999 Harrisburg, PA 17108 (717) 237-7141 Attorney for Defendant THOMAS, THOMAS & HAFER, LLP by: Brooks R. Foland, Esquire I.D. No. 70102 305 North Front Street, P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7626 ASHLEY E. MCKEE, Plaintiff vs. STACEY POWELL, Defendant Attorneys for Stacey Powell IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Douglas Moyer, C/O 911 Communications, One Courthouse Square, Carlisle, PA 17013 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of the CAD report for a date of loss of April 25, 2006 on Georgetown Road, involving Stacey Powell and Ashley McKee. at: Thomas. Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburv. PA 17108- 0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If* you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7626 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE: Seal of tl e Court BY THE COURT: (/ 1 /111.4 -k ?- - '-d Prot ionotary/-( rk, C' iI Division Deputy THOMAS, THOMAS & HAFER, LLP by: Brooks R. Foland, Esquire I.D. No. 70102 305 North Front Street, P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7626 ASHLEY E. MCKEE, Plaintiff vs. STACEY POWELL, Defendant Attorneys for Stacey Powell IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Yellow Breeches EMS, Inc., 233 Mill Street, Mt. Holly Springs, PA 17065 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of the EMS report, accident report correspondence notes statements documents etc regarding Ashley McKee for a date of loss of April 25, 2006. at: Thomas. Thomas & Hafer, LLP, 305 N. Front St., P.O._Box_999. Harrisburg. PA 17108- 0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7626 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant BY THE ,?OURT: DATE: Seal of the Court Prothonot4ry?C e , Civ Division Deputy CERTIFICATE OF SERVICE AND NOW, this day of May, 2007, I, Kate A. Wilhelm, a Paralegal in the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, first class, postage prepaid, to the following: Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, LLP 225 Millennium Way Enola, PA 17025 Kate A. Wilhelm, Paralegal 503541.1 {'? r'i ? ?<J ._"? S'?.3 ?..? f i t._'. , hJ ;r. _'. P -:.?: ' ? `a . J _ •-G SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ASHLEY E. MCKEE, Plaintiffs V. STACEY POWELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL ACTION - LAW JURY TRIAL CERTIFICATE OF SERVICE And now, this 17th day of May, 2007, 1 hereby certify that a copy of the foregoing Supplemental Interrogatory Propounded by Plaintiff to be Answered by Defendant has been served upon the following, via U.S. Certified Restricted Delivery Mail: Brooks R. Foland, Esquire Thomas, Thomas, & Hafer LLP P.O. Box 999 Harrisburg, PA 17108 B) 5 SHOLLENBERGER & JANUZZI, LLP 2225 MILLENNIUM WAY ! ENOLA, PA 17025 (717) 728-3200 ! FAX(717)728-3400 SHOLLENBERGER & JANUZZI, LLP t? - c>> _._a 'i i ..-1 .Mr r..? L; ?: '"i ? ? -? f 4..-> SHERIFF'S RETURN - OUT OF COUNTY .w 'CASE NO: 2007-01344 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCKEE ASHLEY E VS POWELL STACEY R. Thomas Kline sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: POWELL STACEY but was unable to locate Her deputized the sheriff of ADAMS in his bailiwick. He therefore serve the within COMPLT, INTERR, REQ PROD County, Pennsylvania, to On March 22nd , 2007 , this office was in receipt of the attached return from ADAMS Sheriff's Costs: So answer ?,-- Docketing 18.00 Out of County 9.00 Surcharge 10.00 Thomas Kline Dep Adams County 28.00 Sheriff of Cumberland County Postage 3.45 6 8. 4 5 ? 3#410? 03/22/2007 SHOLLENBERGER & JANUZZI Sworn and subscribe to before me this day of A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania Ashley E. McKee vs. Stacey Powell No. 07-1344 civil Now, March 14, 2007 ,1, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Adams County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, March 19 , 20 07 , at 4:55 o'clock P- M. served the within Complaint in Civil Action upon Stacey Powell at 395 Peacb Glen Idaville Rd., Gardners, PA by handing to Stacey Powell a true & attested copy of the original Complaint and made known to Stacey Powell the contents thereof. Sworn and subscribed before me this day of N/A , 20 So answers, Z L-4 ?' I;t 7c D ut e i-eff Jason Kirkner AA W - 'ff of Adams County, PA COSTS SERVICE $ 1.00 MILEAGE 10.00 AFFIDAVIT $ 28.00 &]. 3/21/07 ?Anoo swvov JAI83HS 10 :11 V 91 UVW Lol a3AI303H SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ASHLEY E. MCKEE, Plaintiffs V. STACEY POWELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL PLAINTIFF'S ANSWERS TO DEFENDANT'S INTERROGATORIES Attached, please find Plaintiffs Answers to Defendant's Interrogatories, in the above-captioned action. Plaintiff, Ashley E. McKee, reserves the right to supplement these Answers. Respectfully submitted, SHOLLENBERGEF31& *NU,7F_l, By: ?ShditenbA .D. # 34343 Date: June 20, 2007 State: (a) Your full name; (b) The address of your present residence and the address of each other residence which you have had during the past five years; (c) Date of birth; (d) Social Security Number; and (e) The schools you have attended and the degrees or certificates awarded, if any. ANSWER: (a) Ashley E. McKee (b) 1200 North Middleton Road Carlisle, PA 17013-8766 (1 year to present) 424 South Baltimore Avenue Mt. Holly Springs, PA 17065 (for 18 years) (c) June 25, 1987 (d) 168-76-3679 (e) Carlisle High School, June 2005 Graduate 2. List and describe all expenses and losses that you have incurred because of the incident. ANSWER: See Medical Bills attached to Plaintiff's Answers to Defendant's Request for Production of Documents as Exhibit G. 3. If you know of anyone that has given any statement (as defined by the Rules of Civil Procedure) concerning this action or its subject matter, state: (a) The identity of such person; (b) When, where, by whom, and to whom each statement was made, and whether it was reduced to writing or otherwise recorded; (c) The identity of any person who has custody of any such statement that was reduced to writing or otherwise recorded; and (d) Attach a copy of each such report, statement, memorandum or testimony to your answers to these interrogatories. ANSWER: See statements attached to Plaintiffs Answers to Defendant's Request for Production of Documents as Exhibits B, C. and D. 4. If you know of the existence of any photographs, motion pictures, video recordings, maps, diagrams, or models relevant to the incident, state: (a) The nature or type of such item; (b) The date when such item was made; (c) The identity of the person that prepared or made each item; and (d) The subject that each item represents or portrays. ANSWER: See photographs attached to Plaintiffs Answers to Defendant's Request for Production of Documents as Exhibit A. 5. If you, or someone not an expert subject to Pa.R.C.P. No. 4003.5, conducted any investigations of the incident, identify: (a) Each person, and the employer of each person, who conducted any investigation (s); and (b) All notes, reports, or other documents prepared during or as a result of the investigation (s) and the persons who have custody thereof. ANSWER: See police report attached to Plaintiffs Answers to Defendant's Request for Production of Documents as Exhibit E. 6. Identify each person you intend to call as a non-expert case, and for each person identified, state your relationship substance of the facts to which the witness is expected to testify. ANSWER: To be determined. witness at the trial of this with the witness and the 7. Identify all exhibits that you intend to use at the trial of this matter and state whether they will be used during the liability or damages portions of the trial. ANSWER: To be determined. 8. If you intend to use any book, magazine, or other such writing at trial, state: (a) The name of the writing; (b) The author of the writing; (c) The publisher of the writing; (d) The date of publication of the writing; and (e) The identity of the custodian of the writing. ANSWER: To be determined. 9. If you intend to use any admissions of a party at trial, identify such admissions. ANSWER: To be determined. 10. With respect to the allegations in Plaintiff's Complaint (concerning the negligence of the Defendant), please state: (a) The name, address and telephone number of each witness who has or will provide information or testimony to support these allegations; (b) A summary of the information given by each witness; (c) Whether you have a statement from said witness, whether handwritten, typed, printed, recorded or in any other fashion, and its present location; and (d) the location of each said witness at the time of the alleged incident; and (e) Attach a copy of all such statements to your answers to these interrogatories. ANSWER: See statements attached to Plaintiffs Answers to Defendant's Request for Production of Documents as Exhibits B, C. and D. See medical records attached to Plaintiffs Request for Production of Documents. Plaintiff has not yet determined her trial witnesses. 11. Identify all injuries or diseases that you allege you suffered as a result of the incident. ANSWER: See paragraph 10 of Plaintiffs Complaint. See also, Medical Records attach Requests for Production of Documents as E the answer from the attached documents in See Pa. R.C.P. 4006(b). ad to Plaintiff's Answers to Defendant's xhibit F. Defendant can derive or ascertain substantially the same way as the Plaintiff. 12. Have you fully recovered from any of your injuries, and if so, state the approximate date of recovery. If you have not recovered from any of your injuries, state those injuries from which you have not recovered, and in what respects you have not fully recovered. ANSWER: Plaintiff has not yet fully recovered from her injuries and continues to seek medical treatment. She has not recovered from the injury to her left arm. The doctors are currently attempting to stretch her skin. Then they have to take out the tissue expander and stretch the skin over the old wound where the skin graft is located. By way of further answer, see Medical Records attached to Plaintiff's Answers to Defendant's Requests for Production of Documents as Exhibit F. Defendant can derive or ascertain the answer from the attached documents in substantially the same way as the Plaintiff. See Pa. R.C.P. 4006(b). Defendant can derive or ascertain the answer from the attached documents in substantially the same way as the Plaintiff. See Pa. R.C.P. 4006 (b). 13. Prior or Subsequent Injuries or Disease: Either prior to or subsequent to the accident referred to in the Complaint, have you ever suffered any injuries, diseases or illness involving any portion or function of the body claimed by you to have been affected by the accident referred to in the Complaint? If so, (a) Identify and describe the nature of the injuries, diseases or illnesses you suffered and the dates and causes of same: (b) If such an injury, disease or illness was caused by an accident or incident, state the date, place and nature of the accident or incident: (c) Identify all hospitals, doctors or practitioners who rendered treatment or examinations because of any such injuries, diseases or illnesses, and the date of said treatment or examination: (d) Identify anyone against whom a claim was made, and the court term or number of any claim or lawsuit that was filed in connection with any such injuries; and (e) Set forth the name, address and claim number of any insurance company to which you submitted no-fault, health and/or accident, workmen's compensation or third party claims on account of any such injury or illness. ANSWER: No prior or subsequent injuries, diseases or illness. 14. If you have received medical treatment or examination (including x-rays) because of injury or disease you suffered as a result of the incident, state: (a) The identity of each hospital at which you were treated or examined; (b) The date on which each such treatment or examination at a hospital was rendered, and the charge by the hospital for each; (c) The identity of each doctor or practitioner by whom you were treated or examined; (d) The date on which each such treatment or examination by a doctor or practitioner was rendered, and the charge for each; and (e) The identity of any document(s) (except reports of experts subject to Pa.R.C.P. 4003.5) regarding any medical treatment or examination, setting forth the author and date of such document(s). ANSWER: See Medical Records attached to Plaintiff's Answers to Defendant's Requests for Production of Documents as Exhibit F. Defendant can derive or ascertain the answer from the attached documents in substantially the same way as the Plaintiff. See Pa. R.C.P. 4006(b). 15. Has Plaintiff ever suffered from or received treatment for: a. double vision b. blurred vision c. instability of balance d. infection or disease of inner ear e. vertigo f. dizzy spells g. fainting spells h. epilepsy i. polio j. apoplexy k. paralysis 1. heart disease M. high blood pressure n. diabetes o. brain or nervous disorder p. muscular disorder ANSWER: To her knowledge, Plaintiff has not suffered from or received treatment for any of the conditions described in subparagraphs a through p. 16. If the answer to any of the items in the previous interrogatory is yes, for each such disorder, please state: (a) A description of the disorder; (b) The date of Plaintiffs last attack prior to the accident; (c) The name and address of each medical practitioner or chiropractor who examined or treated Plaintiff for the disorder; (d) A description of the treatment Plaintiff received; and (e) Whether Plaintiff was under treatment at the time of the alleged accident. ANSWER: Not applicable. 17. For the period of five years immediately preceding the date of the incident, state: (a) the name and address of each of your employers, or if you were self- employed during any portion of that period, each of your business addresses and the name of the business while self-employed; (b) The dates of commencement and termination of each of your periods of employment or self-employment; (c) The nature of your occupation in each employment or self-employment; and (d) The wage, salary, or rate of earnings received by you in each employment or self-employment, and the amount of income from employment and self- employment for each year. ANSWER: (a) Carlisle Sentinel West Pine Street Carlisle, PA (b) November 2005 to November 2006 (c) Newspaper carrier (considered independent contractor) (d) paid by the paper based on mileage (a) McDonald's High Street Carlisle and Walnut Bottom Carlisle (b) July 2004 - June 2005 (c) crew person (d) 40 hours a week at $6.00/hour (a) Sheetz Mt. Holly Springs (b) 2000 and 2001 (c) Facilities person (d) 4 hours a day $6.65 per hour 18. If, as a result of this incident, you have been unable to perform any of your customary occupational duties or social or other activities in the same manner as prior to the incident, state with particularity: (a) The duties and/or activities you have been unable to perform; (b) The periods of time you have been unable to perform; and (c) The identity of all persons having knowledge thereof. ANSWER: (a) Unable to work at time of injury job. Hanging out with friends. Going to the movies. Shopping. Going out to eat. Going out in public generally. Mowing the grass. Swimming. Fishing. Snowmobiling. Cooking. Getting dressed. Picking things up. (b) Since the crash. (c) Carol McKee, 77 Big Spring Terrace, Newville, PA Ray Fahnestock, 424 South Baltimore Ave., Mount Holly, PA Eric McKee, 424 South Baltimore Ave., Mount Holly, PA Amy Anderson, 25 Park Street, Mount Holly, PA Scott Anderson, 25 Park Street, Mount Holly, PA William Roberts, 1868 Douglas Drive, Carlisle, PA Elizabeth Morrison, 34 Big Spring Terrace, Newville, PA Janice Anderson, Lavista, Nebraska Peter and Connie Vanmeter, Yates Street, Gardners, PA Donald Paxton, 299 Starner Station Road, Gardners, PA 19. If you were under any physical or mental disability at the time of the incident, explain the disability. ANSWER: Not applicable. 20. If you have made any claim, other than present one, in any court or other tribunal (such as Bureau of Workmen's Compensation, Social Security Administration or any other administrative agency) for any injuries you allegedly sustained as a result of the incident which forms the subject matter of this action, identify such claim by court or tribunal and term number. ANSWER: Not applicable. 21. Please provide a complete itemization of all insurance benefits paid to you or on your behalf as a result of the incident which forms the subject matter of this case (including but not limited solely to medical expenses, rehabilitation expenses, lost wages and replacement services), and indicate the name and address of the insurance carrier and claim number for the carrier providing such benefits. ANSWER: The name and address of the insurance carrier paying first party benefits is Allstate Insurance Company, Med Pay Central, P.O. Box 650536, Dallas, TX 75265-0536. The claim number is 1555348042. Defendant can ascertain the amount of benefits paid by the carrier to date by subpeoning a first party payout sheet or is they prefer, Plaintiff will sign an Authorization permitting Allstate to disclose this information to the Defendant. This amount can also be ascertained by adding up all amounts paid on the medical bills attached to Plaintiffs response to Defendant request for production of documents. 22. At the time of the incident, did you have any condition for which you wore eyeglasses, or for which eyeglasses were prescribed? If so, state: (a) a description of the condition; (b) whether you were wearing eyeglasses at the time of the incident; (c) the name and address of the person who prescribed the eyeglasses; and (d) a description of your vision at the time of the accident referred to in the Complaint, both corrected and uncorrected. ANSWER: (a) nearsighted; (b) yes; (c) Walmart, Carlisle Pike, Silver Spring Township, Mechanicsburg, PA (d) unsure uncorrected; 20/20 corrected. 23. Have you ever been involved in any other legal action for personal injury, or property damage, either as a Plaintiff or as a Defendant? If so, please state: (a) the date and place each such action was filed, identifying the name of the Court, docket number, and attorneys representing each party; (b) a brief description of each such incident or lawsuit; and (c). the result of each such action, whether or not there was an appeal, and the nature and result of any such appeal. ANSWER: No. 24. Please state whether the limited tort option applies to you and explain in detail the basis for your answer. ANSWER: See complaint, specifically averments 19 and 20. SHOLLENBERGER & JANUZZI, LLP By: Date: June 20, 2007 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ASHLEY E. MCKEE, Plaintiffs V. STACEY POWELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL CERTIFICATE OF SERVICE And now, this 20th day of June, 2007, 1 hereby certify that a copy of the foregoing Plaintiffs Answers to Defendant's Interrogatories has been served upon the following, via U.S. Mail: Brooks R. Foland, Esquire Thomas, Thomas, & Hafer LLP P.O. Box 999 Harrisburg, PA 17108 SHOLLENBERGER & JANUZZI. LLP By: GATIM CASE FILES- OPENWIcKee, AshleyfDiscovery\060607 plfs answers to Interr of def [ah].DOC . & 0 Ashley E. McKee VERIFICATION , hereby acknowledge that I am a Plaintiff in this action and that I have read the Answers to Interrogatories and that the facts stated herein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 'x a'4-k? e- Signature Date: June 20, 2007 G 1GLOBA1-\WPDATA\DOCSUNITIAL CONSULT DOCS (SET-UPS)\Verificalion wpd SHOLLEN(3ERGER $ JANUZZi, LLP 2225 Mi llenm Um Way. Enola. PA 170.5 (717) 7263200. FAX (717) 728 3200 ? ? G '? a ?-? `- ??» ? ?. -'? iii ?' _ y., ? . ? ?? ,> sYc SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ASHLEY E. MCKEE, Plaintiffs V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STACEY POWELL, Defendant NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL NOTICE OF SERVING DISCOVERY TO THE PROTHONOTARY: Please take notice that Plaintiff, ASHLEY E. MCKEE, served Responses to Defendant's Request for Production of Documents pursuant to the Pennsylvania Rules of Civil Procedure, by mail, postage prepaid, on the 12th day of July, 2007. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: 0.0tyy o enberger, Esq. Attorney I.D. # 34343 Adam T. Wolfe, Esq. Attorney I.D. #201057 Date: July 12, 2007 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 ottnrnPvs for Plaintiff ASHLEY E. MCKEE, Plaintiffs V. STACEY POWELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL CERTIFICATE OF SERVICE And now, this 12th day of July, 2007, 1 hereby certify that a copy of the foregoing Plaintiffs Answers to Defendant's Request for Production of Documents has been served upon the following, via U.S. Mail: Brooks R. Foland, Esquire Thomas, Thomas, & Hafer LLP P.O. Box 999 Harrisburg, PA 17108 SHOLLENBERGER & JANUZZI, LLP By: Ti by A. S One r, Es q. Attorney ID#34343 2 Shollenberger & Januzzi, LLP 2225 Millennium Way, Enola, PA 17025 Phone: 717-728-3200 Fax: 717-728-3400 CJ '7? - -? t tai rim SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attomevs for Plaintiff ASHLEY E. MCKEE, Plaintiffs V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STACEY POWELL, Defendant NO. 07-1344 CIVIL ACTION - LAW JURY TRIAL And now, this 18th day of September, 2007, 1 hereby certify that a copy of the foregoing Supplemental Interrogatory Propounded by Plaintiff to be Answered by Defendant has been served upon the following, via U.S. First Class Mail: Brooks R. Foland, Esquire Thomas, Thomas, & Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 SHOLLENBERGE By: 5 , LLP SMXLENSERGER & JANUZZI, LLP 2225 MILLENNIUM WAY ! ENOLA, PA 17025 (717) 728-3200 ! FAX (717) 72834W r.? ?"' ?- -v ?? ?-?-; ro ? ? ?, ?? N ,,,,? SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ASHLEY E. MCKEE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. STACEY POWELL, Defendant NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a Subpoena for documents and things pursuant to Rule 4009.22, Plaintiff certifies that: (1) A Notice of Intent to serve the Subpoena with a copy of the Subpoena attached thereto was mailed or delivered to each party at least twenty (20) days prior to the date on which the Subpoena is sought to be served, (2) A copy of the Notice of Intent, including the proposed Subpoena, is attached to this Certificate, (3) No objection to the Subpoena has been received, and (4) The Subpoena which will be served is identical to the Subpoena which is attached to the Notice of Intent to serve the Subpoena. Respectfully submitted, SHOLLENBE Date: ?f1 (A 2-JD By: & JANUZZI, LLP r( hy A. Srfoltefiberger, Esq. ttorney I.D. # 34343 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ASHLEY E. MCKEE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. STACEY POWELL, Defendant NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL CERTIFICATE OF SERVICE And now, this 11th day of January, 2008, 1 hereby certify that a copy of the foregoing Certificate Prerequisite has been served upon the following, via First- Class Mail: Brooks R. Foland, Esquire Thomas Thomas & Hafer, LLP 305 N. Front Street Harrisburg, PA 17101 SHOLLENBERGER & JANUZZI, LLP By: T . S Ien erger, Esq. A o y rney I D# 4343 2 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff ASHLEY MCKEE, Plaintiff V. STACEY POWELL, y. Defendant w r NOTI(«EOFINTENT T1 k?{ F - P O-DUGE'D®C.U E:N S ?1 ,?;a z ;;w _ ? U T TO: Brooks R. Foland Thomas Thomas & Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED P!' # y' e -4 ?S 93 - - _ _ t . PLEASE TAKE NOTICE that Plaintiff intends to serve a subpoena identical to the one attached to this notice. You have twenty (20) days from the date listed below in which to file on record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. SHOLLENBERGER & JANUZZI, LLP By: Date: October 22, 2007 ., SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 . Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff ASHLEY MCKEE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-1344 CIVIL TERM STACEY POWELL, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED - 4t, ISM 01110-99 E And now, this 22nd day of October, 2007, 1 hereby certify that a copy of the foregoing Notice of Intent to Serve Subpoena has been served upon the following, via First-Class Mail: Brooks R. Foland Thomas Thomas & Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 By: SHOLLENBERGER & JANUZZI, LLP 2 A COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ASHLEY MCKEE, ' Plaintiff File No. 07-1344 Civil Term 1 ' V. STACEY POWELL, Defendant SUBPOENA TO PRODUCE. DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Adams County Department of Emergency Services (Name of person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all phone and radio records from the entire day of Tuesday, April 25, 2006. at Shollenberger 8 Januzzi, 2225 Millennium Wav. Enola _ PA 17075,. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Timothy A. Shollenberger ADDRESS: ),),) c AA ;I I .......:..... IA:_.. TELEPHONE: 717-728-3200 SUPREME COURT ID #-3434-1 ATTORNEY FOR: P in i n to ff BY THE COURT: Prothonotary, Civil Division 'Seal of the Court Deputy na ? I ?- -'tifr't ?1T1 cz { THOMAS, THOMAS & HAFER, LLP by: Brooks R. Foland, Esquire I.D. No. 70102 305 North Front Street 6th Floor POB 999 Harrisburg, PA 17108-0999 (717) 255-7626 ASHLEY E. MCKEE, Plaintiff vs. STACEY POWELL, Defendant Attorneys for Stacey Powell IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant 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 (2.0) days in advance of this Certificate; 2. No objection to the subpoenas have been made; and 3. The subpoenas which will be served are identical to the subpoenas which are attached to this Notice. Respectfully submitted, i WRookK8 MAS 8? AFER, LLP Date: By: ?" "V LAND, ESQUIRE 305 N. Front Street, P.O. Box 999 Harrisburg, PA 17108 (717) 237-7141 Attorney for Defendant THOMAS, THOMAS & HAFER, LLP by: Brooks R. Foland, Esquire I.D. No. 70102 305 North Front Street, P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7626 ASHLEY E. MCKEE, Plaintiff vs. STACEY POWELL, Defendant Attorneys for Stacey Powell IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR TMNGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Allstate Insurance Company,-6345 Flank Drive, Suite 1000, Harrisburg, PA 17112; Claimant: Ashley McKee; DOL: 04/24/06 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete conies of the entire first party and property damage claim files to include benefits Davout sheets for wage loss or medical benefits paid, application for benefits form, wage and salary verification, investigative materials, independent medical examination roorts, medical bills, medical records, disability notes, correspondence photo Uhs, property damage estimates, recorded statements, and any other documents contained in the first party and prope damage claim files, at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7626 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant BY THE COURT: DATE:_ 0//-`0,4200's &I ?jl 'j dji P. " Seal o the Court Prothonotary/Cler , Civil Division ?Le,=L ? Deputy THOMAS, THOMAS & HAFER, LLP by: Brooks R. Foland, Esquire I.D. No. 70102 305 North Front Street, P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7626 ASHLEY E. MCKEE, Plaintiff vs. STACEY POWELL, Defendant Attorneys for Stacey Powell IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Aspers Fire Company Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of the entire personnel files for Edward Senkbiel pertaining to his employment at your facility in the fire and EMS departments, correspondence, memoranda, e-mail communications, reports, performance reviews, corrective action documentation, and any other documents contained in your personnel files. at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisbura. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the parry making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7626 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant BY THE COURT: DATE:_ OI Loa- /,460,R 011 6. -P. Seal o the Court Prothonotary/C rk, Civil Division ?L? A 0 V- Deputy THOMAS, THOMAS & HAFER, LLP by: Brooks R. Foland, Esquire I.D. No. 70102 305 North Front Street, P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7626 ASHLEY E. MCKEE, Plaintiff vs. STACEY POWELL, Defendant Attorneys for Stacey Powell IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Mt. Holly Springs Borough - Mt. Holly Fire Company, 11 Mill Street, Mt. Holly Springs, PA 17065 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of the EMS report. accident report, correspondence, notes, statements, photographs, documents, etc. regarding Ashley McKee for a date of loss of April 25. 2006. at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108- 0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7626 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE: //09-41-008 - Seal of the Court BY THE COURT: 1Ctt k. othonotary/Clerk, Ci Division Deputy THOMAS, THOMAS & HAFER, LLP by: Brooks R. Foland, Esquire I.D. No. 70102 305 North Front Street, P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7626 ASHLEY E. MCKEE, Plaintiff Attorneys for Stacey Powell IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM vs. STACEY POWELL, CIVIL ACTION - LAW JURY TRIAL DEMANDED Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Biglerville EMS, I 1 I South Main Street, Biglerville, PA 17307 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of the EMS report, accident report, correspondence, notes, statements, photographs, documents, etc. regarding Ashley McKee for a date of loss of April 25, 2006. at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisbura. PA 17108- 0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA TELEPHONE: (717) 255-7626 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant 17108-0999 BY THE COURT: DATE: l W o26og Sea of he Court rothonotary/Clerk, GbIvil Division Deputy THOMAS, THOMAS & HAFER, LLP by: Brooks R. Foland, Esquire I.D. No. 70102 305 North Front Street, P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7626 ASHLEY E. MCKEE, Plaintiff vs. STACEY POWELL, Defendant Attorneys for Stacey Powell IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Regional Medical Center, Medic 83, 246 Parker Street, Carlisle, PA 17013-3618 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of the EMS report, accident report, correspondence, notes, statements, photographs, documents, etc. regarding Ashley McKee for a date of loss of April 25. 2006. at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108- 0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7626 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE: 01L4 goo Seal o the Court BY THE COURT: 5 ?. ro honotary/Clerk, Civi ivision Deputy THOMAS, THOMAS & HAFER, LLP by: Brooks R. Foland, Esquire I.D. No. 70102 305 North Front Street, P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7626 ASHLEY E. MCKEE, Plaintiff Attorneys for Stacey Powell IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM vs. CIVIL ACTION - LAW STACEY POWELL, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Penn State Life Lion, 228 Petersburg Road, Hanger 15, Carlisle, PA 17013 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of the flight report, accident report, correspondence, notes, statements, photographs, documents, etc. regarding Ashley McKee for a date of loss of April 25. 2006. at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisbure. PA 17108- 0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA TELEPHONE: (717) 255-7626 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant 17108-0999 BY THE COURT: DATE: i/oa1aDnA Seal f thie Court thonotary/Clerk, Ci Division Deputy THOMAS, THOMAS & HAFER, LLP by: Brooks R. Foland, Esquire I.D. No. 70102 305 North Front Street, P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7626 ASHLEY E. MCKEE, Plaintiff vs. Attorneys for Stacey Powell IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW STACEY POWELL, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Adams County Ambulance Association, R.D. #2, Littlestown, PA 17340 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of the EMS report, accident report, correspondence, notes, statements photographs, documents, etc. regarding Ashley McKee for a date of loss of April 25, 2006. at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburiz, PA 17108- 0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7626 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE110'q-1100.0 Seal oft e Court BY THE COURT: 5 OP othonotary/Clerk, Civ Division Lja[ K. Deputy THOMAS, THOMAS & HAFER, LLP by: Brooks R. Foland, Esquire I.D. No. 70102 305 North Front Street, P.O. Box 999 Harrisburg, PA 17108-0999 (717) 255-7626 ASHLEY E. MCKEE, Attorneys for Stacey Powell IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. NO. 07-1344 CIVIL TERM CIVIL ACTION - LAW STACEY POWELL, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dickinson Township Fire Department, 219 Mountainview Road, Mt. Holly Springs, PA 17065 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of the EMS report, accident report, correspondence, notes. statements, photographs, documents, etc. regarding Ashley McKee for a date of loss of April 25, 2006, at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999. Harrisburg. PA 17108- 0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 255-7626 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant BY THE COURT: DATE: / LoaL 1.761)k Seal f th Court 1610 r thonotary/Clerk, Civ Division r- - " I . J?A Deputy CERTIFICATE OF SERVICE D NOW this ? daY of January, 2008, I, Kate A. Wilhelm, a Paralegal in AN „ the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, first class, postage prepaid, to the following: Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, LLP 225 Millennium Way Enola, PA 17025 Kate A. Wilhelm, Paralegal 503541.2 n.3 fQ r, a 'iJ SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff ASHLEY E. MCKEE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. STACEY POWELL, Defendant NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL CERTIFICATE OF SERVICE And now, this 2' day of April, 2008, 1 hereby certify that a true and correct copy of the Notice of Deposition of Bob Myers has been served upon the following via U.S. Mail, postage prepaid, addressed to: Bob Myers 69 Pine Hill Road Enola, PA 17025 SHOLLENB,ERGER & JANUZZI, LLP , Esq. ey I.D. #34343 Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 717-728-3200 3 s• co SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff ASHLEY E. MCKEE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. STACEY POWELL, Defendant NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL CERTIFICATE OF SERVICE And now, this 2 may of April, 2008, 1 hereby certify that a true and correct copy of the Notice of Deposition of Robert Orner has been served upon the following via U.S. Mail, postage prepaid, addressed to: Robert Orner 7 North Baltimore Ave. Mt. Holly Springs, PA 17065 Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 717-728-3200 3 SHOLLENBERGER & JANUZZI, LLP r-3 C::} co SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ASHLEY E. MCKEE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. STACEY POWELL, Defendant NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL CERTIFICATE OF SERVICE And now, this 2r day of April, 2008, 1 hereby certify that a true and correct copy of the Notice of Deposition of Drew Zentmeyer has been served upon the following via U.S. Mail, postage prepaid, addressed to: Drew Zentmeyer 25 Chestnut Street Mt. Holly Springs, PA 17065 SHOLLENBE By: (i A" S rney I ER & JANUZZI, LLP Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 717-728-3200 3 C7 ° _ CD c> ca SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff ASHLEY E. MCKEE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. STACEY POWELL, Defendant NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL CERTIFICATE OF SERVICE And now, this)'d day of April, 2008, 1 hereby certify that a true and correct copy of the Notice of Deposition of Sean McConnell has been served upon the following via U.S. Mail, postage prepaid, addressed to: Sean McConnell 554 Mountain Road Boiling Springs, PA 17007 SHOLLE & JANUZZI, LLP Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 717-728-3200 3 cm CO '?j>!•` -C, OD ry r - ? co SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ASHLEY E. MCKEE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. STACEY POWELL, Defendant NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL CERTIFICATE OF SERVICE And now, this Z?4-day of April, 2008, 1 hereby certify that a true and correct copy of the Notice of Deposition of Daniel Paxton has been served upon the following via U.S. Mail, postage prepaid, addressed to: Daniel Paxton 29 Victory Church Road Gardners, PA 17324 SHOLLENB GER & JANUZZI, LLP By m th oll nberger, Esq. Attorney I.D. #34343 Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 717-728-3200 3 r Ij ca i j fvJ SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff ASHLEY E. MCKEE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. STACEY POWELL, Defendant NO. 07-1344 Civil Term CIVIL ACTION - LAW I JURY TRIAL CERTIFICA E OF SERVICE And now, this 2r dday of April, 2008, 1 hereby certify that a true and correct copy of the Notice of Deposition of Walter Wagamen has been served upon the following via U.S. Mail, postage prepaid, addressed to: Walter Wagamen 1507 Centermills Road Aspers, PA 17304 By: SHOLLENBERG?R & JANUZZI, LLP Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 717-728-3200 3 ro S co co t SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ASHLEY E. MCKEE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. STACEY POWELL, Defendant NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL CERTIFICATE OF SERVICE And now, this 2.E4day of April, 2008, 1 hereby certify that a true and correct copy of the Notice of Deposition of Derek Bream has been served upon the following via U.S. Mail, postage prepaid, addressed to: Derek Bream 7 South Walnut Street Mt. Holly Springs, PA 17065 SHOLLEN By: ey I.D Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 717-728-3200 3 CP SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ASHLEY E. MCKEE, Plaintiffs V. STACEY POWELL, Defendant CERTIFICATE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL And now, this Z- day of April, 2008, 1 hereby certify that a true and correct copy of the Notice of Deposition of Dan and Dee Keck has been served upon the following via U.S. Mail, postage prepaid, addressed to: Dan and Dee Keck PO Box 424 Bendersville, PA 17306 SHOLLENBERGER & JANUZZI, LLP By: D. #34343 Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 717-728-3200 3 G m 4 zf SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff ASHLEY E. MCKEE, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. STACEY POWELL, Defendant NO. 07-1344 Civil Term CIVIL ACTION - LAW JURY TRIAL CERTIFICATE OF SERVICE And now, this 2- day of April, 2008, 1 hereby certify that a true and correct copy of the Notice of Deposition of Barry Nelson has been served upon the following via U.S. Mail, postage prepaid, addressed to: Barry Nelson 34 East Street Mt. Holly Springs, PA 17065 SHOLLENBERG & NU I, LLP By. Timothy 'A. Shollenberger, sq. Attorney I.D. #34343 Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 717-728-3200 3 C7 z P X- SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-4300 Attornevs for Plaintiff ASHLEY E. MCKEE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-1344 Civil Term STACEY POWELL, CIVIL ACTION - LAW Defendant JURY TRIAL PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned action settled, ended, and discontinued with prejudice. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP Attorneys for the Plaintiff By Date: July 8, 2008 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-4300 Attornevs for Plaintiff ASHLEY E. MCKEE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-1344 Civil Term STACEY POWELL, CIVIL ACTION - LAW Defendant JURY TRIAL CERTIFICATE OF SERVICE AND NOW this 8th day of July 2008, 1 hereby certify that I have served the following Praecipe to Discontinue on the following by forwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to: Thomas Thomas & Hafer, LLP Brooks R. Foland 305 N. Front Street Harrisburg, PA 17101 SHOLLENBERGER & JANUZZI, LLP By: Agy?l Ti o ber , E wire _ ? ? ,;? ? .. x? t "' ---? r iZ ?._ r"' _ 1.µ. {?. '- ??t