HomeMy WebLinkAbout98-06675
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No, rS~ Cd/lj 1I..2..l' ( L.
Civil Action (X) Law ( ) Equity
BARBARA JEAN PAYNE
1750 Skippack Pike
Townhouse "2307
Blue Bell, PA 19422
Plaintiff
v.
STEPHANIE BRENEMAN
816 Flintlock Road
Mechanicsburg, PA 17055
Defendant
PRAECIPE TO ISSUE WRIT OF SUMMONS
TO THE PROTHONOTARY:
Please issue a writ of summons in the above-captioned action.
Prepared by:
Writ of Summons shall be issued and forwarded to
( ) Attorney (x) Sheriff
Charles E. SChmidt,~'-:JqUire,
Schmidt and Ronca, I~:; 269 State Street,
Harrisburg, PA 17 01 (717,) 232-6300
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By:
Date:
/UU,;)o( I~g?
Charles E. Schmidt, Jr., Esquire
Supreme Court I.D. No. 19198
209 State Street
Harrisburg, PA 17101
(717) 232-6300
WRIT OF SUMMONS
TO THE ABOVE NAMED DEFENDANT:
YOU ARF. NOTIFIED THAT TilE ABOVE-NAMED PLAINTIFFS
HAVE COMMENCED AN ACTION AGAINST YOU.
Date: /f - do. d, q f
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NOTICIA
Le han demandado a usted en la corte. Si usted quiere
defenderse de estas demandas expuestas en las paginas
siguientes, usted tiene viente (20) dias de plazo al partir de
la fecha de la demanda y la notificacion. Usted debe presentar
una apariencia escrita 0 en persona 0 por abogado y archivar en
la corte en forma escrita sus defensas 0 sus objeciones alas
demandas en contra de su persona. Sea avisado que si usted no
se defiende, la corte tomara medidas y puede entrar una orden
contra usted sin previa aviso 0 notificacion y por cualquier
queja 0 alivio que es pedido en la peticion de demanda, Usted
puede perder dinero 0 sus propiedades 0 otros derechos
importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. 51 NO
TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
."...
II. STATEMENT OF THE FACTS
3. On January 26, 1997, the Plaintiff was a passenger in a
1990 Honda Civic owned by Buckley LeaSing & Auto Sales, 7202
Harrisburg Pike, Carlisle, Pennsylvania 17031, but which was
placed in Defendant's care, custody, and cO/ltrol.
4. On the aforesaid date, the 1990 Honda Civic, operated
by Jeremy Bull and in which Plai/ltiff was a passenger left Route
11 (at or near the intersection of State Route 11 and Roadway
Drive in Middlesex Township, Cumberland County, Pennsylvania),
crossed over the left side of the roadway, and struck a pole.
See more particularly Payne v. Bull, No. 98-4094 Civil, filed in
I
Cumberland County, Pennsylvania, a true a/ld correct copy of the
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Complaint is attached hereto as Exhibit "A".
5. Prior to the accident, the Plaintiff, Jeremy Bull, and
others were social guests of the Defendant, at the Carlisle
Country Club, CarliSle, Pennsylvania.
6. Jeremy Bull, as the Defendant in the case of Payne v.
Bull, supra, alleges that while at the Carlisle Country Club he
was intoxicated and visibly intoxicated. See attached Exhibit
"B", a true and correct copy of Bull's Answer with New Matter.
7. If the allegations in Bull's Answer with New Matter in
the case of Payne v. Bull are true, then the Plaintiff in the
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alternative alleges that the aforesaid accident on January 26,
1997, in which the Plaintiff was severely injured was, i/l the
alternative, at lea5t partially caused by the Defendant Breneman
in allowing Jeremy Bull to operate the 1990 Honda Civic when she
and her guests left the Carlisle Country Club on January 26,
1997.
8. The negligence of the Defendant Breneman consisted of:
(A) Giving care, custody, and control of the 1990
Honda Civic to Jeremy Bull who she knew or should
have known as intoxicated and, therefore, unfit to
drive;
(B) Giving care, custody, and control of the 1990
Honda Civil to Jeremy Bull who was visibly
intoxicated and, therefore, unfit to drive; and
(C) Allowing Jeremy Bull to drive her vehicle while he
was intoxicated and, therefore, unfit to drive.
9. As the result of the Defendant's negligence, the
Plaintiff suffered the following injuries which are severe and
permanent:
(A) Facial Lacerations and swelling;
(B) A complete tear of the posterior cruciate ligament
of the right knee, requiring two surgeries, and
manipulation under anesthesia;
(C) Permanent limitations to her right knee;
(D) Scarring of her face and left and right forehead;
(E) Neck and back soft tissue injuries; and
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(F) Damage to associated muscles, nerves and
ligaments.
10. Medical bills have been incurred as a result of the
Plaintiff's injuries which include, to date, the following:
Carlisle Community Ambulance
(1/26/97)
$
285.00
West Shore Emergency Medical Services
(1/26/97 )
$
377.50
RWC Emergency Physicians
(1/26/97)
$
180.00
Carlisle Imaging Association
(1/26/97)
$
496.00
Carlisle Hospital
(1/26/97-4/11/97)
$ 7,046.00
David C. Baker, M.D.
(1/26/97-4/23/97)
$ 2,345.00
Central PA MRI Center
(2/3/97)
$
875.00
Belvedere Medical Corp.
(1/26/97-1/28/97)
$
750.00
Penn's Wood Physical Therapy
(2/12/97-4/1/97 )
$ 1,453.00
Kevin Black, M.D.
(2/20/97)
$
140.00
King of Prussia Physical Therapy
& Sports Injury Center
(9/24/97-3/4/98 )
$10,345.00
Bryn Mawr Orthopedics
(9/2/97-1/12/98 )
$ 5,090.00
4
WHEREFORE, the Plaintiff, BARBARA JEAN PAYNE demands
judgment of the Defendant, STEPHANIE BRENEMAN, in an amount in
excess of the amount required in compulsory arbitration.
I
submitted,
I P.C.
By:
Charles E. Schmi Esquire
1.D.# 19198
209 state Street
Harrisburg, PA 17101
(717) 232-6300
Attorney for the Plaintiff
6
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BARBARA JEAN PAYNE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
JEREMY BULL,
NO. 1 f- J.j(Q1
JURY TRIAL DEMANDED
0~t.~
Defendant
NOT ICE
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 LOCAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
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BARBARA JEAN PAYNE,
Plaintiff
: IN THE COURT OP COKMON PLEAS
CUMBERLAND COUNTY, PENNSYLVJUUA
v,
JEREHY DULL,
:
CIVIL ACTION - LAW
Defendant
NO,
JURY TRIAL DEKANDED
COMPLAINT
AND NOW, comes the Plaintiff, BARBARA JEAN PAYNE, by and
through her attorneys, SCHMIDT AND RONCA, P.C., and respectfully
avers as follows:
I. THE PARTIES
1. The Plaintiff, BARBARA JEAN PAYNE, is an adult
#2307, Blue Bell, Pennsylvania 19422.
individual currently residing at 1750 Skippack Pike, Townhouse
2. The Defendant, JEREMY BULL, is an adult individual
currently residing at 6607, Apartment C, Carlisle Pike,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
II. STATEMENT OF THE FACTS
3. The events hereinafter described took place on or about
January 26, 1997, at approximately 4:11 p,m., at or near the
intersection of S.R. 11 and Roadway Drive in Middlesex TownShip,
Cumberland County, Pennsylvania.
4, At the aforesaid time and place, the plaintiff, BARBARA
JEAN PAYNE, was a passenger in a 1990 Honda civic being operated
by the Defendant, JEREMY BULL.
5. At the aforesaid time and place, the Defendant, JEREMY
BULL, was travelling in the northbound left lane of Route 11,
approaching its intersection with Roadway Drive.
6. At the aforesaid time and place, the traffic light at
the intersection of Route 11 and Roadway Drive turned yellow, and
the Defendant, JEREMY BULL, applied his brakes and lost control
of his vehicle causing him to skid out of control, to cross the
median into the southbound lanes of Route 11, and to skid into
the entrance of ABF Truck Terminal.
7. After entering the premises of ABF Truck Terminal, the
Defendant's vehicle collided with a traffic signal pole, causing
the vehicle to become airborne, to spin twice in a 360 degree
counterclockwise direction, and to finally come to rest after
striking a parked pick-up truck.
8. As a sole and proximate result of the Defendant's
negligence, the Plaintiff sustained severe and permanent
injuries.
2
.
COUNT I
NEGLIG~HQC
~ABA JEAN P~YNE v, ~REMY DUL~
9, Paragraphs 1 through 8 of the Plaintiff's Complaint are
incorporated herein by reference and made a part thereof as if
set forth in full.
10. The accident was caused solely by the negligence,
carelessness, and recklessness of the Defendant, JEREMY BULL, and
was in no way caused or contributed to by the Plaintiff, BARBARA
JEAN PAYNE.
11. The Defendant's negligence, carelessness, and
recklessness consisted of the following:
A. Failing to exercise the high degree of care
required by a motorist entering an intersection;
B. Driving his vehicle at a speed and in a manner in
excess of the speed limit;
C. Inattentiveness;
D. Failing to maintain control of his vehicle;
E. Driving too fast for circumstances;
F. Crossing the center of the highway; and
G. Some, or all, of the above are violations of the
Pennsylvania Motor Vehicle Code, which is
negligence per se.
3
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12, As the sole result of the Defendant's negligence, the
Plaintiff, BARBARA JEAN PAYNE, suffered the following severe and
permanent injuries:
A. Facial lacerations and swelling;
B. A complete tear of the posterior cruciate ligament
of the right knee, requiring two surgeries, and
manipulation under anesthesia;
C. Permanent limitations to her right knee;
D. Scarring of her face and left and right forehead;
E. Neck and back soft tissue injuries; and
F. Damage to associated muscles, nerves and
ligaments.
13. Medical bills have been incurred as a result of the
Plaintiff's injuries which include, to date, the fol1owing:
Carlisle Community Ambulance
(1/26/97)
$ 285.00
$ 377.50
$ 180,00
$ 496.00
$ 7,046.00
$ 2,345.00
$ 875.00
West Shore Emergency Medical Services
(1/26/97)
RWC Emergency Physicians
(1/26/97)
Carlisle Imaging Association
(1/26/97)
Carlisle Hospital
(1/26/97-4/11/97)
David C. Baker, M.D.
(1/26/97-4/23/97)
Central PA MRI Center
(2/3/97)
4
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Belvedere Medical Corp,
(1/26/97-1/28/97)
$
750.00
Penn's Wood physical Ther.apy
(2/12/97-4/1/97)
$ 1,453,00
Kevin Black, M.D.
(2/20/97)
$
140.00
King of prussia physical Therapy
& sports Injury Center
(9/24/97-374/98)
$10,345.00
Bryn M~wr orthopedics
(9/2/97-1/12/98)
$ 5,090,00
Brian Murphy, M.D.
(Bills unavailable at this time)
Bryn Mawr Hospital
$
$20.583.25
TOTAL
$49,965.75
In addition, plaintiff may incur additional sums in the future.
14. As the sole and proximate result of the Defendant's
negligence, the plaintiff, BARBARA JEAN PAYNE, has suffered a
10ss of earnings and an impairment of earning capacity.
15. AS the sole and proximate result of the Defendant's
negligence, the Plaintiff, BARBARA JEAN PAYNE, has undergone
great pain and suffering in the past and will continue to undergo
great pain and suffering into the future.
16. As the sole and proximate result of the Defendant's
negligence, the plaintiff, BARBARA JEAN PAYNE, has suffered a
5
IN THE COURT OF COMMON PLEAS OF CUMUERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BARBARA JEAN I' ^ YNE,
PlaintilT,
No 98-4094 Civil
vs.
JEREMY BULL.
Defendant
ANSWER
I. 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 these
averments.
2. The allegations of this paragraph are denied. Defendant's residence is 27
Cleveland Street, Apartment 3, Springfield, Massachusetts 0 II 08.
3. The allegations of this paragraph are denied pursuant to Pa. R.C.P. 1029(e).
4. The allegations of this paragraph are denied pursuant to Pa. R.C.P. 1029(e).
5. The allegations of this paragraph are denied pursuant to Pa. R.C.P. 1029(e).
6. The allegations of this paragraph are denied pursuant to Pa. R.C.P. 1029(e).
7. The allegations of this paragraph are denied pursuant to Pa. R.C.p. 1029(e).
8. The allegations of this paragraph are denied pursuant to Pa. R.C.p. 1029(e).
COUNT I
NEGLIGENCE
BARBARA JEAN PAYNE V. JEREMY BULL
9. The Defendant incorporales the Answers of Paragraphs I through 8 herein.
10. The allegations Oflhis paragraph are denied pursuant to Pa. R.C.p. 1029(e).
2
II.
The allegations of this panlgraph are denicd pursuaill iu"l'a IU: I' IIJ~"(.,
12. The allegations of this paragraph arc denicd pursuant to Pa. R.C.P. I029(e),
13. The allegations of this paragraph are denied pursuant to Pa RC,P. I029(e),
14. The allegations of this parugruph are denicd pursuant to Pa. ItC.P. I029(e).
IS. The allegations of this paragraph are denied pursuant to Pa. R.C.P. I029(e).
16. The allegations of this paragraph are denied pursuant to Pa. R.C.p. I029(e).
17. The allcg~tions of this paragraph are denied pursuant to Pa. R.C.p. I029(e).
WHEREFORE, the Defendant demands judgment in his favor and dismissal of the
Complaint.
NEW MATTER
I. On January 26, 1997, the Plaintiff lived in an apartment building with the
Defendant and five (5) other individuals.
2. On January 26, 1997 at approximately noon, the Plaintiff went to the Carlisle
Country club with the Plaintiff and seven (7) other individuals.
3. While at the Carlisle Country Club, the Plaintiff and the Defendant and others ate
and drank, consuming alcoholic beverages.
4. While at the Carlisle Country Club, the Plaintiff and the Defendant became
intoxicated.
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S. While at the Carlisle Country Club, the Plaintiff and the Defendant, while visibly
intoxicated, were served alcoholic beverages by the agents, servants or employees of the Carlisle
Country Club.
6. When it came time to leave the Carlisle Country Club, the Plaintiff knew that the
Defendant was intoxicated.
3
7. When it came time 10 leave IlIe Carlisle Coulllry ClulJ, Ihc I'I"IIHIII I.hu ....... ,.....,,,..,
that the Defendant was driving the vehicle and voluntarily entered the vehicle.
8. Thc Plaintiff was contributorily negligcnt in that she:
a. Knew Defendant was drinking and intoxicated and ncvcrtheless proceeded
to ride in the car with Defendant;
b. Should have known Defendanl was drinking and intoxicated and
nevertheless proceeded to ride in the car with Defendanl;
c. Knew Defendam was drinking and intoxicated and was unable to drive the
car; and
d. Should have known Defendant was drinking and intoxicated and was
unable to drive Ihe car.
9. The Plaintiff assumed the risk of the accident by:
a. Knew and appreciated Defendant was drinking and intoxicated and
nevertheless proceeded to ride in the car with Defendant; and
b. Knew and appreciated Defendant was drinking and intoxicated and
nevertheless proceeded to ride in the car with Defendant, even though
Defendant was unable to drive.
4
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WHEREFORE, the Defcndant has a full and complete defcnse to this action and requests
its dismissal.
Respeclfully submitted,
BLAKEY, YOST, BUPP & SCHAUMANN, LLP
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Donald B. Hoyt, Esquire
Counsel for Dcfendant
17 East Market Street
York, Pennsylvania 17401
SupremeCI.I.D. #18061
(717) 845-3674
5
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CERTIFICATE OF SERVICE
I hereby certify that a LrUf' dflCi c"nrrc-c;t ("Opy of th(>
foregoing document was served by depositing the same in the
United States Mail, postage prepaid, at Harrisburg,
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Pennsylvania, on the ~~ day of March, 1999, on all counsel of
record as follows:
Charles E, Schmidt, Jr.,
SCHMIDT, RONCA & KRAMER,
209 State Street
Harrisburg, Pennsylvania
Esquire
PC
17101
Attorneys for Plaintiff
THOMAS, THOMAS & HAFER, LLP
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Ros~ B. Kulp, Secretar~ :52286.1
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Stephen f Gtduld"l, [IQUlfe
Allornoy I 0 No 43530
THOMAS, THOMAS & HAFER. LLP
30S North Front Stroot
POlt Offc.e 80)( 999
H.rrilburQ, Penn.ytv.nla 11108
(717) 237.7100
E.Mall sea{1lHthl~y.LC9m
AlIornoys for Defendant
STEPHANIE BRENEMAN
BARBARA JEAN PAYNE,
Plaintiff
IN THE COURT OF' COMMON PLEAS OF'
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION -- LAW
NO, 98-6675
STEPHANIE BRENEMAN,
Defendant
JURY TRIAL DEMANDED
AGREEMENT PURSUANT TO RULE 237.2
TO EXTEND TIME TO PLEAD FOLLOWING TEN-DAY NOTICE
It is agreed that Defendant, Stephanie Breneman, is
granted an extension of time through April 19, 1999, in which to
file an answer or preliminary objections. After the above date,
a judgment of non pros or by default, as may be appropriate, may
be entered upon praecipe
without furtn~f'notice.
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Charles E. Schmidt, Jr" Esquire
Attorney for Plaintiff
1;15/1
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Date
S ephen E. Geduldig, Esquir
Attorney for Defendant :5 1.1
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BARBARA JEAN PAYNE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLA}ID COUNTY, PENNSYLVANIA
v.
JEREMY BULL,
CIVIL ACTION - LAW
Defendant
v,
NO. 98-4094
CARLISLE COUNTRY CLUB,
Additional Defendant
JURY TRIAL DEMANDED
..*.......**
BARBARA JEAN PAYNE,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
STEPHANIE BRENEMAN,
Defendant,
NO. 98-6675
./
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
AND NOW this -+Jfday of m~"V{i-, , 1999, I, Charles E,
Schmidt, Jr., Esquire, hereby certify that I have this day
served PLAINTIFF'S NOTICE OF DEPOSITION OF STEPHANIE BRENEMAN,
by depositing a copy of the same in the United States Mail,
postage prepaid, at Harrisburg, Pennsylvania, addressed to:
Donald B, Hoyt, Esquire
Blakey, Yost, Bupp & Schaurnann, LLP
17 East Market Street
York, Pennsylvania 17401
Attorney for Jeremy Bull
.", -...,
.
Guy H. Brooks, Esquire
GOldberg, Katzman & Shipman, P.C,
320 Market Square, Strawberry Square
P.O. Box 126B
Harrisburg, PA 1710B-126B
Attorney for Carlisle Country Club
Stephen E. Geduldig, Esquire
Thomas, Thomas & Hafer, LLP
305 North Front Street
Harrisburg, PA 01
Attorney for S eph nie Breneman
& KRAMER P,C.
..-----"
By:
Charles E. Schmidt, Jr,
1.D. No. 19198
209 State Street
Harrisburg, PA 17101
(717) 232-6300
Attorney for Plaintiff
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BARBARA JEAN PAYNE,
Plaintiff
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
JEREHY BULL,
Defendant
v.
NO. 98-4094
CARLISLE COUNTRY CLUB,
Additional Defendant
JURY TRIAL DEMANDED
..".....
BARBARA JEAN PAYNE,
Plaintiff,
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
STEPHANIE BRENEMAN,
Defendant.
NO. 98-6675 /
JURY TRIAL DEMANDED
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CERTIFICATE OF SERVICE
AND NOW this Itl!, day of mIlA/I"
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, 1999, I, Charles E.
Schmidt, Jr" Esquire, hereby certify that I have this day
served PLAINTIFF'S NOTICE OF DEPOSITION OF TIM TANKERSLEY by
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depositing a copy of the same in the United States Mail, postage
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prepaid, at Harrisburg, Pennsylvania, addressed to:
Donald B, Hoyt, Esquire
Blakey, Yost, Bupp & Schaurnann, LLP
17 East Market street
York, Pennsylvania 17401
Attorney for Jeremy Bull
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GOldberg, Katzman & Shipman, P.C.
320 Market Square, Strawberry Square
P.O. Box 1268
Harrisburg, PA 17108-1268
Attorney ror Carlisle Country Club
Stephen E, Geduldig, Esquire
Thomas, Thomas & Hafer, LLP
305 North Front Street
Harrisburg, PA 17101
Attorney for Stephanie Brenaman
Tim TankerSley
6607 Carlisle Pike, Apartment C
Mechanicsburg, .J(' 17055
By:
Charles E, Schmidt, Jr,
I.D, No, 19198
209 State Street
Harrisburg, PA 17101
(717) 232-6300
Attorney for Plaintiff
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BAABAM JEAN PAYNE,
Plaintiff
IN TilE COURT Of' COMMON PLEAS
CUMB~:RLAND COUNTY, PENNSYLVANIA
v.
CIVlI, ACTION - LAW
JEREMY BULL,
Defendant
v,
NO, 98-4094
CARLISLE COUNTRY CLUB,
Additional Defendant
JURY TRIAL DEMANDED
********
BARBAM JEAN PAYNE,
Plaintiff,
IN THE COURT Of' COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
NO, 98-6675 /'
STEPHANIE BRENEMAN,
Defendant.
JURY TRIAL DEMANDED
AND NOW this
CERTIFICATE OF SERVICE
/ 9'!t day of 'rfJfJA ct
, 1999, I, Charles E.
Schmidt, Jr" Esquire, hereby certify that I have this day
served PLAINTIFF'S NOTICE OF DEPOSITION OF JEREMY BULL, by
depositing a copy of the same in the United states Mail, postage
prepaid, at Harrisburg, Pennsylvania, addressed to:
Donald B, Hoyt, Esquire
Blakey, Yost, Bupp & Schaumann, LLP
17 East Market street
York, Pennsylvania 17401
Attorney for Jeremy Bull
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Stephen E. Gedukl'll. EIq..e
Attorney I O. No. 43~30
THOMAS, THOMAS & HAFER. LLP
305 Nonh Fronr Srreet
POlt OffICe Box 999
Harrisburg, Pennsylvania 17108
(717) 237.7100
E.Mail. sea(ci)lIhlaw,com
Attorneys 'or Defend.nt:
STEPHANIE BRENEMAN
BARBARA JEAN PAYNE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION -- LAW
NO, 98-6675
STEPHANIE BRENEMAN,
Defendant
JURY TRIAL DEMANDED
ANSWER AND NEW MATTER OF DEFENDANT,
STEPHANrE BRENEMAN, TO PLArNTrFF' S COMPLArN'l'
AND NOW, comes Defendant, Stephanie Breneman
("Defendant"), by and through her undersigned counsel,
Stephen E. Geduldig, Esquire, of Thomas, Thomas & Hafer, LLP,
and files the following Answer and New Matter to Plaintiff's
Complaint:
1. Denied pursuant to Pa, R.C.p. 1029(e),
2, Denied. Defendant is an adult individual
23324,
currently residing at 1303 Drayton Road, Chesapeake, Virginia,
WHEREFORE, Defendant, Stephanie Breneman, respectfully
requests that Plaintiff's Complaint be dismissed in its entirety
and jUdgment entered in her lavor,
II, STATEMENT OF FACTS
3, Admitted that on January 26, 1997, Plaintiff was
a passenger in a 1990 Honda Civic owned by BUckley Leasing and
Auto Sales, 7202 Harrisburg Pike, Carlisle, Pennsylvania 17013,
which was being operated by Jeremy Bull, with permission of
Defendant,
4. Admitted that an accident occurred on January 26,
1997, on S.R, 11 (Carlisle Pike) at approximately 4:10 p,m. near
its intersection with Roadway Drive in Middlesex Township,
Cumberland County, Pennsylvania. To the extent that paragraph 4
of Plaintiff's Complaint purports to aver additional facts, same
are denied pursuant to Pa. R.C,p. 1029(e). By way of further
response, what is identified as Exhibit "AH at paragraph 4 of
Plaintiff's Complaint is not attached to Defendant's copy of the
Complaint. Therefore, no response is required.
5. To the extent that paragraph 5 of Plaintiff's
Complaint purports to aver a legal conclusion, no response is
required, By way of further response, it is admitted that
Plaintiff, Barbara Payne, Jeremy Bull and others accompanied
2
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Stephanie Breneman ~t the Carlislo Country Club, Carlisle,
Cumberland County, Pennsylvania, prior Lo Lho accident,
6. To the extent that paragraph 6 of Plaintiff's
Complaint alleges facts which are any lawsuit other than this
one, to which Defendant had no right to plead, no response is
required, By way of further response, what is identified as
Exhibit "AU at paragraph 4 of Plaintiff's Complaint is not
attached to Defendant's copy of the Complaint, Therefore, no
response is required,
7. Denied as legal conclusions and pursuant to Pa,
R,C.P. 1029(e),
8 (a)-(c), Denied as legal conclusions and
pursuant to Pa. R,C.P. 1029(e),
9 (a) - (f) .
Denied as legal conclusions and
pursuant to Pa. R,C.P. 1029(e),
10. Denied as a legal conclusion and pursuant to Pa.
R,C,P. 1029 (e),
11. Denied
R,C,P, 1029 (e).
12, Denied
R,C.P. 1029 (e).
13. Denied
R,C.P. 1029 (e) .
as a legal conclusion and pursuant to Pa,
as a legal conclusion and pursuant to Pa.
as a legal conclusion and pursuant to Pa,
3
14, Denied as a legal conclusion and pursuant to p~.
R.C,?, 1029(e),
WHEREFOR~, Defendant, Stephanie Breneman, respectfully
requests that Plaintiff's Complaint be dismissed in its entirety
and judgment entered in her favor.
III.
PUNITIVE DAMAGES
15, Denied as legal a conclusion and pursuant to Pa.
R,C,P. 1029(e)
WHEREFORE, Defendant, Stephanie Breneman, respectfully
requests that Plaintiff's Complaint be dismissed in its entirety
and judgment entered in her favor.
NEW MATTER
16, Plaintiff's Complaint fails to allege a claim for
punitive damages.
17. Plaintiff's Complaint fails to allege a cause of
action against Stephanie Breneman.
18.
If Plaintiff's allegations, denied as aforesaid, are
proven to be true, then Plaintiff, Barbara Payne, is comparatively
negligent for knowingly, voluntarily, and consciously choosing to get
into the vehicle operated by Jeremy Bull, which she knew or should
have known Bull was allegedly incapable of safely operatin9.
19. At the time of the accident, Plaintiff, Barbara Payne,
was under the influence of alcohol.
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20, Alternatively, at the time of the accident, Plaintiff.
Barbara Payne, was not under the influence of alcohol, and was
conscious, lucid, competent and able to make reasoned decisions
pertaining to her own health, salety and well being,
21, Plaintiff's damages, denied as aforesaid, were caused
by third persons over whom Defendant had no control or right of
control,
22, Plaintiff's claims may be barred or limited by the
Pennsylvania Financial Responsibility Motor Vehicle Act.
WHEREFORE, Defendant, Stephanie Breneman, respectfully
requests that Plaintiff's Complaint be dismissed in its entirety
and judgment entered in her favor,
Respectfully submitted,
THOMAS, ~HOMAS & HAFER, LLP
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Attorney I,D. No. 43530
By:
Attorneys for Defendant,
STEPHANIE BRENEMAN
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BARBARA JEAN PAYNE,
Plaintiff,
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
STEPHANIE BRENEMAN,
Defendant.
NO. 98-6675
JURY TRIAL DEMANDED
REPLY TO NEW MATTER
16. Paragraph 16 contains a conclusion of law which does
not require a responsive pleading,
17, Paragraph 17 contains a conclusion of law which does
not require a responsive pleading,
18. Denied. Paragraph 18 is denied for reasons set forth
in Plaintiff's Complaint and Reply to New Matter in the case of
Barbara Jean Payne v, Jeremy Bull, No, 98-4094 Civil, Common
Pleas Court of Cumberland County.
19, Denied in part. Plaintiff admits to having consumed
two drinks of alcohol, but denies that she was impaired,
20, See reply to No, 19 above,
21. Paragraph 21 does not require a responsive pleading,
22. Paragraph 22 contains a conclusion of law which does
not require a responsive pleading,
.~.
BARBARA JEAN PAYNE,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUN'rY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
NO. 98-6675
STEPHANIE BRENEMAN,
Defendant.
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
AND NOW, this ~ day of May, 1999, I, Charles E, Schmidt,
Jr., Esquire, attorney for the Plaintiff, hereby certify that I
have, this day, served the foregoing, by depositing a copy of the
same in the United States Mail, postage prepaid, at Harrisburg,
Pennsylvania, as well by depositing a copy of the same in the
United States Mail, Certified Mail, Return Receipt Request,
postage prepared, at Harrisburg, Pennsylvania, addressed to:
Stephen E, Geduldig, Esquire
Thomas, Thomas & Hafer
305 North Front Street
Harrisburg, PA 17101
SC
ER, P,C,
By:
Charles E. Schmidt, Jr.
Attorney 1.0. #19198
209 State Street
Harrisburg, PA 17101
(717) 232-6300
Attorney for the Plaintiff
...
VERI f'ICATION
I, Charles E, Schmidt, Jr" attorney for Plaintiff, verify
that I am attorney of record for the Plaintiff, and that the
foregoing document contains no facts within the knOWledge of the
Plaintiff, but rather is based upon the record or facts solely
within the knowledge of the attorney; and, for that reason, I
make this Verification on Plaintiff's behalf,
I verify that the facts contained in the foregoing document
are true and correct to the best of my knowledge, information and
belief.
I understand that intentional false statements herein are
made subject to the penalties of 18 Pa, C.S,A, ~4904 relating to
---..
unsworn falsifications to authorities,
R, P.C,
By:
Charles E. Schmidt, Jr,
Attorney I,D, #19198
209 State Street
HarriSburg, PA 17101
(717) 232-6300
Attorney for the Plaintiff
,.,.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the
.i
foregoIng document was served by depositIng the same in the
United States
Mail, postage prepaid, at Harrisburg,
D ','{II
on the(~day of May, 1999, on all counsel of
Pennsylvania,
record as follows:
Charles E, SChmidt, Jr.,
SCHMIDT, RONCA & KRAMER,
209 State Street
Harrisburg, Pennsylvania
Esquire
PC
17101
Attorneys for Plaintiff
THOMAS, THOMAs & HAFER, LLP
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v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
BARBARA JEAN PAYNE,
Plaintiff,
STEPHANIE BRENEMAN,
Defendant.
NO. 98-6675
JURY TRIAL DEMANDED
AND NOW this
CERTIFICATE OF SERVICE
91P)' day of f1l ~
Jr., Esquire, hereby cer~fY
, 1999, I,
Charles E. Schmidt,
that I have
this day served a copy of the PLAINTIFF'S RESPONSE TO REQUEST
FOR PRODUCTION OF DOCUMENTS OF DEFENDANT ADDRESSED TO PLAINTIFF
by depositing a copy of the same in the United States Mail,
postage prepaid, at Harrisburg, Pennsylvania, addressed to:
Stephen E. Geduldig, Esquire
Thomas, Thomas & Hafer
305 North Front Street
Harrisburg, PA 17101
Respectfully submitted,
I
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BY:
Charles E. Schm~dt,
Attorney 1D # 19198
209 state Street
Harrisburg, PA 17101
(717) 232-6300
Attorney for the Plaintiff
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BARBARA JEAN PAYNE,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
STEPHANIE BRENEMAN,
Defendant.
NO, 98-6675
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
AND NOW this
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day of
Charles E, Schmidt, Jr" Esquire, hereby certify that I have
this day served a copy of the PLAINTIFF'S ANSWERS TO DEFENDANT'S
INTERROGATORIES by depositing a copy of the same in the United
States Mail, postage prepaid, at Harrisburg, Pennsylvania,
addressed to:
Stephen E. Geduldig, Esquire
Thomas, Thomas & Hafer
305 North Front Street
Harrisburg, PA 17101
P.C.
BY:
Charles E. Schmidt, Jr.
Attorney 1D # 19198
209 State Street
Harrisburg, PA 17101
(717) 232-6300
Attorney for the Plaintiff
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BARBARA JEAN PAYNE,
Plaintif f,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
STEPHANIE BRENEMAN,
Defendant,
NO. 9d-6675
JURY TRIAL DEMANDED
AND NOW this
CERTIFICATE OF SERVICE
"'\ \'"
\ ;:::.V- day of July, 1999, I, Shawn T,
Peterson, hereby certify that I have this day served a copy of
PLAINTIFF'S SUPPLEMENTAL ANSWERS TO DEFENDANT'S INTERROGATORIES
by depositing a copy of the same in the United States Mail,
postage prepaid, at Harrisburg, Pennsylvania, addressed to:
Stephen E. Geduldig, Esquire
Thomas, Thomas & Hafer
305 North Front Street
P.O, Box 999
Harrisburg, PA 17101
Attorney for Defendant
Respectfully submitted,
SCHMIDT, RONCA & KRAMER, P,C,
BY:~""~
Shawn T. Peterson
Paralegal
209 State Street
Harrisburg, PA 17101
(717) 232-6300
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Barbara Jean Payne
I, Barbara Jean Payne, verify that I am the Plaintiff in
the foregoing action. I have read the foregoing document and
to the extent that it is based upon information which I have
given to my counsel it is true and correct to the best of my
knowledge, information, and belief, To the extent that the
contents of the foregoing document are that of counsel, I have
relied upon counsel in making this Verification,
I understand that intentional false statements herein
are made subject to the penalties of 18 Pa.C.S.A, ~ 4904
relating to unsworn falsifications made to authorities,
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BARBARA JEAN PAYNE,
Pl,lintiU
IN THE COURT Of COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
NO, 98-6675
STEPHANIE BRENEMAN,
Defendant
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
AND NOW this ).. '-\ ~ day of August, 1999, I, Charles E,
Schmidt, Jr., Esquire, hereby certify that I have this day
served a copy of the PLAINTIff'S INTERROGATORIES ADDRESSED TO
DEFENDANT (FIRST SET) by depositing a copy of the same in the
United States Mail, postage prepaid, at Harrisburg,
Pennsylvania, addressed to:
Stephen E. Geduldig, Esquire
Thomas, Thomas & Hafer
305 North Front Street/---\
Harrisburg, PA 17101 I
,
Re pectfully submitted,
,
HMIDT, ~6NCA & KRAro ER,
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BY:
Charles E, Schmidt,
Attorney 10 # 19198
209 State Street
Harrisburg, PA 17101
(717) 232-6300
Attorney for the Plaintiff
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BARBARA JEAN PA'OJf:,
1'11.1 i fl t i f t ,
IN '1'111,: couwr OF COMMON rl.F.AS
C:UMHI':Hl.MW COUNTY, PF.NNSYLVANIA
v,
CIVIL ACTION - LAW
STEPHANIE BRENEMAN,
Defendant,
NO, 98-667S
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
AND NOW this 4'0 day of May, 200a, I, Shawn '1'. Peterson,
hereby certify that I have this day served PLAINTIFF'S FIRST
SUPPLEMENTAL RESPONSE TO DEFENDANTS' REQUEST FOR PRODUCTION OF
DOCUMENT, by depositing a copy of the same in the United States
Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed
to:
Stephen E. Geduldig, Esquire
Thomas, Thomas & Hafer
305 North Front Street
Harrisburg, PA 17101
SCHMIDT, RONCA & RRAMER, P, C .
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Shawn T. Peterson, Paralegal
209 State Street
Harrisburg, PA 17101
(717) 232-6300
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BARBARA JF.AN PAYNF.,
Plaintiff,
I N TilE COUHT OF COMMON Pr.EA~;
CII11BEHLAND COUNTY, PENNSYLVANIA
v.
cr V J L ACT ION - LAW
STEPIIAN I r. fWF.NEMAN,
Defendant,
NO. 'J8-(,C7"
JURY THIAL DEMANDED
CERTIFICATE OF SERVICE
AND NOW this 13"1 day of June, 2000, I, Shawn T, Peterson,
hereby certify that I have this day served a copy of PLAINTIFF'S
SECOND SUPPLEMENTAL HESPONSE TO DEFENDANT'S HEQUEST FOR
PRODUCTION OF DOCUMENTS by depositing a copy of the same in the
United States Mail, postage prepaid, at HarriSburg,
Pennsylvania, addressed to:
Stephen E. Gedu1dig, Esquire
Thomas, Thomas & Hafer
305 North Front Street
HarriSburg, PA 17101
Respectfully sUbmitted,
SCHMIDT, RONCA & KRAMER, P,C,
BY: u~sh--
Shawn T. Peterson, Paralegal
209 State Street
Harrisburg, PA 17101
(717) 232-6300
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BARBARA JEAN PAYNE,
Plaintiff,
I tJ TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
STEPHANIE BRENEMAN,
Defendant.
NO. 98-6675
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
AND NOW this 3'd day of July, 2000, I, Shawn T. Peterson,
hereby certify that I have this day served a copy of PLAINTIFF'S
THIRD SUPPLEMENTAL RESPONSE TO DEFENDANT'S REQUEST FOR
PRODUCTION OF DOCUMENTS by depositing a copy of the same in the
United States Mail, postage prepaid, at Harrisburg,
Pennsylvania, addressed to:
Stephen E. Geduldig, Esquire
Thomas, Thomas & Hafer
305 North Front Street
Harrisburg, PA 17101
Respectfully submitted,
SCHMIDT, RONCA & KRAMER, P.C,
BY: .Uwk
Shawn T, Peterson, Paralegal
209 State Street
Harrisburg, PA 17101
(717) 232-6300
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BARBARA JEAN PAYNE,
Plaintiff,
HI TilE COURT OF Cot1110l1 PLEAS
Ctll.HlERLAND COUNTY, PENNSYLVANI.l'l
v,
CIVIL ACTION - LAW
STEPHANIE BRENEMAN,
Defendant,
NO, 98-6675
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
AND NOW this 7th day of September, 2000, I, Shawn T,
Peterson, hereby certify that I have this day served a copy of
the Plaintiff's Fourth Supplemental Response to Defendants'
Request for Production of Documents, by depositing a copy of the
same in the United States Mail, postage prepaid, at Harrisburg,
Pennsylvania, addressed to:
Stephen E. Geduldig, Esquire
Thomas, Thomas & Hafer
305 North Front Street
P.O. Box 999
Harrisburg, PA 17101
Attorney for Defendant
Respectfully submitted,
SCHMIDT, RONCA & KRAMER, P.C.
BY:
awn T. Peterson, Paralegal
209 State Street
Harrisburg, PA 17101
(717) 232-6300