HomeMy WebLinkAbout03-0761DOUGLAS WALKER,
Plaintiff, : IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSLVANIA
V.
: CIVIL ACTION - LAW
EDWARD FURLONG, : NO- 03 - I16o l Cr v1 r
Defendant : JURY TRIAL, DEMANDED
PRAECIPE FOR WRIT OF SUMMONS
To the Prothonotary;
Please issue a Writ of Summons in the above captioned action- Writ of Su
be issued and forwarded to the Sheriff for service upon: Summons shall
Edward Furlong
c/o Fry Communications
800 West Church Road
Mechanicsburg, PA 17055
Date: 2-20-03
Mark 147 quire
155 S. Hanover St.
Carlisle, PA 17013
Supreme Court I.D.# 87663
(717) 241-6070
WRIT OF SUMMONS
To the above named Defendant:
YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS
COMMENCED AN ACTION AGAINST YOU. _ /1
Date: M X,, ,;?CV,3
By:
Deputy
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SHERIFF'S RETURN - REGULAR
CASE NO: 2003-00761 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WALKER DOUGLAS
VS
FURLONG EDWARD
RONALD HOOVER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within WRIT OF SUMMONS
FURLONG EDWARD
DEFENDANT
was served upon
the
, at 1525:00 HOURS, on the 5th day of March 2003
at C/O FRY COMMUNICATIONS
MECHANICSBURG, PA 17055
EDWARD FURLONG
800 WEST CHURCH ROAD
by handing to
a true and attested copy of WRIT OF SUMMONS
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
6.21
+r,
. 00
10.00 R. Thomas Kline
03/06/2003
ROMINGER & BAYLEY
Sworn and Subscribed to before
me this /o t- day of
?LtLC? d. ?r9(? a A. D.
By:
Deputy Sheriff
rothonotary
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DOUGLAS WALKER,
Plaintiff,
V.
EDWARD FURLONG,
Defendant.
Civil Action - Law
No. 03-761
JURY TRIAL DEMANDED
PRAECIPE FOR ENTRY OF APPEARANCE PURSUANT TO Pa.R.C.P. 1012
TO THE PROTHONOTARY:
Kindly enter the appearance of Robert A. Lerman, Esquire, and Peter D. Solymos, Esquire of
Griffith, Strickler, Lerman, Solymos & Calkins, as attorneys for the Defendant, Edward Furlong, in
the above-captioned matter and mark the docket accordingly.
ZICKLER, LERMAN,
OS & CALKINS
Dated:
BY
I
Robert A. Lerman
U -?
Supreme Court ID No. 07490
BY ;
Peter D. Solymos
Supreme Court ID No. 07475
Attorney for the Defendant, Edward Furlong
110 South Northern Way
York, PA 17402
Telephone: (717) 757-7602
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DOUGLAS WALKER, Civil Action - Law
Plaintiff,
V. No. 03-761
EDWARD FURLONG,
Defendant. JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
rd
AND NOW, thid? day of April, 2003, I, Robert A. Lerman, a member of the firm of
GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date
served a copy of the Praecipe for Entry of Appearance by United States Mail, addressed to the
party or attorney of record as follows:
Mark F. Bailey, Esquire
Rominger & Bailey
155 S. Hanover Street
Carlisle, PA 17013
(Counsel for Plaintiff)
CKLER, LERMAN,
1S & CALKAS ,
By:/?/ //? ?'
obert A. Lerman, SupremevCour? ID No. 07490
Attorney for the Defendant, Edward Furlong
110 S. Northern Way
York, PA 17402
(717) 757-7602
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DOUGLAS WALKER,
Plaintiff,
V.
EDWARD FURLONG,
Defendant.
Civil Action - Law
No. 03-761
JURY TRIAL DEMANDED
PRAECIPE FOR WITHDRAWAL OF APPEARANCE
TO THE PROTHONOTARY:
Kindly withdraw the appearance of Robert A. Lerman, Esquire and Peter D. Solymos, Esquire, as
attorneys for the Defendant, Edward Furlong, in the above-entitled matter and mark the docket
accordingly.
GRIFFITH, STRICKLER, LERMAN,
,SOLYMOS & CALKINS
/ n
BY
Robert A. erman
Supreme Court ID No. 07490
Peter D. Solymo
Supreme Court ID No. 07475
Attorney for the Defendant, Edward Furlong
110 South Northern Way
York, PA 17402
Dated: ?7i 0 Telephone: (717) 757-7602
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DOUGLAS WALKER,
Plaintiff,
V.
EDWARD FURLONG,
Defendant.
Civil Action - Law
No. 03-761
JURY TRIAL DEMANDED
??CERTIFICATE OF SERVICE
AND NOW, this 4' -day of December, 2003, I, Peter D. Solymos, Esquire, a member
of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify
that I have this date served a copy of the Praecipe for Withdrawal of Appearance by United
States Mail, addressed to the party or attorney of record as follows:
Mark F. Bailey, Esquire
Rominger & Bailey
155 S. Hanover Street
Carlisle, PA 17013
Counsel for Plaintiff
Donald B. Hoyt, Esquire
17 E. Market Street
York, PA 17401
Counsel for Defendant
GRIFFITH, STRICKLER, LERMAN,
S LYMOS & CALKINS
By:jYi?,1
Attorney I.D.#: 07475
110 S. Northern Way
York, PA 17402
717-757-7602
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
DOUGLAS WALKER
Plaintiff
No. 03-761 Civil
VS.
EDWARD FURLONG JURY TRIAL DEMANDED
Defendant
PRAECIPE FOR RULE TO FILE COMPLAINT
TO THE PROTHONOTARY:
Please issue Rule on Douglas Walker to file a Complaint in the above case within twenty
(20) days after service of the Rule or the Prothonotary, upon praecipe, shall enter a judgment non
pros.
C BLAKEY, YOST, BUPP & RAUSCH, LLP
Date: ?? t75 By: CDr-wlel
onald B. Hoyt, Es uire
S. Ct. I.D. #18061
Attorney for Defendant
17 East Market Street
York, PA 17401
Telephone (717) 845-3674
Fax No. (717) 854-7839
NOW, MARCH S , 2005, RULE ISSUED AS ABOVE.
Prothonotary
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUTNY, PENNSYLVANIA
DOUGLAS WALKER
Plaintiff
No. 03-761 Civil
VS.
EDWARD FURLONG
Defendant
.JURY TRIAL DEMANDED
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set fc
following pages, you must take action within twenty (20) days after this complaint
served, by entering a written appearance personally or by attorney and filing in writ
court your defenses or objections to the claims set forth against you. You are warns
fail to do so the case may proceed without you and a judgment may be entered agai
court without further notice for any money claimed in the complaint or for any othe
relief requested by the plaintiff. You may lose money or property or other rights in
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. if'
NOT HAVE A LAWYER. GO TO OR TELEPHONE THE OFFICE SET FORTH
i in the
I notice are
with the
that if you
you by the
laim or
mart to
IU DO
OW.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY 3E ABLE
TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAYO FER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEF..
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Phone: (717) 249-3166
(800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to
the Americans with Disabilities Act of 1990. For information about accessible faci
reasonable accommodations available to disabled individuals having business before
please contact our office. All arrangements must be made at least 72 hours prior to
or business before the Court. All arrangements must be made at least 72 hours prior to a
)ly with
-s and
ie Court,
? hearing
hearing or
business before the court. You must attend the scheduled conference or hearing.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUTNY, PENNSYLVANIA
DOUGLAS WALKER
Plaintiff
V5.
No. 03-761 Civil
JURY TRIAL DEMANDED
EDWARD FURLONG
Defendant
COMPLAINT
AND NOW, comes Douglas Walker, by and through his privately retained
E. Rominger, Esquire and in support of his Complaint avers as follows:
, Karl
1. Plaintiff is an adult individual with a domicile at 234 E. Mulberry Avenu?. Carlisle,
Cumberland County, Pennsylvania.
2. Defendant is an adult individual residing at 4619 Hillside Road. Harri
Pennsylvania.
3. On or about February 22, 2001, Plaintiff was injured in a motor vehicle collision.
4. Plaintiff sustained severe injury, not limited to his back and legs; and
and suffering.
5. Asa result of the injuries he has lost wages and earning capacity, and will
future economic and medical damages.
COUNT 1. NEGLIGENCE
6. Previous paragraphs are incorporated by reference.
pain
suffer
7. The facts and occurrences hereinafter related, took place on or about Febr?iary 22,
2001, near the parking lot of Fry Communications at 800 W. Church
Mechanicsburg, Cumberland County, Pennsylvania.
8. Plaintiff was operating his motor vehicle in a lawful, careful and prudent
9. Plaintiff stopped at the intersection of the parking lot of Fry
appropriate and prudent manner.
10. Defendant at that time was operating his automobile in a reckless and
manner.
11. Defendant' vehicle struck Plaintiff's vehicle.
12. Defendant had a duty to Plaintiff to operate his vehicle in a safe manner
13. Defendant violated his duty by acting negligently and recklessly as
below.
14. At the time of the accident, the negligence of the Defendant consisted
following:
(a). Failing to keep his vehicle under proper and adequate control.
(b). Failing to keep a careful and diligent watch on the road.
(c). Failing to maintain an assured clear distance.
(d) Failing to follow the provisions of Pennsylvania Motor Vehicle
to the operation of motor vehicles as they relate to approaching
the roadway at an intersection.
(e). Such other acts or omissions as may be revealed in the course of
a trial in this case.
15. Defendant struck Plaintiff's vehicle with great force.
16. As a result direct and proximate of the impact by Defendant's vehicle, the
suffered injuries which resulted in the necessity of medical treatment and
17. Said injuries, which were a result of the impact of Defendant's vehicle,
in an
described
relating
vehicles on
liscovery or
work.
Plaintiff severe physical injuries and mental anguish, pain and suffering, a hock to
the nervous system, physical trauma, and emotional distress, as well as
bills, disabling Plaintiff from enjoying life and full function of his limbs
18. Plaintiff received extensive medical treatment for his injuries.
19. Plaintiff lost work, wages, and had other pecuniary damages, including
aforementioned medical bills, as well as various out of pocket expenses
result of Defendant's negligence.
20. Plaintiff suffered and continues to suffer as a result of Defendant's neg]
WHEREFORE, Plaintiff Douglas Walker respectfully requests
enter a judgment in his favor and against Defendant in an amount in excess of the
compulsory arbitration.
Date: March 31, 2005
Respectfully submitted,
ROMINGER. BAYLE!Y &
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle. PA 17013
(717) 241-6070
Supreme Court 1l)# 811924
Attorney for Plaintiff
re medical
organs.
a direct
this Court
limit on
VERIFICATION
Karl E. Rominger, Esquire, states that he is the attorney for, Plaintiff in this
he makes this affidavit as attorney because the Plaintiff is not in this jurisdiction at
filing and he has sufficient knowledge or information and belief, based upon his
the matters averred or denied in the foregoing document; and that this statement is
to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to unsworn falsification to
on; that
time of
igation of
e suhlect
ities.
Date: March it, 2005 Respectfully submitted,
ROMINGER, BAYLEY & W "ARE
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUTNY, PENNSYLVANIA
DOUGLAS WALKER
Plaintiff
No. 03-761 Civil
vs.
EDWARD FURLONG
Defendant
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
1, Karl E. Rominger, Esquire, attorney for Plaintiff, do hereby certify that I thlis day
served a copy of the Complaint upon the following by depositing same in the Unitedi States Mail,
first class postage prepaid, at Carlisle. Pennsylvania, addressed as follows:
Edward Furlong
clo Donald Hoyt, Esquire
17 East Mt. St.
York, Pa 17401
Dated: March 31, 2005 Respectfully submitted
ROMINGER, BAYLEY & W ARE
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81 u24
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
DOUGLAS WALKER
Plaintiff
No. 03-761 Civil
vs.
EDWARD FURLONG JURY TRIAL DEMANDED
Defendant
NOTICE TO PLEAD
TO: Mr. Douglas Walker
c/o Karl E. Rominger, Esquire
ROMINGER, BAYLEY & WHARE
155 South Hanover Street
Carlisle, PA 17013
You are hereby notified to plead to the enclosed New Matter within twenty (20) days from
service hereof or a default judgment may be entered against you.
Respectfully submitted,
BLAKEY, YOST, BUPP & RAUSCH, LLP
By.
onald B. Hoyt, Esquire
Counsel for Defendant
17 East Market Street
York, Pennsylvania 17401
Supreme Ct. I.D. #18061
(717) 845-3674
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
DOUGLAS WALKER
Plaintiff
No. 03-761 Civil
VS.
EDWARD FURLONG JURY TRIAL DEMANDED
Defendant
ANSWER AND NEW MATTER
1. The allegations of this paragraph are denied. After reasonable investigation,
Defendant is without knowledge or information sufficient to form a belief as to the truth of this
averment.
2. The allegations of this paragraph are admitted.
3. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
4. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
5. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
6. The allegations of this paragraph require no response. Should one be required,
however, Defendant hereby incorporates ¶¶ 1 through 5 of this Answer.
7. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
8. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
9. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
10. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
11. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
12. The allegations of this paragraph are denied. They state legal conclusions to
which no response is required.
13. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
14. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
15. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
16. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
17. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
18. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
19. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
20. The allegations of this paragraph are denied pursuant to Pennsylvania Rule of
Civil Procedure 1029(e).
WHEREFORE, Defendant requests the Court to dismiss the Complaint, with costs of
suit.
NEW MATTER
21. The answers contained in ¶¶I through 20 are hereby incorporated by reference
thereto as if more fully set forth herein below.
22. Plaintiff's damages, if any, are barred or limited, in whole or in party, by the
provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, including but not
limited to the limited tort provision, and the provisions precluding recovery for medical bills and
wage loss otherwise covered by first party insurance benefits, as well as the reductions mandated
by 75 Pa. C.S. §I797(a).
WHEREFORE, Defendant requests dismissal of the Complaint, with costs of suit.
Date:
BLAKEY, YOST, BUPP & RA SCH, LLP
av: onald B. Hoyt, squire
S. Ct. I.D. #18061
Attorney for Defendant
17 East Market Street
York, PA 17401
Telephone (717) 845-3674
Fax No. (717) 854-7839
VERIFICATION
DONALD B. HOYT, ESQUIRE, verifies that he is attorney for Defendant, that he is
authorized to represent him in this action, that he has acquired the facts supporting the within
Defendant's Answer to Complaint and New Matter in his capacity as attorney for Defendant, and
that the facts set forth in the within Answer to Complaint and New Matter are true and correct to
the best of his knowledge, information and belief. He understands that false statements herein
are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to
authorities. r
Dated: ?1?/QJ
Donald B. Hoyt, Esquire
Counsel for Defendant
CERTIFICATE OF SERVICE
I hereby certify that I am this day causing a copy of the foregoing document to be served
on the following person in the manner indicated:
By First Class United States Mail on:
Karl E. Rominger, Esquire
ROMINGER, BAYLEY & WHARE
155 South Hanover Street
Carlisle, PA 17013
BLAKEY, YOST, BUPP & RAUSCH, LLP
/ t-
By.
Dona d B. Hoyt, E 're
Counsel for Defendant
17 East Market Street
York, Pennsylvania 17401
(717) 845-3674
Supreme Ct. I.D. #18061
Dated: 7
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
DOUGLAS WALKER
Plaintiff
No. 03-761 Civil
vs.
EDWARD FURLONG
Defendant
JURY TRIAL DEMANDED
ANSWER TO DEFENDANT'S NEW MATTER
22. Is a conclusion of law and requires no answer. By way of further answer, if an
answer is required the same is denied and strict proof of the same is demanded at trial.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court to enter
a judgment in his favor and against Defendant in an amount in excess of the local limit on
compulsory arbitration.
Date: Respectfully submitted,
ROMINGER, BAYLEY & WHARE
------------
Kar E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
DOUGLAS WALKER
Plaintiff
vs.
No. 03-761 Civil
JURY TRIAL DEMANDED
EDWARD FURLONG
Defendant
CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Douglas Walker do hereby certify that I
this day served a copy of the Answers to Defendant's New Matter upon the following by
depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania,
addressed as follows:
Donald B. Hoyt, Esquire
17 East Market Street
York, Pa 17401
Date: t?_ 2 Respectfully Submitted,
ROMINGER,BAYLEY & WHARE
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, Pa 17013
(717) 241-6070
Supreme Court #81924
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
vs.
EDWARD FURLONG
Defendant
No. 03-761 Civil
JURY TRIAL DEMANDED
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Defendant certifies that:
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to counsel for the Plaintiff on May,
2005;
(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.
onald B. Hoyt, quire
Attorney for Defendant
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Date: Cg
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff No. 03-761 Civil
vs.
EDWARD FURLONG JURY TRIAL DEMANDED
Defendant
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Defendant certifies that:
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to counsel for the Plaintiff on September
13, 2005;
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate;
(3) Opposing counsel has no objection to the issuance of the
subpoenas, as per Attorney Rominger's letter attached.
(4) The subpoena which will be served is identical to the subpoena
which is attached to the notice of intent to serve the subpoena.
Donald B. Hoyt, squire
Attorney for Defendant
Date:
09-14-'05 15.02 FROM-ROCIINGER,SkYLE`i,??)HAA 7172415272
T-352 5001!001 F-392
ROMINGER, BAYLEY & WHARE
Attorneys at Law
Karl E. Rominger James I. Nelson
Mark F. Bayley Michael O. Palermo, Jr
Michael J. Whare
September 14, 2005
Via Fax Only (717) 854-7839
Norma M. Doll, Paralegal
Donald B. Hoyt, Esquire
17 East Market Street
York, Pa 17401
RE: Doug Walker
Dear Ms. Doll:
In regards to your letter on September 13, 2005, Karl E. Rominger, has no
objection to the service of subpoenas on Fry Communications, Orthopaedic and Spine
Specialists and PMA Group.
Thank you for your time and attention to this matter.
Sincerely,
Brooke Binger, Paralegal
1,55 South Hanover Street, Carlisle, Pennsylvania 17013 • Tel: (717) 2,41.6070 • Fax: (717) 241-6878
www.romingcrlaw.com
ADVOCACY • ADVICE • ANSWERS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
vs.
EDWARD FURLONG
Defendant
No. 03-761 Civil
JURY TRIAL, DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009-21
Donald B. Hoyt, Esquire, Attorney for the Defendant, Edward Furlong, 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 of record and serve upon the undersigned an objection to the subpoena. If no
objection is made the subpoena may be served.
Date:
BLAKEY, YOST, BUPP & RAUSCH, LLP
4on d B. JHo Esquire
Attorney for Defendant
S. Ct. I.D. #18061
17 East Market Street
York, PA 17401
Telephone (717) 845-3674
Fax No. (717) 854-7839
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff No. 03-761 Civil
vs.
EDWARD FURLONG JURY TRIAL DEMANDED
Defendant
CERTIFICATE OF SERVICE
I hereby certify that I have this day caused a copy of the foregoing Notice of Intent to Serve
Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4004.21, to be served
upon the following person in the manner indicated below:
By First Class Mail on:
Karl E. Rominger, Esquire
ROMINGER, BAYLEY & WHARE
155 South Hanover Street
Carlisle, PA 17013
BLAKEY, YOST, BURP & RAUSCH, LLP
By:- 1 1"-- U?-C?
Norma . Doll, Paralegal
Dated: ?/? 3- S
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff No. 03-761 Civil
VS.
EDWARD FURLONG JURY TRIAL DEMANDED
Defendant
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Defendant certifies that:
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to counsel for the Plaintiff on FebruaryZr
2006.
(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 filed;
(4) The subpoena which will be served is identical to the subpoena
which is attached to the notice of intent to serve the subpoena.
onald B. Ho , squire
Attorney for Defendant
Date: L /c 8'z-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
vs.
EDWARD FURLONG
Defendant
No. 03-761 Civil
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009-21
Donald B. Hoyt, Esquire, Attorney for the Defendant, Edward Furlong, 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 of record and serve upon the undersigned an objection to the subpoena. If no
objection is made the subpoena maybe served.
Date: 'o
BLAKEY, YOST, BUPP & RAUSCH, LLP
By.
Donald B. oyt, Esquire
Attorney for Defendant
S. Ct. I.D. #18061
17 East Market Street
York, PA 17401
Telephone (717) 845-3674
Fax No. (717) 854-7839
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff No. 03-761 Civil
VS.
EDWARD FURLONG JURY TRIAL DEMANDED
Defendant
SUBPOENA TO PRODUCE DOCUMENTS OR TIIINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Custodian of Records -STATE CORRECTIONAL INSTITUTION AT HOUTZDALE
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce
the following documents or things: a complete cony of all records on Douglas Walker, DOB
05-07-67, at 17 East Market Street, York, PA 17401.
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 parry 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
Donald B. Hoyt, Esquire
17 East Market Street
York, PA 17401
S. Ct. I.D. #18061
Telephone (717) 845-3674
Attorney for Defendant
BY THE COURT:
DATE:
Seal of the Court Prothonotary/Clerk, Civil Division
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff No. 03-761 Civil
VS.
EDWARD FURLONG JURY TRIAL DEMANDED
Defendant
NOTICE
TO: CUSTODIAN OF RECORDS
STATE CORRECTIONAL INSTITUTION AT HOUTZDALE
You are required to complete the following Certificate of Compliance when producing
documents or things pursuant to this Subpoena.
CERTIFICATE OF COMPLIANCE
WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
PURSUANT TO RULE 4009.23
I,
certify to the best of my knowledge,
information and belief that all documents and things required to be produced pursuant to the
subpoena issued on have been produced.
(Person served with subpoena)
Date:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff No. 03-761 Civil
vs.
EDWARD FURLONG JURY TRIAL DEMANDED
Defendant
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
T0: Custodian of Records - LEADER INSURANCE COMPANY
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce
the following documents or things: a copy of all records pertaining to Douglas Walker,
relatin to Policy No. 137-19546-8202-001 and all revious Policies, to 17 East Market Street,
York, PA 17401.
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:
Donald B. Hoyt, Esquire
17 East Market Street
York, PA 17401
S. Ct. I.D. #18061
Telephone (717) 845-3674
Attorney for Defendant
DATE:
Seal of the Court
BY THE COURT:
Prothonotary/Clerk, Civil Division
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
No. 03-761 Civil
vs.
EDWARD FURLONG
Defendant
JURY TRIAL DEMANDED
NOTICE
TO: CUSTODIAN OF RECORDS
LEADER INSURANCE COMPANY
You are required to complete the following Certificate of Compliance when producing
documents or things pursuant to this Subpoena.
CERTIFICATE OF COMPLIANCE
WrM SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
PURSUANT TO RULE 4009.23
1,
certify to the best of my knowledge,
information and belief that all documents and things required to be produced pursuant to the
subpoena issued on have been produced.
(Person served with subpoena)
Date:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff No. 03-761 Civil
VS.
EDWARD FURLONG JURY TRIAL DEMANDED
Defendant
CERTIFICATE OF SERVICE
I hereby certify that I have this day caused a copy of the foregoing Notice of Intent to Serve
Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.2 1, to be served
upon the following person in the manner indicated below:
By First Class Mail on:
Karl E. Rominger, Esquire
ROMINGER, BAYLEY & WHARE
155 South Hanover Street
Carlisle, PA 17013
BLAKEY, YOST, BUPP & RAUSCH, LLP
By: - 1 Q-_
Norma Doll,
Dated: / " 6
' i
-1?
` ?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER .
Plaintiff No. 03-761 Civil
VS.
EDWARD FURLONG JURY TRIAL DEMANDED
Defendant
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Defendant certifies that:
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to counsel for the Plaintiff on August 2,
2007.
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate;
(3) See attached letter from Karl E. Rominger, Esquire, indicating that
he has no objection to the subpoena being issued;
(4) The subpoena which will be served is identical to the subpoena
which is attached to the notice of intent to serve the subpoena.
Ll?? X. Z161?
Donald B. Hoyt, E
Attorney for Defendant
Date:
ROMINGER & ASSOCIATES
Attorneys at Law
Karl E. Rominger Michael O. Palermo, Jr.
August 6, 2007
Donald B. Hoyt, Esquire
BLAKLEY, YOST, BUPP & RAUSCH, LLP
17 East Market Street
York, Pennsylvania 17401
RE: Walker v. Furlong
Dear Attorney Hoyt:
This letter is in regards to your letter dated August 2, 2007 which enclosed several
subpoenas, which you intend to serve.
I have no objection to any of the subpoenas being served.
Thank you for your time in this matter.
Sincerely,
2=squire
KER:bab
aTH, COPY FOR
155 South Hanover Street, Carlisle, Pennsylvania 17013 • Tel: (717) 241-6070 • Fax: (717) 241-6878
www.romingerlaw.com
ADVOCACY • ADVICE • ANSWERS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
VS.
EDWARD FURLONG
Defendant
No. 03-761 Civil
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009-21
Donald B. Hoyt, Esquire, Attorney for the Defendant, Edward Furlong, 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 of record and serve upon the undersigned an objection to the subpoena. If no
objection is made the subpoena may be served.
BLAKEY, YOST, BUPP & BAUSCH, LLP
Date: B?-
Donald B. Hoyt, Es ' e
Attorney for Defendant
S. Ct. I.D. #18061
17 East Market Street
York, PA 17401
Telephone (717) 845-3674
Fax No. (717) 854-7839
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
No. 03-761 Civil
VS.
EDWARD FURLONG
Defendant
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I hereby certify that I have this day caused a copy of the foregoing Notice of Intent to Serve
Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21, to be served
upon the following person in the manner indicated below:
By First Class Mail on:
Karl E. Rominger, Esquire
ROMINGER, BAYLEY & WHARE
155 South Hanover Street
Carlisle, PA 17013
BLAKEY, YOST, BUPP & RAUSCH, LLP
By:
i . Hilbert, Paralegal
I W
Dated:
C_ ? O
-
n
.z .-
:. 4 } _ = T
rn
O
l
y?
?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
No. 03-761 Civil
VS.
EDWARD FURLONG
Defendant
JURY TRIAL DEMANDED
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Defendant certifies that:
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to counsel for the Plaintiff on August 2,
2007.
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate;
(3) See attached letter from Karl E. Rominger, Esquire, indicating that
he has no objection to the subpoena being issued;
(4) The subpoena which will be served is identical to the subpoena
which is attached to the notice of intent to serve the subpoena.
Date: QO 7
Lzm& z 14Z
Donald B. Hoyt, uire
Attorney for Defendant
ROMINGER & ASSOCIATES
Attorneys at Law
Karl E. Rominger
August 6, 2007
Donald B. Hoyt, Esquire
BLAKLEY, YOST, BUPP & RAUSCH, LLP
17 East Market Street
York, Pennsylvania 17401
RE: Walker v. Furlong
Dear Attorney Hoyt:
Michael O. Palermo, Jr.
This letter is in regards to your letter dated August 2, 2007 which enclosed several
subpoenas, which you intend to serve.
I have no objection to any of the subpoenas being served.
Thank you for your time in this matter.
Sincerely,
re
2=squi
KER:bab
THIS CON Y FOR
155 South Hanover Street, Carlisle, Pennsylvania 17013 • Tel: (717) 241-6070 • Fax: (717) 241-6878
www.romingerlaw.com
ADVOCACY • ADVICE • ANSWERS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
VS.
EDWARD FURLONG
Defendant
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009-21
Donald B. Hoyt, Esquire, Attorney for the Defendant, Edward Furlong, 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 of record and serve upon the undersigned an objection to the subpoena. If no
objection is made the subpoena may be served.
BLAKEY, YOST, BUPP & RAUSCH, LLP
Date: &V)
No. 03-761 Civil
By.
Donald B. Hoyt, Es6ire
Attorney for Defendant
S. Ct. I.D. #18061
17 East Market Street
York, PA 17401
Telephone (717) 845-3674
Fax No. (717) 854-7839
W '
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
No. 03-761 Civil
VS.
EDWARD FURLONG
Defendant
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I hereby certify that I have this day caused a copy of the foregoing Notice of Intent to Serve
Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21, to be served
upon the following person in the manner indicated below:
By First Class Mail on:
Karl E. Rominger, Esquire
ROMINGER, BAYLEY & WHARE
155 South Hanover Street
Carlisle, PA 17013
BLAKEY, YOST, BUPP & RAUSCH, LLP
1 /111
By: 'al lel?i
Ti any 'lbert, Paralegal
Dated: ?- Ib-6
C7 ? C 7
'` - Fri
CJ3
.:
?
ry;fly
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff No. 03-761 Civil
VS.
EDWARD FURLONG JURY TRIAL DEMANDED
Defendant
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Defendant certifies that:
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to counsel for the Plaintiff on August 2,
2007.
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate;
(3) See attached letter from Karl E. Rominger, Esquire, indicating that
he has no objection to the subpoena being issued;
(4) The subpoena which will be served is identical to the subpoena
which is attached to the notice of intent to serve the subpoena
""0&
Donald B. Hoyt, squire
21 Attorney for Defendant
1
Date: 7 7
f
ROMINGER & ASSOCIATES
Attorneys at Law
Karl E. Rominger
August 6, 2007
Donald B. Hoyt, Esquire
BLAKLEY, YOST, BUPP & RAUSCH, LLP
17 East Market Street
York, Pennsylvania 17401
RE: Walker v. Furlong
Dear Attorney Hoyt:
Michael O. Palermo, Jr.
This letter is in regards to your letter dated August 2, 2007 which enclosed several
subpoenas, which you intend to serve.
I have no objection to any of the subpoenas being served.
Thank you for your time in this matter.
Sincerely,
2=squire
KER:bab
+ THM COPY FOR
155 South Hanover Street, Carlisle, Pennsylvania 17013 • Tel: (717) 241-6070 • Fax: (717) 241-6878
www.romingerlaw.com
ADVOCACY • ADVICE • ANSWERS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
VS.
EDWARD FURLONG
Defendant
No. 03-761 Civil
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND TMGS FOR DISCOVERY PURSUANT TO RULE 4009-21
Donald B. Hoyt, Esquire, Attorney for the Defendant, Edward Furlong, 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 of record and serve upon the undersigned an objection to the subpoena. If no
objection is made the subpoena may be served.
Date: lzb--)
BLAKEY, YOST, BUPP & RAUSCH, LLP
By:
DAM B. Ho , sq e
Attorney for Defendant
S. Ct. I.D. #18061
17 East Market Street
York, PA 17401
Telephone (717) 845-3674
Fax No. (717) 854-7839
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
vs.
EDWARD FURLONG
Defendant
No. 03-761 Civil
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I hereby certify that I have this day caused a copy of the foregoing Notice of Intent to Serve
Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.2 1, to be served
upon the following person in the manner indicated below:
By First Class Mail on:
Karl E. Rominger, Esquire
ROMINGER, BAYLEY & WHARE
155 South Hanover Street
Carlisle, PA 17013
BLAKEY, YOST, BUPP & RAUSCH, LLP
By:
T ffany . 'lbert, Paralegal
???/j 6t)--)
Dated:
r.._
w
t-_ N
- GO
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
No. 03-761 Civil
VS.
EDWARD FURLONG
Defendant
JURY TRIAL DEMANDED
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Defendant certifies that:
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to counsel for the Plaintiff on August 2,
2007.
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate;
(3) See attached letter from Karl E. Rominger, Esquire, indicating that
he has no objection to the subpoena being issued;
(4) The subpoena which will be served is identical to the subpoena
which is attached to the notice of intent to serve the subpoena.
Donald B. Hoyt,
Attorney for Defendant
Date:
ROMINGER & ASSOCIATES
Attorneys at Law
Karl E. Rominger Michael O. Palermo, Jr.
August 6, 2007
Donald B. Hoyt, Esquire
BLAKLEY, YOST, BUPP & RAUSCH, LLP
17 East Market Street
York, Pennsylvania 17401
RE: Walker v. Furlong
Dear Attorney Hoyt:
This letter is in regards to your letter dated August 2, 2007 which enclosed several
subpoenas, which you intend to serve.
I have no objection to any of the subpoenas being served.
Thank you for your time in this matter.
Sincerely,
2=squire
KER:bab
!=TH,S COPY FOR
155 South Hanover Street, Carlisle, Pennsylvania 17013 • Tel: (717) 241-6070 • Fax: (717) 241-6878
www.romingerlaw.com
ADVOCACY • ADVICE • ANSWERS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
VS.
EDWARD FURLONG
Defendant
No. 03-761 Civil
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009-21
Donald B. Hoyt, Esquire, Attorney for the Defendant, Edward Furlong, 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 of record and serve upon the undersigned an objection to the subpoena. If no
objection is made the subpoena may be served.
Date:
BLAKEY, YOST, BUPP & BAUSCH, LLP
onald B. Hoyt, Esquire
Attorney for Defendant
S. Ct. I.D. #18061
17 East Market Street
York, PA 17401
Telephone (717) 845-3674
Fax No. (717) 854-7839
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff No. 03-761 Civil
VS.
EDWARD FURLONG JURY TRIAL DEMANDED
Defendant
CERTIFICATE OF SERVICE
I hereby certify that I have this day caused a copy of the foregoing Notice of Intent to Serve
Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21, to be served
upon the following person in the manner indicated below:
By First Class Mail on:
Karl E. Rominger, Esquire
ROMINGER, BAYLEY & WHARE
155 South Hanover Street
Carlisle, PA 17013
BLAKEY, YOST, BUPP & RAUSCH, LLP
By
iff R. Hilbert, Paralegal
Dated: Y /)--/ ' d?
K ;
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
VS.
EDWARD FURLONG
Defendant
No. 03-761 Civil
JURY TRIAL DEMANDED
CEItTII'ICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Defendant certifies that:
(1) A notice of intent to serve the subpoena with a copy of the subpoena
attached thereto was mailed or delivered to counsel for the Plaintiff on September
21, 2007.
(2) A copy of the notice of intent, including the proposed subpoena, is
attached to this certificate;
(3) See attached letter from Karl E. Rominger, Esquire, indicating that
he has no objection to the subpoena being issued;
(4) The subpoena which will be served is identical to the subpoena
which is attached to the notice of intent to serve the subpoena.
Wald B. o wire
Attorney for Defendant
Date: 9 - ?k/- C2' C)6 7
09-21-'07 15,58 FROM-ROMINGER & ASSOC 7172416278 T-735 P221/221 F-847
ROMINGER & A:sSOCIATES
Attorneys at Law
Karl E. Rominger Michael O. Palermo, Jr.
September 21, 2007
VIA Facsimile Only (717) 854-7839
Donald B. Hoyt, Esquire
17 East Market Street
York, Pennsylvania 17401
RE: Your Insured - Edward Furlong
Our client - Douglas Walker
Date of boss - 2/22/01
Dear Attorney Hoyt:
I am in receipt of your correspondence dated September 21, 2007, regarding the
above referenced matter. I have no objection to the subpoena which was attached.
Should you have any questions, please do not hesitate to contact the office.
Sincerely,
?1E. ltominger, Esquire
KER/tip
155 South Hanover Street, Carlisle, Pennsylvania 17013 - Tel: (717)241-6070 • Fax: (717) 241-6878
www.romingerlaw.com
ADVOCACY 9 ADVICE 0 ANSWERS
Albert G. Blakey
Donald B. Hoyt
Charles A. Rausch
Bradley J. Leber
David A. Mills
John J. Baranski, Jr.
Nicole M. Ehrhart
Carolyn J. Pugh
Blakey, Yost, Bupp & Rausch, LLP
Attorneys at Law
September 21, 2007
Karl E. Rominger, Esquire
ROMINGER & ASSOCIATES
155 South Hanover Street
Carlisle, PA 17013
Re: Our Insured- Edward Furlong
Your Client Douglas WaHwr
D/L- 2/22/01
Dear Mr. Rominger:
of counsel
David Wm. Bupp
retired
Donald H. Yost
I attach a Notice of Intent to serve a subpoena for documents on the State Correctional Institution
at Houtzdale. Since time is of the essence, could you please issue a letter stating that you have
no objection to the subpoena as soon as possible and fax it to me at (717) 854-7839?
Thank you.
Very truly yours,
Tiffany R lirt, Paralegal
BLAKEY, YOST, BUPP & RAUSCH, LLP
TRH/mos
Enclosure:
CC. Lee Ann Oatman
Claim No. OP201083X
VIA FAX AND FIRST CLASS MAIL
17 East Market Street, York PA 17401 717-845-3674 Fax 717-854-7839
Visit our website at www.blakeyyost.com
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
VS.
EDWARD FURLONG
Defendant
No. 03-761 Civil
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009-21
Donald B. Hoyt, Esquire, Attorney for the Defendant, Edward Furlong, 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 of record and serve upon the undersigned an objection to the subpoena. If no
objection is made the subpoena may be served.
Date: '4j - )- / -
BLAKEY, YOST, BUPP & RAUSCH, LLP
By: r 7Z,
B. oyt,
Attorney for Defendant
S. Ct. I.D. #18061
17 East Market Street
York, PA 17401
Telephone (717) 845-3674
Fax No. (717) 854-7839
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DOUGLAS WALKER
Plaintiff
VS.
EDWARD FURLONG
Defendant
No. 03-761 Civil
JURY TRIAL DEMANDED
TO: Custodian of Records - STATE CORRECTIONAL INSTITUTION AT HOUTZDALE
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce
the following documents or things: a conA to ceoy of aH reeorda on Door Wafter. DOB
0547-67. !fit March 1. 2006, to the grant at 17 East Market Street, York, PA 17401.
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:
Donald B. Hoyt, Esquire
17 East Market Street
York, PA 17401
S. Ct. I.D. #18061
Telephone (717) 845-3674
Attorney for Defendant
DATE:
Seal of the Court
BY THE COURT:
Prothonotary/Clerk, Civil Division
C? C=
-V (73
M r; s`e t
? tv
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUTNY, PENNSYLVANIA
DOUGLAS WALKER
Plaintiff
No. 03-761 Civil
V.
EDWARD FURLONG
Defendant
TO THE PROTHONOTARY:
JURY TRIAL DEMANDED
PRAECIPE TO DISCONTINUE
Please mark the above captioned matter as settled and discontinued with prejudice.
Respectfully submitted,
Rominger & Associates
Date: October 31, 2007
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID # 81924
Attorney for Ptaintiff.
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