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Home My WebLink About98-06873 I 1 , , t .1 , , , I I J IS !~ , I .U 1~ i I '1 ':0. ~ - ~ .~ cS t \. ~ - '. ';) . - 1'-1 j\'<) it-- 100 " ~i ~1 ! . i ~\ \ NOTICIA Le han dernaandado a usled en la corte. Si usted quieie 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 nolificacion. Usted d(~he presenlar una apariencia escrita 0 en persoa 0 por abogado y archivar en 1.1 corle enform.l escrila sus defensas 0 sus objections 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 uSled sin previo 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 importanled para usled. ~ ~ Date:'i)~ 7/ ISS r /" ;J;nf) !rjIU~A-f( David W. Knauer, Esq'uire Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME paR TELEFONO A LA OFICINA CUY A DIRECClON SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUJR ASISTENCIA LEGAl. CUMBELAND COUNTY LAWYER REFERRAL SERVICE Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 (717) 240-6200 ',;:: ;!'. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LORI J. DIMMICK 418 Little John Drive Dillsburg, PA 17019 Plaintiff CIVIL ACTION - LAW No. q f. (. J '13 (.LC'~( -r;-~ v. JUSTIN K. MICKLEY 370 Wenksville Road Biglerville, PA17307 Defendant JURY TRIAL DEMANDED COMPLAINT 1. The Plaintiff, Lori J. Dimmick, is an adult individual with an address of 418 Little John Drive, Dillsburg, Pennsylvania 17019. 2. The Defendant, Justin K. Mickley, is an adult individual with an address of 370 Wenksville Road, Biglerville, Pennsylvania 17307. 3. At all times relevant herein, the Plaintiff was the owner and operator of a certain 1992 Honda Accord LX. 4 At all times relevant herein, the Defendant was the owner and operator of a certain 1979 Chevrolet C 10 Pick-Up Truck. 5. In Lower Allen Township, Cumberland County, Pennsylvania, at the intersection of SR0114 and SR2017, four stop signs control the intersection. 6. On December 24,1996, at or about 6:55 P.M., the Plaintiff, who was traveling in a westerly direction on SR 0114 after stopping for the aforesaid stop sign at the aforesaid Intersection, proceeded through the intersection continuing to travel in a westerly direction. 7. On the aforesaid date and at the aforesaid time, the Defendant who was approaching the aforesaid intersection in a southerly direction on SR2017 failed to stop for the stop sign and struck the Plaintiffs vehicle as it was lawfully traversing the aforesaid Intersection traveling in a westerly direction. 8. The aforesaid collision was caused solely by the carelessness, recklessness and negligence of the Defendant in that he: a.) failed to lower his speed as he approached the aforesaid intersection; b.) failed to keep a vigilant outlook as he proceeded on the aforesaid road; c.) failed to see the Plaintiffs vehicle which was then proceeding lawfully through the aforesaid four stop sign controlled intersection; d.) failed to avoid striking the Plaintiffs aforesaid vehicle which was then and there proceeding lawfully through the aforesaid four stop sign controlled intersection; e.) was operating his aforesaid vehicle at a speed in excess of the distance his headlights illuminated in front of his vehicle in the darkness then and there extant; f.) was operating his vehicle at a speed in excess of the speed that was appropriate for the road on which he was traveling; g.) struck the Plaintiffs aforesaid vehicle; h.) was otherwise negligent. 9. Solely as a result of the Defendant's carelessness, recklessness and negligence the Plaintiff has suffered severe and sundry injuries to her person. 10. Solely as a result of the Defendant's carelessness. recklessness and negligence the Plaintiff has suffered the following elements of damages recoverable at law: a.) past and future medical expenses; b.) past and future pain and suffering; c.) past and future loss of enjoyment of life; d.) past and future emotional distress; e.) past lost wages; f.) impairment of future economic horizons; g.) other damages recoverable under the law of the Commonwealth of Pennsylvania. WHEREFORE, the Plaintiff demands judgment in her favor and against the Defendant in an amount in excess of the amount for mandatory referral to arbitration. Respectfully submitted. Date:f)~ 7) /97 Y DAVID W. KNAUER, P.C. @~;;)t) 1 J 0/ David W. Knaue~ Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 ~ ~ 1t~ ~ --.j. , , r') : ,\3 1\ " .. ...... '\ ~ N , ~ i ' " ...... ( , \ f'- ~ \\) 1: ~ '1 a \/1 ~ ~\ri \ . ,,- ~ ~ \J or respecting strategy or tactics and privileged communication from and to counsel) to the within action. 2. Any and all statemenls concerning the action, as defined by Rule 4003.4 from all witnesses including any statements from the parties herein, or their respective agents, servants or employees. 3. All photographs taken or diagrams prepared of the scene of the accidenVincident or any instrumentality involved therein. 4. Any and all documents containing the names and home and business addresses of all individuals contacted as potential witnesses. 5. Reports of any and all experts who will testify at Trial. 6. A copy of the Defendant(s) insurance policy. Respectfully submitted, DAVID W. KNAUER, P.C. Date: December 7, 1998 (;] I {uJiQ [11 ;:~ David W. Knauer,JEsquire Attorney for the Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 l -2- f~ i'he Court of Co 111 III on Pleus of Cumherl:lIHl Cotlnl~. Pennsylv:lI1i:l Lori .1. Dimmick VS. ,Just in K. Mickley s~ 98-687] Civil 19_ I'O\\', 12 I B/9S 19_.1 SIIEIUH OF CDIJIEIIL,\:>;D COr:>;TY. P,I do licrcli) dcpulizr lhc Sh"iffoC Adams Coune". tn clcculc tIlili \Vrit. this depue.uioD being made at the request and risk orchc Plaintiff. ~~~~. SheriCCoCCumbcrland Coun,).Pa. Affiduvit of Senice i'iow, within 19 . at o'c1uck :\1. served the upoo or b~. banding to att~sted copy of the original the contents thereof. .\ . a true and and n1:.lde known to So answers. SheriCr oC County. Pa. COSTS 5\\orn :Jnd suh,>crihcd before me this 19_ SERVICE MILE.-\GE ,\ HI D.-\ \'IT s day or 5 . -" .~ .... ~". ""' ~ ~ "" '" ,.. ,.., ,. ,.. r- ro. i',"~,.~Mft(,.1I11~:)lo.T DATE RECEIVED Of. TE PROCESSED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17325 ------------. _. - ... .._--.~-- ._._-~---~--,."._.--_.+. SHERIFF SERVICE PROCESS RECEIPT, end AFFIDAVIT OF RETURN INSTRUCTIONS: See "INSTRUCTlm,S Fon SERVICE OF PROCESS BY THE SHfnIH" on lhe IItV.,.. 01 thelasllNo 51 copy ollhll form Ple'M type Of ptlnlleglbly, inluring ,..d.tllhfy 01 all coplet 00 not del.ch .ny copMtI ACaD I!NY,I I. PLAINTIFF/SI .. COURT NUMBER LORI J, DIMMICK 98-6873 Civil 3. OEFENDANTISI ~.__.- .- ------- 4 TYPE OF WRIT OR COMPLAINT 'ntj P f' JUSTIN K, MICKLEY f3t;rp.c>t For.Pro:u:ti\<'l~~ Ib:im:nts; & IERVE 5. NAME OF INDIVIDUAL. COMPANY. CORPORATION. Eii:-!ciSEAvlCE OR OESCRIPTlON OF PRO~~I:!Rb5'!l~ SOlD . Justin K,Mickley 8. ADDRESS (51'"1 01 AFO. Aplrlmenl No , City, Bata. Twp . St.le end ZIP CODe) AT 370 Ilcnl:svillc Rd., Iliglcrvi lie, I'^ 17307 7. INDICATE UNUSUAL SERVICE: rl PERSONAL :-; PERSON IN CHARGE" DEPUTIZE "] CERT, MAIL U REGISTERED MAIL l-~ POSTED rJ OTHER Now, 19 , I, SHERIFF OF ADAMS COUNTY, PA., do hBreby deputize the ShB'iff of County to execute this Writ and make return thero! according to law. This deputation being made at the rBquest and risk of thB plaintiff. SHERIff OF ADAMS COUNTY 8. SPECIAL INSTRUCTlONS OR OTHEA INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N_B_ WAIVER OF WATCHMAN-Any deputy sheriHlevying upon or allaching any property under within writ may leave pme without a watchman. In custody 01 whomever is lound in possession, aller nOlltying person of levy or allachment, without liabilily on the part Ollluch deputy or the sheriflto any plaintiff herein lor any loss. destruction or removal 01 any such property before sheriU's sale thereol 9. SIGNATURE 01 ATTORNEY or other ORIGINATOR roquesting service on behall of: X PLAINTIFF :J DEFENDANT 10, TELEPHONE NUMBER t1. DATE David W, Knauer, Esq. SPA E BELOW FOR USE OF SHERIFF ONLY 12. I acknowledge receipt or the writ or complalnl as Indicated above. 717) 795-7790 DO NOT WRITE BELOW THIS LINE SIGNATURE 01 Authorized ACSD Deputy or Clerk and Title 13. Date Received 14. Expiration I Hearing date 15.1 hereby CERTIFY and RETURN thai I [}{hav. personallv served, :J have served person in charge. 0 have legal evidence 01 service as shown In "Aemarks" (on reverse) o have posted the above described property with Ihe writ or complaint described on the IOdividual. company, corporation, etc., at the address shown above or on the IndlYldual. company, corporation, elc.. at Ihe address Inserted below by handing/or Posting a TRUE .nd ATTESTED COpy therof. 16. 0 I hereby eer1ily and relurn a NOT FOUND because I am unable to locale tM individual, company, corporation, etc., named above. (See remarks below) 17, Name and title 01 Individual served 18. A person 01 luitable age and discretion Read Order I thenrllldlng In the derendanl'l ulual Ear ene Mickle randmother of Justin K. Mickle 'r""'......o 0 19, Address 01 where served (complete only II dllferenlthan shown above) (Slreel or RFD, Apartment No., Cily, Boro, Twp.. 20. Date 01 Service 21. Time State and ZIP CODE) 12/14/98 3:10PM 22, AnEMPTS Dep,lnt. Date Miles Dep,lnt. Dep.lnl. i':" :f,~;;." 23, Advance Costs 24. f$75.00 Fm. She . ff #23050 f.;, f:'~, '_:!(AFFIRMED and subscribed to before mo this <~; 25. 22.20 Pd. N A of '9 Slgnalure of Sheriff RAYMOND \,. NE\/MAN Date 12/14/98 SHERIFF OF ADAMS COUNTY 39, Dale Received Slephen E. Ooduldog. Elqu"e Allomey I D. No. 43530 THOMAS, THOMAS & HAFER, LLP 305 North Front Slreet PO'I OffICf Bo, 999 Harrisburg, Pennsylvania 17108 (717) 237.7100 E.Mall seQll'illthlaw.com Altorn"y. for Defendant JUSTIN K MICKLEY LORI J. DIMMICK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 98-6873 CIVIL CIVIL ACTION - LAW JUSTIN K. MICKLEY, Defendant JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Stephen E. Geduldig, Esquire, and Thomas, Thomas & Hafer, LLP, as attorneys for Defendant, Justin K. Mickley, in the above-captioned matter, reserving our right to answer or otherwise plead to Plaintiff's Complaint. Respectfully submitted, THOMAS, THOMAS ~R, LL~ . . ~I . f/ L' (,--(/ C ~,-//' -- it}1 ,rr} , . By: \ .1 ./ STEPHEN E. GEDULDIG, ESQUIR Attorney I.D. No. 43530 ,\~ :45898.1 Attorneys for Defendant, JUSTIN K. MICKLEY ,~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-6873 CIVIL ACTION - LAW JURY TRIAL DEMANDED LORI J. DIMMICK, v JUSTIN K. MICKLEY, Defendant ANSWER AND NEW MATTER OF DEFENDANT TO PLAINTIFF'S COMPLAINT AND NOW, Defendant Justin K. Mickley, by his attorneys, Thomas, Thomas & Hafer, LLP, files his Answer to Plaintiffs Complaint as follows: 1. Admitted upon information and belief, 2. Denied as stated. By way of answer, the address of Justin K. Mickley is 116 Heckenluber Road, Biglerville, Pennsylvania 17037. 3. Admitted upon information and belief, 4. Admitted. 5. Admitted, 6. Admitted. 7. Admitted. 8.a)-h) Defendant admits that he was responsible for the accident and Plaintiffs injuries and damages, if any. 9. Denied as a legal conclusion and pursuant to Pa.R.C.P, 1029(e). 10. Denied as a legal conclusion and pursuant to PaRC.P. 1029(e). WHEREFORE, Defendant Justin K. Mickley respectfully requests you Honorable Court to dismiss Plaintiff's Complaint without cost or judgment to it. CERTIFICATE OF SERVICE I, STEPHEN E. GEDULDIG, ESQUIRE of the law firm of THOMAS, THOMAS, & HAFER, do certify that I served the foregoing document on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: David W. Knauer, Esquire DAVID W. KNAUER, P.C. 411-A East Main Street Mechanicsburg, PA 17055 THOMAS, THOMAS & HAFER Date: ~.J .\' . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA LORI J. DIMMICK, Plaintiff CIVIL ACTION - LAW Y. No. 98-6873 JUSTIN K. MICKLEY, Defendant JURY TRIAL DEMANDED . !' .. REPLY TO NEW MATTER 11. The Plaintiff incorporates herein by reference thereto Plaintiffs Complaint as if more fully set forth herein. 12. - 16. Denied as alleged. The Plaintiff avers that paragraphs 12 through 16 of the Defendant's New Matter are conclusions of law to which no reply is required pursuant to the Pennsylvania Rules of Civil Procedure and strict proof thereof is demanded at time oftrial. '" i , WHEREFORE, the Plaintiff demands judgment in her favor and against the Defendant on the Defendant's New Matter. Respectfully submitted, DAVID W. KNAUER, P.C. David W. Knau squire Attorney for Plaintiff Attorney 1.0. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 Date:~/0!997 , . ! LORI J. DIMMICK Plaintiff CIVIL ACTION - LAW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 98-6873 JUSTIN K, MICKLEY Defendant JURY TRIAL DEMANDED . ~. CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that f did this 16th day of April, 1999. serve a true and Stephen E. Geduldig, Esquire Thomas, Thomas & Hafer, LLP 305 North Front Street H'"i'bY1~ (J J;~ David W. Knauer , Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 correct copy of the within document on all counsel of record by United States mail, first class, prepaid addressed as follows: ) .1 , .--1 " . .. Slephen E. Ooduldlg. Esquire Allomey 1.0. No. 43530 THOMAS, THOMAS & HAFER, LLP 305 North Front Street POll Office Bo' 999 Hlrrisburg, Pennsylvania 17108 (717) 237.7100 E.Mait: seClll'iltthlaw.com Attorneys for Defendant: JUSTIN K. MICKLEY LORI J. DIMMICK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 98-6873 CIVIL CIVIL ACTION - LAW JUSTIN K. MICKLEY, Defendant : JURY TRIAL DEMANDED RULE TO SHOW CAUSE AND NOW, this It/ day of /J~"re-(,v- ,1999, upon consideration of the attached Motion of Defendant, Plaintiff is hereby ruled to show cause why he should not serve full and complete Answers to Interrogatories and Response to Request for Production of Documents or show cause why Defendant's Motion should not be granted. RULE RETURNABLE '2" DAYS FROM DATE OF SERVICE BY THE COURT: /Ii- 1.' . ~. . \.).~ ~ ~ 0.; .~ '1 ~l". \.l '.' ~. .!, l;- ~~ ) I , ..J f: . . . ....~ r ~. (: ~ . I, , ! . .......- 1 l" :\ ~ . ~ Exhibit A . ... .-) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LORI J. DIMMICK 418 Little John Drive DiIIsburg, PA 17019 Plaintiff CIVIL ACTION - LAW , v. No. 9&. t,~?..J C~ . ' .-; . . ~ I I JUSTIN K. MICKLEY 370 Wenksville Road Biglerville, PA17307 Defendant JURY TRIAL DEMANDED .- " " .~., ,':" . , ;.'.: NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE 8EEN 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 an 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. .~I , CUM8ELAND COUNTY LAWYER REFERRAL SERVICE Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 TRUe (.,()py FRO . (717) 240-6200 In TIStj M RECORD and the frtOrry Whereof, I here unro sOt my ,.. r ' of said at Car1~Jt- :;~ ,\" . '. ',"~ fLf\'"'....~'~ ~ q. .:,) ".-:.;1...... ," . ~ ". .. , I"'" . "I' . ';: k' ;,,!, . NOTlCIA Le h.1n dem,lJnd"do ,\ u~ted en I" corte. Si u~led quieie defender~e de eslas demandas ('xpuesla~ en las pagina~ ~iguientes. u~ted liene viente (20) dias de plalo .11 partir de 1.1 fecha de 1.1 demanda y I" notificacion. Usted ueue presenlar una ap.1riencia escrita 0 en persoa 0 por abogado y archivar en 1.1 corle enforma escrita sus defensas 0 sus objections alas demandas en contra de su person". Sea avisado que si usted no se defiende, 1.1 corte lomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier quejol 0 alivio que es pedido en 1.1 peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importanted para usted. LLEVE EST A DEMANDA A UN ABOGADO INMEDIA T AMENTE. 51 NO TIENE A80GADO 0 51 NO TIENE El DINERO SUFIClENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 llAME POR TELEFONO A LA OF/ClNA CUYA DIRECClON SE ENCUENTRA ESCRITA A8AjO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENClA LEGAL. CUMBELAND COUNTY LAWYER REFERRAL SERVICE Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 (71 7) 240-6200 Date:r;;kJ<<r 7,. IS '71 /, . . '} . iv;Q / ~ / Lilt t(~ /l/Py/J!,- David W. Knauer, Esquire Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 -r.a~s'Oll~ ~tc. \ ~ \\j\j~ aforesaid intersection, proceeded through the intersection continuing to travel in a westerly direction. 7. On the aforesaid date and at the aforesaid time, the Defendant who was approaching the aforesaid intersection in a southerly direction on SR2017 failed to stop for the stop sign and struck the Plaintiffs vehicle as it was lawfully traversing the aforesaid intersection traveling in a westerly direction. 8. The aforesaid collision was caused solely by the carelessness, recklessness and negligence of the Defendant in that he: a.) failed to lower his speed as he approached the aforesaid intersection; b.) failed to keep a vigilant outlook as he proceeded on the aforesaid road; c.) failed to see the Plaintiffs vehicle which was then proceeding lawfully through the aforesaid four stop sign controlled intersection: d.) failed to avoid striking the Plaintiff's aforesaid vehicle which was then and there proceeding lawfully through the aforesaid four stop sign controlled intersection; e.) was operating his aforesaid vehicle at a speed in excess of the distance his headlights illuminated in front of his vehicle in the darkness then and there extant; f.) was operating his vehicle at a speed in excess of the speed that was appropriate for the road on which he was traveling; g.) struck the Plaintiff's aforesaid vehicle; l\an\SbUtg '\JtC 1 ~ \~~~ VERIFICATION Subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to authorities, I hereby certify that the facts in the foregoing pleading are true and correct to the best of my information and belief. Date: I ~. ~-9.( ~ ~'Vv9 'UJ,J:,,,u<k- ~att\s'oUtl} ~tC \ 'C \9~~ Exhibit B . , " " .' ,"(, .- . . Slepnen E Geduld'9. Esquire Atlorney I 0 No "3~30 THOMAS. THOMAS & HAFER, LLP 30~ North Fronl Street P01' OffICe Box 999 H.".,bufO, Pennsylvama 17108 (717) 237.7'00 E.Ma,' seQ(aitthlawcorn Allofney, fOf Dofendant JU~TIN K MICKLEY LORI J. DIMMICK. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 98-6873 CIVIL CIVIL ACTION - LAW JUSTIN K. MICKLEY, Defendant JURY TRIAL DEMANDED REQUEST FOR PRODUCTION OF DOCUMENTS OF DEFENDANT ADDRESSED TO PLAINTIFF Defendant hereby requests that you furnish pursuant to Rule 4009 of the Pennsylvania Rules of Civil Procedure, at our expense. or permit the Defendant or someone acting on its behalf to inspect. examine, and copy the following items conceming this action which are in the possession, custody, or control of the Plaintiff(s), counsel for Plaintiff(s). or any other person or entity acting on behalf of Plaintiff(s), including any insurer(s) for Plaintiff(s). Said items shail be produced or made available for inspection at the office of Defendant's attomeys located at 305 North Front Street, Harrisburg. Pennsylvania within thirty (30) days after service of this Request, on a date and time to be arranged between counsel: 1. All photographs showing. representing or purporting to show any of the vehicles, instrumentalities, locales, persons, property, injuries and any and all other matters related to the subject matter of this litigation. 2. All diagrams. sketches. drawings, plans. measurements or blueprints showing. representing or purporting to show any of the vehicles. instrumentalities. locales. persons. property, inJune~ 01' other matter involved in the incident which form the baSIS of Plaintiffs' Complaint or cause of action 3 All statements, includir.g but not restricted to those defined by Pa RC P. 40035. signed statements. transcripts of recorded statements or Interviews. or any memoranda or summary of transcripts of statements or interviews of any party, person or witness. or their agents or employees. who have any knowledge or information of the facts concerning or pertaining to the incident. the subject matter, the claims. the damages. injuries, or any other matter involved in or pertaining to this case 4. All expert opinions. expert reports, expert summaries or other writings. and curriculum vitae as to each such expert or experts which relate to the subject matter of this litigation and the incident in question. 5. All documents prepared by you or by any insurer(s), representative(s), agent(s) or anyone acting on your behalf, except your attorney(s), during an investigation of any aspect of the incident in question. Such documents shall include any documents made or prepared through the present time with the exclusion of mental impressions, conclusions or opinions respecting the value or merit of a claim or defense or respecting strategy or tactics. (NOTE: As referred to herein. "documents" includes written, printed, typed, recorded or graphic matter, however produced or reproduced. including correspondence, telegrams, other written communications. data processing storage units, tapes, videos, films, microfilm, microfiche, contracts. agreements. notes. memoranda, summaries, analyses. projections. indices. work papers. studies. test reports. test results, surveys. diaries, calendars, films. photographs, videos, movies, diagrams, drawings, sketches, minutes of meetings or any other writing [including copies of the foregoing. regardless of whether the parties to whom this request is addressed is not in the possession, custody or control of the onglnal) now In Ihe possession, custody or control of Plalnllffs. Ihelr former or present counsel, agenls. employees. officers. insurers or any other persons acting on their behalf.) 6. If nol otherwise covered by the above Requests. the complete claims/investigationlsubrogallonlinsurance tlle(s) of your Insurcr(s). tncludlno. but not limited 1Q. your first party automobile insurance carrier. and/or YO.!Jr worker's comDensatlon carrier. dealing with the incident in question. with the exclusion of the menial impressions. conclusions or opinions respecting the value or merit of a claim or defense. or respecting strategy or tactics. 7. All documents relating in any way to all injuries, damages and losses sustained by Plaintiff(s). This should include, but not be limited to bills, invoices, medical reports, medical records, receipts, hospital records. charts and x-rays, wage and employment information, and all other documents in any way relating to Plaintiffs' alleged injuries and damages. 8. Any release or other agreement between any person or entities given or obtained in regard to the subject incident. 9. Any and all documents evidencing or pertaining to any lien by any person or entity against potential recovery of damages by Plaintiff in this action. 10. All documents or exhibits which you intend to offer or identify as exhibits and/or evidence at any depositions or at the trial of this matter. 11. All documents, including but not limited to, advertisements. circulars, brochures, pamphlets. leaflets, writings and other such promotional items any expert witness you have retained for use at trial uses and has used in the past to promote his services as an expert witness. 12. All financial records conceming the Plaintiff including but not limited to any and all tax returns. W-Z's. and other filings. employment records. and wage or salary information. 13. Any and all documents which eVIdence any facts on the basis of which it will be asserted that the Defendant caused or contnbuted to the happening of the injuries sustained by the Plaintiff 14. Any documents identified in your Answers 10 any set of Interrogatories propounded by any party to this litigation. 15. All documents which would support any claims for injuries/damages averred in Plaintiffs' Complaint. 16. A copy of any declaration sheet for any automobile insurance pOlicy applicable to this case under which you are an insured. 17. All records regarding any treatment. consuhalion or therapy for any psychological or psychiatric condition, injury or issue. 18. Any document or thing obtained by subpoena or authorization. 19. Any other discoverable document or thing in your file. not specifically requested herein above. THOMAS, THOMAS & HAFER ,-'" . ,:::-" f By: :: .{j.z-./~,(' Stephen E. Geduldig, Esquire ) 1.0. No. 43530 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7119 i , , f . L Attomeys for Defendant Dated: \.: i .~. ;-.,1 ~1 '-''" i i L.-\\ \'\ \'-\\0\ Stephen e. OeduldlQ. eJQUtf'. Allorney I 0 No 43530 THOMAS, THOMAS & HAFER. LLP J05 North Front Slreet Post Office BOll 999 Hamsbuft), Pennsylvania 17108 (7t7) 237.7100 E.Ma.1 seQ!l'iltthlaw com Al!orncy~ 'or DefendJnl JUS TIN K MICKLEY LORI J. DIMMICK. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA v. NO. 98-6873 CIVIL CIVIL ACTION - LAW JUSTIN K. MICKLEY, Defendant : JURY TRIAL DEMANDED DEFENDANTS INTERROGATORIES DIRECTED TO PLAINTIFF DEFINITIONS "Document" means any written. printed. typed. or other graphic matter of any kind or nature. however produced or reproduced. including photographs. microfiims, phonographs. video and audio tapes. punch cards. magnetic tapes. discs, data cells, drums. and other data compilations from which information can be obtained. "Identify" or "Identity" means when used in reference to- (1) A natural person. his or her. (a) full name; and (b) present or last known residence and employment address (including street name and number. city or town, and state or country): (2) A document: (a) its description (e.g.. letter, memorandum, report. etc.). title, and date; l' ,.~ " , (b) its subject matter; .~ ;;; ,\ " :{ r< '. p. i I ~f! .1 '~ ! 1. State (a) (b) (c) (d) (e) (I) (g) (h) (i) ANSWER: Your full name. Each other name. d any. which you have used or by which you have been known; The name of your spouse at the time of the accident and the date and place of your marriage to such spouse; The address of your present residence and the address of each Crther residence which you have had during the past five years; Your present occupation and the name and address of your employer; Date or your birth; Your Social Security number; Your military service and positions held. if any: and The schools you have attended and the degrees or certificates awarded. if any. , I r t l^' i. i l' ~ , '. , , 5 (a) Identify each person who (1) Was a witness to the incident through sight or healing and/or (2) Has knowledge of facts concerning the happening of the incident or conditions or circumstances at the scene of the incident prior to, at the time of, or after the incident. I r i;' .,,1 (b) With respect to each such person identified. state that person's exact location and activity at the time of the incident. ANSWER: ) \ '. '. 9. If you. or someone not an expert subJect to PaRCP. No 40035. conducted any investigations of the incident. Identify: (a) Each person, and the employer of each person. who conducted any investigation(s); and (b) All notes. reports. or other documents prepared during or as a result of the investigation(s) and the persons who have custody thereof. ANSWER: ., ~ l r h l " 10. Identify each person you intend 10 call as a non.exper1 witness at the tnal of this case, and for each person idenlified. state your relationship with the witness and the substance of the facts to which the witness is expected to testify ANSWER: I 1-' , , If.~ ;f ,I, Ii "". '. J' ' ""~ ;\: I '. 13. If you intend to use any book. magazine, or other such writing at trial. state. (a) The name of the writing: (b) The author of the writing; (c) The publisher of the writing; (d) The date of publication of the writing; and (e) The identity of the custodian of the writing. . ~. . .. ANSWER: .." t~ ~ " 19. If, either prior to or subsequent to the incident, you suffered any injury or disease in those portions of the body claimed by you to have been affected by the incident state: .,. ..~ .~, /' f T\ 'j I .J I~ . (a) The injury or disease you suffered; (b) The date and place of any accident. d such injUry or disease was caused by an accident; (c) The identity of hospitals. doctors, or practitioners who rendered treatment or examination because of such injury or diseases; and ',. l' (d) The identity of anyone against whom a claim was made, and the tribunal and docket number of any claim or lawsuit that was filed in connection with such injury or disease. f ANSWER: 21 Please state the name, address. and telephone number of your family physician and each and every physician you have consulted in the last five (5) years pnor 10 the dale of this incident. as well as indicate the date in which Plaintiff lasl consuned any physIcian for any type of phYSical complaint and the reason for such consultation ANSWER: j."; J:! . 22 Have you fully recovered from any of your injulles. and If so. slate the approximate date of recovery. If you have not recovered from any of your injuries, stale those injuries from which you have not recovered. and in what respects you have not fully recovered , ANSWER: l I '. !:' 'I i , -/ 1 ;r a II. I~ ~ ,r' , ..t I.:., 1<, c. 'f:\:. I"" '^ i'J ) j., 24. Have you ever suffered any Injuries in any accident. either pnor to. or subsequent to this incident? If so, please state a the date and place of such inJury; b a detailed descnptlon or the injunes received; c. the names and addresses of any and all hospitals or doctors rendering treatment; and d. the nature and extent or recovery and. if any permanent disability was suffered, the nature and extent or such permanent disability. ANSWER: 25. Stale whether you have ever receIVed psychiatric or psychological care or treatment. and if so. stale the IoIlowing: (a) the nature 01 lhe disorder lor which you were treated and lhe name and address and specially of the person lreallng you; (b) the dates lor which treatment was given; and (c) whether you were ever confined to any institution for the treatment of such disorders. and If so. slate the name and address of such institutions and the date of confinement. ANSWER: " ') t.......: ~~ , I'} .::.. I , , . I'" rl~); f ,".;~'i Itr:;~"f {rw. I"...'''..... C.~ , , j.... i......., I'/i '''i~_ I .~~. {~~~.:' 26 SpeCIfically stale the 'severe and sundry injuries' you claim you suffered as a result of this incidenl. as referenced In Paragraph 9 of your Complaint: please do not refer Simply to the medical records. ANSWER: 29 II you consumed any alcoholic beverage, sedative. tranquilizer. marijuana. cocaine, hashish, or other drug, medicine, or pill during the ei~ hours immediately preceding the incident. state: (a) The nature. amount. and type of item consumed. (b) The amount of time over which consumed: (c) The idenl~y of any and all persons who have any knowledge as to the consumption of those items; and (d) The identity of the physician or medical practitioner or other person who gave. purchased, or prescribed any of said items, if any. , . t' ANSWER: . .~ 31. For the penod of five years immedIately preceding lhe date of the inCIdent. state (a) the name and address of each of your employers, or If you were self- employed dUring any portion of that period, each of your bUSiness addresses and the name of the business while self-employed; (b) The dates of commencement and termination of each of your periods of employment or self-employment: (c) The nature of your occupation in each employment or self-employment; and (d) The wage, salary, or rate of earnings received by you in each employment or self-employment, and the amount of income from employment and self- employment for each year. ANSWER: ) I , " \ ~ i !i I.' 33. If. as a resutt of this incldcnt, you have been unable to pcrform any of your customary occupational dutics or social or othcr actlvilies In thc samc manner as prior to thc incidcnt. state with particularity (a) (b) (c) ANSWER: The dutics and/or actlvilles you have been unable to perform. The periods of time you have becn unable to perform; and The identity of all persons having knowledge thereof. ," I '. ::.' ) .1 l '." . .' ,_. 33. Identify the source and state the amount and date of any and all benefits or payments of any kind that you have received or have been paid on your behalf because 01 losses you sustained or expenses you incurred as a result of the subject accident, including but not limited to all first party insurance benefits. workers' compensation. medical expense coverage and compensation for disability, sick leave, vacation time, dismemberment or disfigurement, death. income or hospital indemnity and lost income or earnings. ANSWER: . :' ) .\ ; -, , r r . "\ Exhibit C . : .' Stephen E. Ooduldig. Esquire Allomey 1.0. No. 43530 THOMAS, THOMAS & HAFER, LLP 305 North Front Streel POll OffICf Box 999 Harrisburg, Pennsylvania 17108 (717) 237,7100 E.Mall: seo@tthlaw.com Attorneys for Defendant' JUSTIN K. MICKLEY LORI J. DIMMICK, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 98.6673 CIVIL : CIVIL ACTION - LAW JUSTIN K. MICKLEY, Defendant : JURY TRIAL DEMANDED BRIEF IN SUPPORT OF DEFENDANT'S MOTION TO COMPEL PLAINTIFF TO ANSWER INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS I. FACTUAL AND PROCEDURAL HISTORY This matter was initiated by a Complaint filed on December 7, 1998, alleging that Plaintiff, Lori J. Dimmick, received injuries to her person and suffered injuries to her person when the vehicle in which she was the driver collided with a vehicle operated by Defendant. Plaintiff's Complaint alleges negligence and carelessness on the part of Defendant in connection with the auto accident. On April 14, 1999, Defendant served upon the Plaintiff Interrogatories and a Request for " .~ Production of Documents. On June 30, 1999, counsel for moving defendant wrote to Plaintiff's matter forward. To date, Defendant has not received responses to these discovery requests, nor counsel and requested that he serve the appropriate discovery responses, in an effort to move the have they been objected to. An extension requested by Plaintiff has expired. '" ~ Respectfully submitted. THOMAS, THOMAS & HAFER ~/. By: Stephen E. Geduldig, Esquire I.D. No. 43530 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7119 Attorney for Defendant """. 1 fO~\ ~j IN TilE COllin OF COMMON PLEAS OF ClIMJJEIU.ANI> COlINTY.I'ENNSYLV MilA LORI J. DIMMICK, Plaintiff FILE NO: 98.6873 CIVIL. ACTION. LAW VS, JUSTIN K, MICKLEY, Defendant : ,JURY TRIAL DEMANI>ED WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the entry of appearance of thc undersigned as counsel of record for the Plaintiff, L.ori J. Dimmick. DATED: SePtember~. 1999 ~' DAV W. KN .- f ! I I , _. LA/' By: ,~ avid W. Knaue . Esquire Supreme Court I.D.#21582 41 I-A East Main Street Mechanicsburg, P A 17055 (717)795-7790 ENTRY OF APPEARANCE Please enter the appearance of the undersigned as counsd of record for the Plaintiff, Lori J. Dimmick. t' II DATED: September.LilL. 1999 KA THERMAN, BRIGGS & GREENBERG o . riggs, Esquire upreme Court I.D.#52987 31 South Queen Street York, PA. 17403 (717) 848-3838 CERTIFICATE OF SERVICE I, STEPHEN E. GEDULDIG, ESQUIRE of Ihe 1,Iw firm of THOMAS, THOMAS, & HAFER, LLP do certify Ihatl wrved Ihe foregoing documlml on Ihe following person(s), by deposiling the same in the United Slales Mail, poslage prepaid, .II H,lIIisburg, Pennsylvania addressed as follows: John Briggs, Esquire KATHERMAN, 8RIGGS & GREENBERG 31 South Queen Street York, PA 17403 THOMAS, THOMAS & HAFER, LLP ?lj~1Jt. STEP~QUIRE .., COMMONWEAL TH OF PENNSYLVANIA COUNTY OF CUMBERLAND 1.0HJ .J. Dlr-1:-1ICY, P },ll nt iff I tl THE ('C,OPT rw :~i'~~:'~,' .:; i':,Ei\:; '/. tV). ~tn '. 68.' 3 JUST I N r:. MICKLEY, [)t.'[endt1ol JUil'{ THIrd. iJK~~Mj[)E!l SUBPOENA TO PRODUC~ DOCUMENTS OR THIN~~ FOR DISCOVERY PURSUANTJQ RUL_E 4009.22 TO: Custodian of Records. Ronald Schlansky. MD, Medical Arts Building. Suite 106. 220 Wilson Street, Carlisle, PA 17013 (Name of Person or Enlily) Within twenty (20) days afler service of Ihls subpoena. you arc ordered by Ihe court 10 produce Ihe follOWing documents or things' Complete co Dies of any and all records. reports. notes. corresDondence. memoranda and diaqnoslic studies reqardinq Lori J. Dimmick. SSN: 187-38-2873. Date of Birth: 9/1/62 at: Thomas. Thomas & Hafer. LLP. 305 N Front St.. P.O. Box 999. Harrisburq. PA 17108- 0999 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena. together with Ihe certificale of compliance. to Ihe party making Ihis request al Ihe address lisled above. Vou have Ihe right 10 seek in advance. the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena. within twenty (20) days after its service. the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Stephen E. Geduldig, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7119 SUPREME COURT ID#: 43530 ATTORNEY FOR: Defendant \: ~. ?" f,':. BY THE COURT: DATE: dl>'. ~)/ Jt',('(l Seal of the Court i~/ dt?/!:'" f;;,..-:"-' ~~~/,7 Prothonotary/Clerk, Civil Division D;J;;vud' F. ,>1/? 9f;f , '. ~- '. !:, ~f ~ (4/97) ~i :~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND 1.01(1 .1. DIr'I~IICK, PI <l i nt i I I I N THE COUP'!' elF CfA":"(J!l ['r.Ll\;~ v. rlO. "8- (,8 Fl JUSTIN K. MICKLEY, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR OISCOVERY PURSUANT TO RULE 4009.22. TO: Custodian of Records. KDV Orthopedics/J. Joseph Danyo. MD. 908 South George Street. York. PA 17403 (Name of Person or Enllly) Within twenly (20) days afler service of Ihis subpoena. you are ordered by the court 10 produce Ihe following dOf":.Jmenls or things: Complete copies of any and all records. reports. notes. corresDondence. memoranda and diaonostic studies reoardino Lori J. Dimmick. SSN: 187-38-2873. Date of Birth: 9/1/62 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburo. PA 17108- 0999 (Address) You may deliver or mail legible copies of the documents or produce Ihings requesled by Ihis subpoena. togelher wilh Ihe certificate of compliance. 10 the party making Ihis request at the address listed above. You have Ihe righl to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce Ihe documents or things required by this subpoena. within lwenly (20) days afler ils service. Ihe party serving this subpoena may seek a court order compelling you 10 comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Stephen E. Geduldig, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7119 SUPREME COURT ID#: 43530 ATTORNEY FOR: Defendant ~','~ j:- !. f' , !. BY THE COURT: DATE: (;1,.,'1" ~7/ ..?c/IJ Seal of the Court /5/ ~/~/. '" '~~I;~-' Prothonotary/Clerk, Civil Div' Ion De;1t/;'''- /"./<;;4, ~ (4/97) l~ [' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LORI J, DIMMICK, Pl din. i f ( III Tm; COURT OF COMr10N PLEAS v. 110. 0,8-6873 JUSTIN K. MICKLEY, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Jay J. Cho, MD, 5124 East Trindle Road, Mechanicsburg, PA 17055 (Name of Person or Entity) Within twenly (20) days after service of Ihis subpoena. you are ordered by the court 10 produce Ihe following documents or things: ComDlete copies of any and all records. reDorts. notes. corresDondence. memoranda and diaonostic studies reqardino Lori J. Dimmick. SSN: 187-38-2873. Date of Birth: 9/1/62 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburo. PA 17108- 0999 (Address) You may deliver or mail legible copies of the documents or produce things requesled by Ihis subpoena. together wilh Ihe certificale of compliance. to the party making Ihis request at Ihe address listed above. You have Ihe righllo seek in advance. the reasonable cost of preparing the copies or producing the things sought. \ , If you fail 10 produce the documenls or Ihings required by this subpoena, wilhin twenly (20) days after ils service. the party serving this subpoena may seek a court order compelling you 10 comply wilh it. l !i t I' I t , I ~... t.. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: StephE;n E. Geduldig. Esquire ADDRESS: P.O. Box 999. Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7119 SUPREME COURT ID#: 43530 ATTORNEY FOR: Defendant BY THE COURT: DATE: (]"., ,;,'!, de;?? S&o3l of the Court / /'...L. ,r'J /.1 I. /'h~'; ;;(-. ,,7y....' Prothonotary/Clerk, Civil D' ision -1:'. >>./f::' fk 7/' /7 . ~':"';-/''''/'''-; Deputy (4/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LOPI J. O::-1MIO:, Plaln:l ff rrl THE COtJ?7 OF C:MMOr: PLEA~ v. NO. 9'3-687) JUSTIN K. MICKLEY, Defend<:1nt JUP:( TPIAL OE:'!AtIDE:I SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records. Shepardstown Family Practice. 2140 Fisher Road, Mechanicsburg. PA 17055 (Name of Person or Entity) Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following documents or things: Complete copies of any and all records. reports. correspondence. memoranda. notes and diaonostic studies reoardinQ Lori J. Dimmick. SSN: 187-38-2873. Date of Birth: 9/1/62. from April 1999 to the present at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. HarrisburQ. PA 17108- 0999 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance. to the party making this request at the address listed above. You have the right to seek in advance. the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena. within twenty (20) days after its service. the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Stephen E. Gedu1di9. Esquire ADDRESS: P.O. Box 999, Harrisburg. PA 17108-0999 TELEPHONE: (717) 237-7119 SUPREME COURT 10#: 43530 ATTORNEY FOR: Defendant BY THE COURT: DATE: /~_ltlrAc)., ~. d-.CY::O Seail of the Court k;/ (',w.Jit ilK 1J'n1. Prothonotary/Clerk, Ch$ Division IZI".B --/?;}W/L! /lit. -Ihv?<'(~ x9n Deputy If (4/97) CERTIFICATE OF SERVICE I, STEPHEN E. GEDULDIG, ESQUIRE of lhe law firm of THOMAS, THOMAS, & HAFER, llP do certify lhal I served the foregoing documenl on lhe following person(s), by depositing the same in the Uniled Slates Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: John Briggs, Esquire KATHERMAN, BRIGGS & GREENBERG 31 South Queen Street York, PA 17403 THOMAS, THOMAS & HAFER, llP 8/2/00 STEPHEN E. GEDULDIG, ESQUIRE ! .~. ~:.> >~ , " - .' " '-:':J "'l J ~:~~ . ~::2 c. I" U. -j o I \ I 1\