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HomeMy WebLinkAbout01-5846IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION KIMBERLY GOODLING 57 Village Court Mechanicsburg, PA 17050 PLAINTII~F V. NANCY L. STEINBERGER 114 Peach Lane Carlisle, PA 17013 DEFENDANT FILE NO.: ~ ~2~k~ CIVIL ACTION: PRAECIPE FOR SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue summons in the above captioned action, which arises from a motor vehicle accident that occurred on October 9, 1999. Writ of Summons shall be issued and forwar~ ~ Date:/gl ~ ~t~/. Dusan Bratic, Esq. ID 19249 101 SouthU.S. Route 15 Dillsburg, PA 17019 (717) 432-9706 SUMMONS IN CIVIL ACTION TO: NANCY L. STEINBERGER 114 Peach Lane Carlisle, PA 17013 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. /~tf.~l_~_ ~. ~l~t~ l~ro)l~n~taw/Clerk, ~¢ ~is~' ~ , 01HB-00151 BRATIC and PORTKO Dusan Bratic, Esquire 101 Office Center, Suite A 101 South U.S. Route 15 DiHsburg, PA 17019 Attorney for Plaintiff KIMBERLY GOODLING, (PLA~I~) VS. NANCY L. STEINBERGER, (OV.~NOANT) IN THE COURT OF COMMON PLEAS CLqt~ERLAND COUNTY~ PENNSYLVANIA No. O1 = 5846 CIVIL ACTION= LAW JURY TRIAL DEMANDED PRA CIPE TO DISCONTtNUE TO ~ PROTHONOTARY: Please mark the above-captioned case settled, discontinued and ended. Date: By: // .... l~usan Bratic, Esquire 101 Office Center, Suite A 101 South U.S. Route 15 Attorney for Plain. Off Court I.D. ? 9~ ~ 01IIB-00151 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L. Steinber~ KIMBERLY GOODLING~ (PL INT ) VS. NANCY L. STEINBERGER, (DEFENDANT) IN Tm~ COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 5846 CIVIL ACTION- LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendant, Nancy L. Steinberger. Date: October 24. 2001 i~.spe~ully submitted, LAW OFFICES OF JACOBS & SABA Attorney for Defendant Identification No.58867 01HB-00151 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Flirt, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L. Steinberger KIMBERLY GOODLING~ (PLAINX~) VS. NANCY L. STEINBERGER~ (DE~OANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA No. 01 - 5846 CIVIL ACTION- LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rick~rds, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he mused a true and correct copy of l~flIIy~,~g~a~ to be served by regular fa'st class mail upon: Dusan Bratic, Esquire 101 South U.S. Route 15 Dillsburg, PA 17019 Dated: October24.2~l Girard E. Rickards, Esquire Attorney for Defendant O1HB-O0151 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L. Steinberg~ KIMBERLY GOODLING~ (PLAINTIFF) VS. NANCY L. STEINBERGER, (DEFENDANT) IN TH~ COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 5846 CIVIL ACTION- LAW JURY TRIAL DEMANDED PRAECIPE FOR RUL TO FILE COMPLAINT TO ~ PROTHONOTARY: Please enter a RUt.g upon Plaintiff to file a Complaint within twenty (20) days hereof or suffer the entry of a Judgment of Non Pros. Date: October 24. 2001 Attorney for Defendant Nancy L. Steinberger RULE TO FILE COMPLAINT AND NOW, this ~A'q~. day of _f')~ ~r~ ,2001 a RLS.E is hereby entered upon the plaintiff to fde a Complaint here'm within twenty (20) days after service hereof or suffer the entry of a ludgment of Non Pros. PROTHOI~OT~ 011-1B-00151 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L. Steinberg~ KIMBERLY GOODLING~ (PLA~rI~) VS. NANCY L. STEINBERGER~ (DEFENDANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5846 CML ACTION- LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of Praecipe for Rule to File Complaint to be served by regular lb-st class mail upon: Des,an Bratic, Esqu'Lre 101 South U.S. Route 15 Dfllsburg, PA 17019 DaSd: Oetober24.2~l Girard B. Rickards, Esquire Attorney for Defendant SHERIFF'S RETURN - REGULAR CASE NO: 2001-05846 P COMMONWEALTH OF PENNSYLVANIA: COIINTY OF CUMBERLAND GOODLING KIMBERLY VS STEINBERGER NANCY L DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon STEINBERGER NANCY L the DEFENDANT , at 114 PEACH LANE CARLISLE, PA 17013 NANCY L STEINBERGER at 2132:00 HOURS, on the 15th day of October , 2001 by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.20 Affidavit .00 Surcharge 10.00 .00 33.20 Sworn and Subscribed to before me this /[~ day of 0~.~ 3 ~t A.D. Prothonotary So Answers: R. Thomas Kline 10/16/2001 DUSAN BRATIC & ASSOCIATES By: Deputy Sheriff CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: KIMBERLY GOODLING -VS- NANCY L. STEINBERGER COURT OF C0~940N PLEAS TERM, CASE NO: 01-5846 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, Esq. 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 days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/26/2001 MCS ,on behalf .~f ~ Attorney for DEFENDANT DEll-300275 7 9 310 --LO 1 .COlVilVION~J]ZALTH OF PENNSYLVANIA COUNTY OF CI/[VIBERLAND IN THE MATTER OF: KIMBERLY G00DLING -VS- NANCY L. STEINBERGER COURT OF C0~gt0N PLEAS TERM, CASE NO: 01-5846 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 SEIDLE MEHORIAL HOSPITAL - HEDICAL BRUCE MACKELLAR, M.D. MEDICAL TO: DUSAN BRATIC, ESQUIRE MCS on behalf of GIRARD E. RICKARDS,. ESq. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersiEned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completinE the attached counsel card and returninE same to HCS or by contactinE our local HCS office. DATE: 12103/2001 CC: GIRARD E. RICKARDS, ESQ. INGRID LAPTOS - 01HB-00151 HCS on behalf of GIRARD E. RICKARDS, ESq. Attorney for DEFENDANT Any questions regarding this matter, contact TH~ MCS GROUP INC. 1601 HARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-172098 79310--C02 -COMMONIatEALTH OF PE~$Y'LVANI.% COUNTY OF CUMBERL-X.ND KIMBERLY GOODLING VS NANCY L. STEINBERGER File No. 01-5846 SUBPOENA TO PRODUCE DO~'TS OR T'rtlNG5 FOR DISCOVERY PURSUANT TO RULE 4009 '~'~ TO: CUSTODIAN OF RECORDS FOR: SEIDLE MEMORIAL HOSPITAL Wi:bin r*'e.? ~) days ~et se~'ice of t~s subp~ you ~t ord~ ~ ~e ~un to pto~uc~ the following ~ocuments or :,~in $~ SEE ATTACHED at MCS GROUP INC.. 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA 19109 ceni~cate ~ ~mmplian~e. re ~he p~ ~m~ this teque~ ac the ad~ advice. ~e ~monable cost of ptep~n& the copi~ or produc~n& the ~n~ If'.v:u fa./]..m '.'--':duce the d~ments or th/n~ requited by. h/s suBpcer, a. w'it.'".An rwenm,.("~l days. aP.e,., s se.",'. Ce. be p~, ser','m~ ::'.:s s:::peena may seek a ~m,u't order ¢ompeilin$ y~u to comply veit.~ it. T'dtS SL'B?OKNA WAS ISSUED AT T'rIE R£QLr~'-I' OF ~ ~C)LLOWIN'G PERSON: NAM~ GIRARD E. RICKARDS, ESOUIRE ADDR~_~: 214 SENATE AVENUE. SUITE CAMP HILL PA 17011 T~-'?.u. ON:- (21~) 246-0900 SUPR~Mi COUirr ID ATTOkN~--f FO~: THE DEFENDANT 12/26/2001 SeG ortho Cam't EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SEIDLE MEMORIAL HOSPITAL - 120 S. FILBERT STREET MECHANICSBURG, PA 17055 RE: 79310 KIMBERLY L. GOODLING Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the l~resent. Subject: KIMBERLY L. GOODLING 7073 CARLISLE PIKE, CARLISLE, PA 17013 Social Security #: 208-56.8350 Date of Birth: 05-12-1970 SU10-342510 79310--L01 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KIMBERLY GOODLING TERM, -VS- CASE NO: 01-5846 NANCY L. STEINBEEGER As a prerequisite to service of a subpoena for documents and thinEs pursuant to Rule 4009.22 MCS on behalf of GIRARD E. EICKARDS, Esq. 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 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. MCS on behalf of DATE: 12/26/2001 GIRARD E. RICKARDS, Esq. Attorney for DEFENDANT DEll-300276 79310--L02 COlvIi~iOlq'wq~ALTH OF PENNSYLVANIA COUNTY OF CLrl~IBERLAND IN THE MATTER OF: KIMBERLY G00DLING -VS- NANCY L. STEINBERGER COURT OF COMMON PLEAS TERM, CASE NO: 01-5846 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 SEIDLE MEMORIAL HOSPITAL - MEDICAL BRUCE MACKELLAR, M.D. MEDICAL TO: DUSAN BRATIC, ESQUIRE MCS on behalf of GIRARD E. RICKARDS, ESq. intends to serve a subpoena identical to the one that is attached to this notice. You have tventy (20) days from the date listed beio~ in which to file of record and serve upon the undersigned an objection to the subpoena. If the t~enty day notice period is waived or if no objection is made, then the subpoena may be served. Coa~lete copies of any reproduced records may be ordered at your expense by completinE the attached counsel card and returninE same to MCS or by contacting our local MCS office. DATE: 12;03/2001 CC: GIRARD E. RICKARDS, ESQ. INGRID LAPTOS - 01HB-00151 MES on behalf of GIRARD E. RICKARDS, ESq. Attorney for DEFENDANT Any questions regarding this matter, contact Th~HCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-172098 79310--C02 ~0MMON'WEALTH OF PE~SYT..VANIA COUNTY OF CUMBERLA.ND KIMBERLY GOODLING VS NANCY L. STEINBERGER File No. 01-5846 SUBPOENA TO PRODUCE DO~'TS OR THINGC FOR DISCOVERY PURSUAN'F TO RULE 4009 ~'~ TO: CUSTODIAN OF RECORDS FOR: BRUCE MACg~T.~.A~ M.D. Wi:him ~ve..-~..- I~n) days Ltl'er sen'ice of th.~s subpoena, you ue ordered by ~he c~un to produce the fo;lowing documents or :hinss: SEE ATTACHED ' at MCS GROUP INC., 1601 MARKET STREET. SUITE 800. PHILADELPHIA PA 19103 You may dc~,'et or mail feeble copi~ of the documen~ or produce th.i.,'~l I~aested b.v this subpo~nL together with the certificate o'.'compliance, to the panT. malrdn$ this request at the adc~,"~u IL~ed alive. You have the right to see~ in advance, the ."~.monable cost of prepm'in[ the copie,J or producing the t'hin~l If you ,~1 to .:voduce the documents or thin~ required by t~s subpoena, within nven~ (2~1} days after its sec'ice, the patty. servin~ :~.is ~poena may s~k a cm~"~ order compellins you to comply with P_ THIS SL'~PO~/A WAS ISSUED AT T'ME REQUF. ST OF ~ FOLLOWING P£R$ON: NAM~. GIRARD E. RICKARDSt ESQUIRE ADDR~..~.~: 214 SENATE AVENUE. SUITR 50q CAMP HILL PA 17011 TELEPHON-'- (215) 246-0900 SU?RF..M~: COURT ID ~ AI-tOR.N~' FOR: THE DEFENDANT 12/26/2001 Se~ ofthe ( -'.q. 7/9/-} EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BRUCE MACKELLAR, M.D. 122 SOUTH FILBERT STREET MECHANICSBERG, PA 17055 RE: 79310 KIMBERLY L. GOODLING Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: KIMBERLY L. GOODLING 7073 CARLISLE PIKE, CARLISLE, PA 17013 Social Security #: 208-56-8350 Date of Birth: 05-12-1970 SU10-342512 7 9 3 1 0 --LO2 01HB-00151 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0958 Attorneys for Defendant Nancy L. Steinberger KIMBERLY GOODLING~ (PLAINTIFF) VS. NANCY L. STEINBERGER, (DEIq NOANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 5846 CML ACTION- LAW JURy TRIAL DEMANDED PRAECIPE TO FILE AFFIDAVIT OF SERVICE TO THE PROTHONOTARY: Kindly file the attached Affidavit of Service to the Rule to File Complaint fried with this Court on or about October 25, 2001 in the above referenced matter. Date: January_ 14, 2002 Respectfully submitted, Girard E. Richrds, Esquire Attorney for Defendant 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number (717) 731-0988 Identification No. 58867 01HB-00151 LAW OI~ICES OE JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L. Steinberg~ KIMBERLY GOODLING, (rLA~NrIm VS. NANCY L. STEINBERGER~ (DE~NDA~T) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01-5846 CIVIL ACTION- LAW JURY TRIAL DEMANDED AFIfl~AVIT OF SERVICE I, Girard E. Rickards, Esquire, attorney for Defendant Nancy L. Steinl~rger, do hereby affn'm that I received the below attached return receipt of the Rule to File Complaint sent by Certified Mail, Return Receipt Requested, which return receipt appears to contain the signature of Sherry_ Fitzkee, an employee or agent of Dusan Bmfic, Esquire. The undersigned understands that the statements therein are made subject to the penaltie~ of 18 Pa.C.S.A. §4904 relatln~ to unswom falsification to authorities. · · Cew~31e~ i~m~ 1, 2, a~d 3. Also comptete item 4 if Restricted Delivery is desired. s Print your name and address on the reveme so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Nt~eAddressed to: Dusan Bratic, Esquire 101 South U.S. Route 15 Dillsburg, PA 17019 A. Received by (P/ease Ptfnt C~eriy) 3ellve~ [] Addressee ~om item 17 []Yes [] No l~l"~edtfled Mall [] Express Mall [] Registered [] Return Receipt for Merchandies [] Insured Mail [] C.O.D. 4. Restricted DelNef~? ~-xtm~F6e) [] Yes 01BB-0015T Rule to F~'te C~p~tat PS Fo~n 3811, Jay 1999 Date: January_ 14. 2002 Girard E. Rickards, Esquire Attorney for Defendant O1HB-O0151 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 505 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L. Steinber§~ KIMBERLY GOODLING~ (rLA I ) VS. NANCY L. STEINBERGER~ (DEFE~OANr) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 5846 CIVIL ACTION- LAW JURy TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of Praecipe to File Affidavit of Service to be served by regular first class mail upon: Dusan Bratic, Esquire 101 South U.S. Route 15 Dillsburg, PA 17019 Dated: ~Ianuary 14. 2002 Girard E. Rickards,'~quim Attorney for Defendant KIMBERLY GOODLING Plaintiff NANCY L. STEINBERGER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 01-5846 JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en law paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar trna comparencia escrita o en persona o con tm abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas em contra de su persona. Sea avisado que si usted no se defiende, ia corte tomara medidas y puede continuer ia demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas law provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE ELDINERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 KIMBERLY GOODLING Plaintiff NANCY L. STEINBERGER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CWIL ACTION LAW NO. 01-5846 JURY TRIAL DEMANDED COMPI,AINT NOW COMES the Plaintiff, Kimberly Goodling, by and through her counsel, Bratic & Portko and make the within Complaint against the Defendant, Nancy L. Steinberger, as follows: 1. Plaintiff, Kimberly Goodling, is an adult individual residing at 3S Spruce Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Nancy L. Steinberger, is an adult individual residing at 114 Peach Lane, Carlisle, Cumberland County, PA 17013. 3. The facts and occurrences hereinafter related took place on or about October 9, 1999 at or about 6:00 p.m. at or about Carlisle Pike, New Kingston, Cumberland County, Pennsylvania. 4. At the aforesaid time and place, Plaintiff, Kimberly Goodling, was the passenger in an automobile being driven by her sister, Darlene Miller. 5. At the aforesaid time and place the automobile in which Kimbefly Goodiing was a passenger was traveling South on Carlisle Pike in the left hand lane of the two Southbound lanes, when it was struck by Defendant Nancy L. Steinberger's vehicle as it attempted to make a left hand turn from the right hand lane. 6. At the aforesaid time and place Defendant, Nancy L. Steinberger, was the operator of a vehicle, which was traveling South on Carlisle Pike in the right hand lane of two Southbound lanes. Defendant, Nancy L. Steinberger, was traveling in the same direction of travel as the vehicle in which Plaintiff was a passenger in the lane to the right of Plaintiff's lane of travel. The Defendant attempted to make a left hand mm from the right lane and in so doing struck the rear passenger side of the vehicle in which the Plaintiff was a passenger. This impact caused the vehicle in which Plaintiff was a passenger to go out of control and end up on the left side of the highway across the street in a grassy area beside the road. 7. At that time and place the vehicle operated by Defendant, Nancy L. Steinberger, was caused or allowed to go out of control smashing into the vehicle operated by Darlene Miller and causing the Plaintiffto sustain the serious injuries set forth below. 8. Said collision and all of the herein mentioned injuries and damages sustained by Plaintiff are the direct result of the negligent, careless and reckless manner in which Defendant, Nancy L. Steinberger, operated her vehicle as follows: (a) In failing to keep proper and adequate control over her vehicle; (b) In driving her vehicle in a reckless manner and with careless disregard for the rights and safety of others and in otherwise operating her vehicle upon the highway in a manner endangering persons and property in violation of 75 Pa.C.S.A. Section 3714; (c) In failing to apply her brakes in time to avoid striking the vehicle in which Plaintiff was a passenger; (d) In being inattentive and failing to maintain a sharp lookout of the road and the surrounding traffic conditions in violation of 75 Pa.C.S .A. Section 3303; (e) Failing to operate her vehicle in accordance with existing traffic conditions and traffic controls and in violation of 75 Pa.C.S.A. Section 3303; (f) In attempting to make a left hand mm without being in the extreme left-hand lane in violation of 75 Pa.C.S.A. Section 3331(b). (g) Otherwise operating her vehicle in a careless, reckless, and negligent manner and in a manner violating the Motor Vehicle Code of the Commonwealth of Pennsylvania. 9. As a result of the aforementioned accident, Plaintiff, Kimberly Goodling, sustained painful and severe injuries including but are not limited to: (a) Abrasions, contusions and injuries to her muscles and nerves; (b) Injuries to her knee (medical records say fight knee your notes say left); (c) Neck and back injuries; (d) Temporomandibular joint injuries; (e) Headaches; 10. By reason of the aforesaid injuries sustained by Plaintiff, Kimberly Goodling, she was forced to incur liability for medical treatment, medications, hospitalizations and similar miscellaneous expenses, including replacement services, in an effort to restore herself to health, and claim is made therefore. 11. Because of the nature of her injuries, Plaintiff, Kimbefly Goodling, has been advised, and therefore, avers the she may be forced to incur similar expenses in the future, and claim is made therefore. 12. As a result of the aforesaid injuries, Plaintiff, Kimberly Goodling, has undergone and in the future will undergo a great physical and mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefore. 13. As a result of the aforesaid injuries, the Plaintiff, Kimberly Goodling, has been and in the future will be subject to great humiliation and embarrassment, and claim is made therefore. 14. As a result of the aforementioned injuries, Plaintiff, Kimberly Goodling, has sustained work loss, loss of opportunity and a permanent diminution of her earning power and capacity, and claim is made therefore. 15. As a result of the aforesaid injuries, Plaintiff, Kimbefly Goodling, has sustained uncompensated work loss, and claim is made therefore. 16. Plaintiff, Kimberly Goodling, continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefore. WHEREFORE, Plaintiff, Kimberly Goodling, demands judgment of the Defendant, Nancy L. Steinberger, in an amount in excess of Thirty-Five Thousand and 00/100 ($35,000) Dollars and in excess of the amount requiring compulsory arbitration. Dated: i:an~m ID # 19249 101 South U.S. Route 15 Dillsburg, PA 17019 (717) 432-9706 Attorney for Plaintiff VERIFICATION I, K~mh~rlyGoodlinq hereby acknowledge that I am the Plaintiff of Civil Actioq 01q5846 , that ! have read the ~oregoing Complaint and that the facts stated therein 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. Dated: ~lq~in~ KIMBERLY GOODLING Plaintiff NANCY L. STEINBERGER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 01-5846 JURY TRIAL DEMANDED I HEREBY CERTIFY that a true and correct copy of the foregoing Complaint was furnished by U.S. Mail, first class, postage prepaid on this /7 day of January 2002, to: Dated: Girard E. Rickards, Esquire Jacobs & Saba 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 7 01HB-00151 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nanc~ L. Steinberg~r KIMBERLY GOODLING~ (PLAINTIW) VS. NANCY L. STEINBERGER, (OE~NOA~T) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 5846 CML ACTION- LAW JURY TRIAL DEbIANDED NOTICE YOU HAVE BI~.~N SUED IN COURT. If you wish to defend again~ the claims set forth in the following pages, you must take action within twenty (20) days after this Answer with NeW Matter of Defendant Nancy L. Steinber~er to Plaintiff's Complaint and N0~iq~ are served by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the court without further notice for any money claimed in the Answer with New Manet of Defendant Nancy L. Steinber~er tO Plaintiff' s Complaint or for any other claim or relief requested by the Plaintiffs. 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 OR CANNOT AFFORD ONE, GO TO OR 'rRI.I~.PHONE THE OFFICE SET FORTH BRI.OW TO FIND OUT WI-~.KE YOU CAN GET LEGAL I-~.l.p. CUMBERLAND COUNTY Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 01HB-00151 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L. Steinberg, KIMBERLY GOODLING~ (PLAINTI~) VS. NANCY L. STEINBERGER, (DEFENDANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 5846 CML ACTION- LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANT NANCY L. STEINBERGER TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Nancy L. Steinberger, by and through her attorney, Girard E. Rickards, Esquire, in support of Answer with New Matter of Defendant Nancy L. Steinberger to Plaintiff's Complaint hereby avers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. ARer reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 4. Therefore, each and every averment of paragraph 4 is specifically denied and strict proof thereof is demanded at the time of trial. 5. Denied pursuant to Pa.R.C.P. 1029(e). 6. It is admitted that at the aforesaid time and place, Defendant Nancy L. Steinberger was the operator of a vehicle traveling south on the Carlisle Pike. The remaining averments of paragraph 6 are denied pursuant to Pa.R.C.P. 1029(e). 7-16. Denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendant Nancy L. Steinberger respectfully requests your Honorable Court to Dismiss the Plaintiff's Complaint with prejudice. NEW MATTER 17. The Plaintiffs' claims for medical expenses and/or wage loss are barred, or should be reduced in accordance with {}1722 of the Pennsylvania Motor Vehicle Financial Responsibility Act. 18. The Plaintiffs' claims made be barred by the limited tort option of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, Defendant Nancy L. Steinberger respectfully requests your Honorable Court to dismiss the Plaintiff's Complaint with prejudice. Date: February_ 22. 2002 Respectfully submitted, ~ E. Rickards, Esquire Attorney for Defendant Nancy L. Steinberger Identification No. 58867 01I-~-00151 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L. Steinber~ KIMBERLY GOODLING, (PLAINTIFF) VS. NANCY L. STEINBERGER, IN THE COURT OF COMMON PLEAS CWMBERLAND COUNTY, PENNSYLVANIA No. 01 - 5846 CIVIL ACTION- LAW JURY TRIAL DEMANDEO VERIFICATION I, Nancy L. Steinberger, verify that the statements made in the foregoing Answer with New Matter of Defendant Nancy L. Steinber~er to plaintiff's Comolaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Dated: 01ItB-00151 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L. Steinberg~ KIMBERLY GOODLING, (PLAINTIFF) VS. NANCY L. STEINBERGER~ (DEFENDANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 5846 CML ACTION- LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of Answer with New Matter of Defendant Nancy L. Steinber~er to Plaintiff's Complaint to be served by regular first class mail upon: Dusan Bratic, Esquire 101 South U.S. Route 15 Dillsburg, PA 17019 Dated: February_ 22. 2002 Girard E. Rickards, Esquire Attorney for Defendant 0 II-IB-00151 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite S03 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L. Steinberg~ KIMBERLY GOODLING~ (PLAINTIFF) VS. NANCY L. STEINBERGER~ (DEFENDANT) IN TH~ COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01-5846 CIVIL ACTION = LAW JURY TRIAL DEMANDED DEFENDANT'S MOTION TO COMPEL DISCOVERY 1. This lawsuit was commenced by Praecipe for Writ of Summons on October 9, 200 I. 2. The PlaintiWs Complaint was served on or about January 19, 2002. 3. This lawsuit arises from a motor vehicle accident that occurred on October 9, 1999, from which the Plaintiff alleges that she sustained personal injuries. 4. On October 23, 2001, the Defendant served upon Plaintiff's counsel a set of Interrogatories. A true and correct copy of the Defendant's Interrogatories to the Plaintiff are attached hereto as Exhibit "A" and incorporated herein by reference. 5. On October 23, 2001, the Defendant served upon Plaintiff's counsel a Request for Production of Documents. A true and correct copy of the Request for Production of Documents is attached hereto as Exhibit "B" and incorporated herein by reference. 6. As of this date, the Plaintiff has failed to provide either responses or objections to any of the Defendant's requested discovery. 7. The Plaintiff's answers to Interrogatories and response to Request for Production of Documents are overdue by several months. 8. The Plaintiff's failure to identify witnesses and evidence in support of her claim is precluding the Defendant from preparing an appropriate defense and in investigating the Plaintiff's WHEREFORE, Defendant Nancy Steinberger respectfully requests your Honorable Court to enter an Order compelling the Plaintiffto serve answers to Interrogatories and a response to Request for Production of Documents by a date certain, or suffer sanctions pursuant to Pa.R.C.P. 4019. The Defendant further prays this Honorable Court to declare the period of time fi'om November 9, 1999 until the Plaintiff's discovery responses are served as a period of delay attributable to the Plaintiff for the purposes of any future Rule 238 damages. Date: M 2 2 2 Respectfully submitted, LAW OFHCES OF JACOBS & SABA By: l E. Rickards, Esquire Attorney for Defendant Identification No.58567 2 Exhibit A OIH~-O01$1 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 - -TTclephone Number: (717) 731-0955 'Attorneys for Defendant Nancy L. Steinberge KIMBERLY GOODLING, (PLAINT,FF) VS. NANCY L. STEINBERGER, (DEFENDANT) IN TH~ COURT OF COMMON PLEAS ~ERLAND COUNTY, PENNSYLVANIA No. 01-5846 CIVIL ACTION - LAW JURY TRIAL DEMANDED INTERRoGATORIF~S ADDRESSED TO: I~imberly Goodllng, Plaintiff e/o Dusan Bratic, Esquire 101 South U.S. Route 15 Dillsburg, PA 17019 Attorney, for Plaintiff The Defendant propounds the following Interrogatories to be answered under oath pursuant to Pa. R.C.P. 4005, 4006 by the Plaintiff(s) within thirty (30) days after ~ervice. The foregoing Interrogatories are to be regarded as continuing and you are requested to provide, by way of supplementary answers thereto, such additional information as may hereafter be obtained by you, or any person on your behalf, which will augment or otherwise modify any answers now given to the foregoing Interrogatories pursuant to Pa. R.C.P. 4007.4. Such supplemental responses are to be served upon the Defendant seasonai>~y after receipt of such information. 1. PERSONAL INFORMATION: PLEASE PROVIDE 'r~ FOLLOWING INFORMATION FOR EACH PLA1Ni'I~'~' INVOLVED IN ACTION: (A) FULL NAME AND ANY PRIOR NAMES USED FROM TiiE TIME OF 'l'l:u~ INCIDENT FOR WHICH 'l'~ ACTION IS BROUGHT. (B) CURRENT ADDRESS AND ANY PRIOR ADDRF_~SES USED FROM TI:I.E TIME OF 'l'H~ INCIDENT FOR WHICH 'i'mS ACTION IS BROUGHT. (C) DATE OF BIRTH. (o) SocoJ~ SECtaUTr N~. 2. CURRE~ EMPLOYMENT: FOR EACH l~r~'~TM PLEASE STATE: (A) Cu~ PLACE OF E2glPLOYMF, NT, PO~i'ilON AND LENGTH OF CU~ EMPLOY~IENT; AND (B) T~tu PLACE OF E1V~LOYMENT AND PO~IJliON AT Tl:t~ TIME OF 'I'I:iE 1NCIDENT~ IF DI~'~'iZlm, ENT. 3. INJUP. mS: DESCRIBE ~ARATELY EACH INJIJRY EACH PLAIN'I~{C' SUSTAINED ][lq THE INCIDENT AND '1'~ APPROXIMATE DATE ON WHICH EACH PLAINTIFF RECOVERED FROM EACh'SUCH INJURY. 4. HEALTI-~ CARE PROVIDERS: IDENI't~'Y EACH HEALTH CARE PROVIDER WHO HAS EXAMINED, TREATED OR RENDERED SERVICES TO EACH PLAINTI~I,' BECAUSE OF Tills INCIDENT, INCLUDING THE DATES OF SUCH SERVICES AND 'l'H~ CHARGES FOR SA_ME. MEDICAL EXPENSES AND INSURANCE PAYMENTS: STATE 'lll~ TOTAL AMOUNT OF MEDICAL EXPENSES INCURRED BY EACH PLAINTI~'~' THAT RELATES TO 'rm~ INCIDENT, '1~ AMOUNT COMPENSA't~.z3 BY FIRST PARTY THE AMOUNT~ IF ANY~ SUBJECT TO A LIFAI OF ANY SORT~ 'l~l~.; IDEN'Ill'I( (INCLUDING'IH.It NAME~ ADDRESS~ AND POLICY NUMBER) OF ANY I.I'x~IHOLDER~ AND 1~ AMOUNT CLAI~:~ TO BE RECOVIiJRA. BLE AT TRIAL. 6. TERMINATION OF MEDICAL SERVICES: WHEN AND BY WHOM WAS EACH PLAIiN'I'I.~ ~' LAST E~G~M]~ED OR GIVEN MEDICAL ATI'ENTION FOR l'l:l~ INJURIES RECEIVED IN '1'- 1.~ INCID]~F.9 7. CONTINUATION OF MEDICAL SERVICES: IF THE PLAIi~'tl~' IS STILL BEING TREATIe~O FOR 'l'l:ll~ INJURIES RECeivED IN ']'H I,'~ INCIDEIN'T~ IDENT/~'I~ BY WHOM AND STATE HOW FREQUENTLY SUCH TREATMENTS ..ARE BEING GIVEN NOW~ TltE NATURE OF '1t!~ TREATMENT BEiI~G ADMINL~-II~tED~ AND 'latz EXTkNT TO WH/CH TREA~ WILL BE REQUIRED IN 't'tl.~ FUTURE, 8. PRIOR CONDITIONS: ~,XPLAIN ALL PRIOR HEALTH PROBLEMS OR IN,IUR1ES AND IDEN'i'~Y TId~.; HEALTH CARE PROVIDERS WHO TREAT,'~ EACH PLA~rI'~'~' FOR THOSE INJURIES IN TH~: LAST SlX (6~ YEARS. 9. FAMILY PHYSICIAN: ~LEASE STATE '~'~:t~ NAME AND ADDRESS OF YOUR FAMILY PHYSICIAN FOR '~'~ LAST ~w~ (5) Y~A~. 10. PRIOR OR SUBSEQUENT ACC[DENTS: IF BEFORE OR A~'I'~ THE INCIDJ[~qT WHICH IS TtlE SUBJECT OF THIS LAWSUIT~ ANY PLAIN'I'~' WAS INVOLVED IN ANY Or]'H ~ ~ INVOLVING INJURIF~ TO ANY PART OF T~ BODY~ PLEASE STATE Tl:~ TYPE OF INCIDENT INVOLVED AND'~'H~ HEALTH CARE PROVIDERS WHO RENDERED TREATMENT FOR THOSE INJURIES. 11. DIS~BiL~TY: 12. Loss OF EARN GS: IS ANY I:~LAIN'I'I~'~' MAKING A CLAI1VI FOR LOSS OF EARNINGS OR IMPAIRMENT OF EARNING CAPAcriY BECAUSE OF THIS INCIDENT? IF SO, THEN PLEASE PROVIDE Tlil~ FOLLOWING INFORMATION OF EACH: (A) EACH E~IPLO YER, JOB 11'ILE AND DESCRIPTION OF DUTJ/~S AS W]~LI. AS MON'I H],Y OR - ~' WEEKLY RATE OF PAY AT THE TIME OF 'rills INCIDENT; TH~: INCLUSIVE DATES DURING WHICH ANY PLAINTU~'J~* ALLEGES HE OR UA:LE WAS UNABLE TO WORK AS A RESULT OF THI,~ INCu.}ENT .~ rl'li~ TOTAL AMOUNT OF EARNINGS AND PLAI~'iI~'~' LOST BECAUSE OF 'i'ltlS ABSENCE; (c) THE SOURCE AND AMOUNT OF ANY WAGES OR SALARY REc~IY'ED SINCE THIS INCIDENT; AND (D) THE DATE ON WHICH ANY PLAIN'II~'~' FIP, ST REILqlNED TO WORK FOLLOWING INCIDENT AND EACH EMPLOYER FOR WHOM ANY PLAINr~'t' HAS WOI~A~:sz SINCE ]NC1DENT ~l'lH ~CLUSIVE DATES OF EMPLOYMENT~ EACH JOB 'lIl~ ANY HAS ~:~.I~ AND F_.ACH MONTIII,Y OR WEEKLY RATE OF PAY WHICH ANY I~A]~'I1~'_~' HAS REur.~rl/D FROM rl~tm DATE OF sTARTING WORK AGAIN Ar't'~.~ 'rm~ INCIDEKr Uh'l~ THE PRESENT TIMEo 13. IMPAII~D EARNING CAPACITY: IS ANY PLAEN'i'~'~' M_~K'TNG A CLAIM FOR IMPAIRED EARNING CAPACITY BECAUSE OF Tiffs INCIDENT.'? IF YES, PLEASE STATE '1'~: ACTUAL VALUE OF ANY PLAIN'r~'~'~S IMPAIRED EARNING- CAPA~rrY, ~_.;i-iiNG OUT TH~.; MANNER IN WHICH SA~D VALUE WAS CALCULATED, AND BY WHOM. 14. STATEMENTS: HAS ANY PLAINTI~' OR ANYONE AC-rING ON ANY PLAI~'iI~'["$ BI~I~LF OBTAINED ANY STA1]~IENTS~ REPORTS~ MEMORANDUI~ OR TESTIMONY IN ANY FORM FROM ANY PERSON P*.~.,A~G TO ']'HI~ INC][I)]~To IF SO~ PLF~ ]])E~l"rn~ FROM WHOM '[fie STATEM~ WAS TAKEN, THE DATE OF 'I'H~.; STATEMENT AND PROVIDE A COPY IN ANSWER TO 'IHIS INT,'<RROGATORY. 15. WITNESSES: IDEI~'{.II,'¥ ANY WITNESS WHO HAS ANY KNOW'LI~.E OF OR INFORMATION AS TO '~'H~; FACTS PERTAINING TO I~:uS INCIDENT. ALSO PROVIDE A SUMMARY OF '~'H~: INFORMATION WHICH EACH WITNESS HAS CONCERNING THIS INCIDENT. 16. EXPERT WITNESSES: IDF_I~II~'Y AIJ, EXPERTS WHO ANY I~-_,AINTI~I,' EXPECTS TO CAI,I. AT 'llcu~ TRIAL OF CASE, AND PUP. SUANT TO PA R.C.P. 4003.5(A)(1)(B), STATi~ '~a~ SUBSTANCE OF 'r,~ ~: FACTS AND OPINIONS TO WHICH ANY lu~JklN'll~'~"S EXPERT WH.IL TE~'il~'¥ AND 'l'ltl~ SU~Y OF GROUNDS FOR EACH OPINION. TI~ FACTS, OPINIONS AND GROUNDS OF 'l'H ~: EXPERT MAY BE CONTAI2~D IN AN EXPERT REPORT WHICH MAY BE A~'FAt;lt~c;D. SUCH REPORT OR ANSWER TO 'I'H ~,~ INTI~IROGATORY SHOULD BE SIGNItD BY ANY PLAIN'II~Y~S EXPERT. 17. PHOTOGRAPHS, DOCUME~S AND THINGS: IF ANY PLAI~N'I'II.'I,'~ OR ANYONE AC'I1NG ON ANY PLAIN'I'II,'v"$ BEHALF, HAS OR KNOWS OF ANY PHOTOGRAPHS~ DIAGRAMS~ MEASUREMENTS~ SURVEYS OR Orl'H[q:R DESCRIPTIONS REGARDING- OR RELATING- IN ANY WAY TO TH ~ INCIDENT, PLEASE IDENTIk'Y THOSE ITEMS. IN I,II~U OF ANSWERING TIdE FOREGOING INTERROGATORY~ COPIES OF ANY SUCH rl]~vfS MAY BE PROVIDED AS ATTACHMENT TO THESE ANSWERS. 18. RELATED LAWSUITS: PLEASE IDEN'III~Y BY CAPTION, DOCKEI:NUMBER AND COURT ANY 0'1'~ ~:~. LAWSUITS ARISING FROM '!v~ ~q INCIDENT OR RELATING TO '1'1:~ INJURIES CLAIME~ BY THE PLAIiNTI~'~' IN '~'~ SUIT, OR IN WHICH ANY PLA1Nr~'I,' HAS BEEN INVOLVED. ~'~. AG~JI~T A~YO~E 0'1'~ ~:~ ~ D~1~DANTS IN '~ ~,~ ACTION FOR ~ DAMAGF~q OR ~ ARISING OUT OF OR R~AT~.~ TO 'rm~ INCIDENT. 20. PRIOR CONVICTIONS: HAVE YOU BEEN CONVICTED OR pl,l~T~ GUILTY TO ANY CRIME WI'I. HIN 'll:l~ PAST TEN (10) YEARS. IF SO, PLEASE STATE FOR EACH CONVICTION OR PLEA, 'll:u~ O~:~ENSE CHARGED, 'H:L~ COURT CAPTION AND DOCKET, AND 'l'flg DI~O:srl'l. ON AND SENi]~I'CE. 21. LIENS: WOULD ANY ~r,TiX,EMENT OR VERDICT SECURED BY YOU IN 'ires IvlA'l-l~t~,t BE SUBJECT TO ANY FEDERAL I~lq~N~ STATE Lll~N~ l~L~ LIb~N~ WORKMEN'S COMPENSATION LIEN~ OR ANY SllklILAR OR 01'~:~. LI]~I? I~ SO, IDEN'I'I~Y 'lMa~ HOLDER OF 'l~i~ LII~N, Tii~ MVIOUNT OF 'l{:Uc; T.n~T, 'l~a.~ COSTS OF EX~I~ISES COA,'I~,ED BY Tii~ v.n~l, AHD l~il~ CIR~ANCE UNDER WHICH YOU ARE OR MIGHT BE OBLIGATED TO SATISFY '1'1:!~ LB~N. _ 22. VEIHC J INFORMATION: Wl'l~. RESPECT TO ANY POLICY OF MOTOR ~'~:H~CLE INSURANCE OF WHICH YOU WERE J[~[.'I'H I~;~. A N~ ]NSI.IRED OR INSURED AS OF THE DATE OF '1'~ ACCIDENT REFERRED TO IN 'l'HE PLA1NI'II"~S' COMPLAINT, STATE: (A) THE NAME AND ADDRESS OF '~'HE INSURANCE COMPANY ISSUING '~'HE POLICY; (B) THE POLICY NUMBER: (C) F.,F~'I~CTIVE DATES OF 'I'HE POLICY PERIOD; (D) YOUR TORT ,~':g.~-lzON I'URS~ANT TO 75 PA.C.S.A. §1705; (E) Wii~-I ,-,,~:~ YOU WERE A NAM ,~:, ~ INSURED OR IN$URED UNDER 'l{cua; POLICY; I~OR EACH REGI~TI~RED ¥~:- iCLE THAT YOU OWNED AT 'lHl~ TiME OF '1~1/$ ACCIDENT~ STATE: (A) ~ YEAR, ~gl~. AND LICENSE PLATE NUMBER(S) OF ALL SUCH ¥ g:-,CLF~; -:/~i~ (C) THE NAME, ADDRESS AND POLICY NUMBER OF THE COMPANY ]~4SURING ALL SUCH ~'~:-,C~(S). Respectfully submitted, Date: October 24. 2001 LAW OFFICF_,S OF JACOBS & SABA Rickards, Esquire Attorney for Defendant Identification No. 58867 OIHB-O0151 "~ EAW'OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L, Steinberg~ .KIMBERLY GOODLING, (PLAXNXIrr) VS. NANCY L. STEINBERGER, IN THE COURT OF COMMON PLEAS CUlVlBERLAND COUNTY, PENNSYLVANIA NO. 01-5846 CML ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of Defendant's Interrogatories Addressed to plaintiff to be served by regular first class mail upon: Dusan Bratic, Esquire 101 South U.S. Route 15 Dillsburg, PA 17019 Dated: October 24. 2001 Attorney for Defendant Exhibit B 0 II-IB-O0151 ' '~ I.~WV'OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L. Steinberger ~KIMBERLY GOODLING, (PLAINTIFF) VS. NANCY L. STEINBERGER, (DE OANT) IN TIlE COURT OF COM34[ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~t%o. oi- $~4o CIVIL ACTION - LAW JURY TRIAL DEMANDED REQUEST FOR PRODUCTION OF DOCIYMF_~ITS UNDER Pa. R.C.P. 4009 ADDRESSED TO: Kimberly Goodling, Plaintiff c/o Dusan Bratic, Esquire 101 South U.S. Route 15 Dillsburg, PA 17019 Attorney for Plaintiff You are directed to produce the following documents pertaining to the incident, occurrence, or accident described in Plaintiff'S Complaint for inspection and copying at the offices of lacobs & Saba, 214 Senate Avenue, Suite 503, Camp Hill, PA, 17011, pursuant to Pennsylvania Rule of Civil Procedure 4009: .- 1. The entire contents of any and all claims and investigation fries prepared ia this matter, however labeled, excluding references to mental impressions, conclusions or opinions representing the value or merit of the claim or defense, or respecting strategies or tactics in privileged communications from counsel. ' ' 2J' All statements, memoranda, or writings, whether signed or unsigned, of any and all witnesses, including any and all statements, memoranda, and writings of Plaintiff(s). 3. All photographs, recordings, films, charts, sketches, graphs and diagrams taken and/or prepared. 4. Reports of, or from, any and all experts who will testify at trial, or whom you expect will testify at trial. 5. All statements concerning this action or its subject matter previously made by any party or witness pursuant to Pa. R.C.P. 4003.4. 6. All bills, receipts, reports, diagnosis (including x-my and like diagnostic reports) or prognosis and records of any and all medical, physical, psychiatric and/or psychological treatment by any doctor, hospital, psychologist, and psychiatrist, pharmacy or me~iical facility for any injury, treatment or damage received by Plaintiff(s) for any of the 'alleged incidents referred to in Plaintiff(s) Complaint. 7. All bills of any kind incurred by Plaintiff(s) as a result of the alleged incident, occurrence, or accident. 8. All medical records, employer statements, IRS W-2 Forms, and Income Tax ' '7'R;*~u'~n~s (for the preceding five (5) years), lost wages and/or employment records and all other writings, including expert reports, establishing any claim Plaintiff(s) may assert for lost eaxnings and lost earning capacity and for any other financial losses. '" 92 ' AU documents, exhibits, or other tangible physical objects, and/or reports, of any kind whatsoever that will be presented or introduced into evidence at time of trial. 10. A complete copy of the declaration page of all motor vehicle insurance policies of which you were a named insured or insured that were in effect on the date of the motor vehicle accident referred to in the Plaintiff(s) Complaint. ~ 11. A copy of any and all settlement agreements and/or releases involving claims arising from the incident referred to in the Plaimiff(s) Complaint. Date: October 24. 2001 Respectfully submlUed, LAW Ol~'l~'lCES OF IACOBS & SABA Attorney for Defendant Identification No.58867 OIHB-O0151 L~W'OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L. Steinberg~ . ..KIMBERLY GOODLING~ (PL~aNTIFF) VS. NANCY L. STEINBERGER~ (O~A~T) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01-5846 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of Defendant's Request for Production of Documents Addressed to Plaintiff to be served by regular f~t class mail upon: Dusan Brafic, Esquire 101 South U.S. Route 15 Dillsburg, PA 17019 Dated: October 24. 2001 Attorney for Defendant 01HB-00151 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nancy L. Steinber KIMBERLY GOODLING~ (PLAINTIFF) VS. NANCY L. STEINBERGER~ (DEFENDANT) er IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01-5846 CML ACTION- LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of Defendant's Motion to Commfl Discovery. to be served by regular fLrst class mail upon: Dusan Bratic, Esquire 101 South U.S. Route 15 Dillsburg, PA 17019 Dat~..d: M~'gh 20. 2002 Girard E. Rickards, Esquire Attorney for Defendant 01I-IB-00151 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant Nanc~ L. Steinberge KIMBERLY GOODLING, (PLAINTIFF) VS. NANCY L. STEINBERGER, (DEFENDANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01-5846 CIVIL ACTION- LAW JURy TRIAL DEMANDED RULE TO SHOW CAUSE AND NOW, this 27 . c[ Day of ~/~ ~ r~ & 2002, upon consideration of the Defendant's Motion to Compel Discovery, a RULE is hereby issued upon the Plaintiffto show cause why the Defendant's Motion to Compel Discovery should not be granted. RULE RETURNABLE within 2_ O days after service. BY THE COURT: KIMBERLY GOODLING Plaintiff NANCY L. STEINBERGER Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION LAW : NO. 01-5846 : : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I HEREBY CERTIFY that a tree and correct copy of the foregoing Answers to Interrogatories and Request for Production of Documents was furnished by U.S. Mail, first class, postage prepaid on this ~)in' day of April 2002, to: Girard E. Rickards, Esquire Jacobs & Saba 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 BRATIC & PORTKO Dated: