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HomeMy WebLinkAbout00-06534 ~ "_",,u,; "~-'";,,.. ";;..-tit;; JIMMIE L. BONNER, JR. and VEETA L. BONNER, his wife Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. aJ - k53 t.f 6;J : CIVIL ACTION - LAW v. WILLIAM C. MURDORF Defendant : JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in Court. If you wish to defend against the claims set forth in the following papers, 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 Two Liberty Avenue Carlisle, Pennsylvania 17013-3387 Telephone: (717) 249-3166 Date: 9//)s-!fJooo { . ary , Esquir laintiffs alnut Street Harrisburg PA 17101 (717) 238-4798 (717) 238-4793 - Telecopier Pa. 1.0. No. 25827 i,'.-'.-';' ;;,,':;,;.' "ll.' 0,""" JIMMIE L. BONNER, JR and VEETA L. BONNER, his wife Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 0-0- &$3'1 ~ ~ WILLIAM C. MURDORF Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT COUNT I Jimmie L. Bonner, Jr. v. William C. Murdorf AND NOW, comes the Plaintiffs, Jimmie L. Bonner, Jr. and Veeta L. Bonner, his wife, by their attorney, Lawrence J. Neary and respectfully represents as follows: 1. Plaintiffs, Jimmie L. Bonner, Jr. and Veeta L. Bonner, his wife, are adult individuals residing at 545 S. 16th, St. Harrisburg, Dauphin County, Pennsylvania. 2, Defendant, William C. Murdorf, is an adult individual residing at 15 Birch St., Mechanicsburg, Cumberland County, Pennsylvania. 3. On November 25, 1998 at or about 4:25 p.m. Plaintiff, Jimmie L. Bonner, Jr., was the operator of a motor vehicle stopped at the red light at the intersection of St. Johns Dr. and the Carlisle Pike in Cumberland County, Pennsylvania, at which time and place the Defendant, William C. Murdorf, caused or allowed his vehicle to collide into the rear end of the Plaintiffs vehicle. , . . -, - ,~-" -'~" ~ -, ." ,'-- 4. This accident resulted solely from the negligence and recklessness of the Defendant herein and was due in no manner whatsoever to any act or failure to act on the part of the Plaintiff. 5. The negligence and recklessness of the Defendant consisted of the following: a, Failure to properly operate and control his motor vehicle. b. Driving at an excessive rate of speed under the circumstances. c. Operating his vehicle without due regard for the rights, safety and position of the Plaintiff at the point aforesaid. d. Following another vehicle more closely than is reasonable and prudent under the circumstances. e. Operating his vehicle in violation of the statutes of the Commonwealth of Pennsylvania pertaining to the operation of vehicles on the streets and highways. f. Failing to keep a reasonable and proper look out on the highway for other vehicles. g. Failing to stop his vehicle within assured clear distance ahead. h. Failing to exercise a degree of care, caution and skill reasonable required under all the circumstances. i. Failing to have his vehicle under proper control so as to prevent this vehicle from striking the Plaintiff's vehicle. j. Failing to notice the vehicle of the Plaintiff. 2 -<- , <".- :--'j'!ti k. Failing to take evasive action in order to avoid impacting with the Plaintiffs vehicle. I. Failing to apply his brakes in sufficient time to avoid striking Plaintiffs stationary car. 6. As a result of this accident, Plaintiff has suffered injuries which are or may be serious, including cervical strain, neck stiffness with burning sensation, severe headaches, dizziness, spasm in the left trapezius area, reversal of the cervical lordotic curve, bulging of the C4-5 and C5-6 discs, anxiety attacks, severe stiffness and tenderness of the cervical paraspinal muscles, C5-6 nerve root irritation, evidence of Carpal Tunnel Syndrome, burning sensation in his face, chest pain radiating down his left arm, muscle tightness in his suboccipital and upper trepezius musclature, decreased cervical range of motion, decreased upper extremity strength, seizure like symptoms, cervical fracture at C-6; severe damage to the nerves and nervous system, and various other ills and injuries. 7. The injuries sustained by the Plaintiff, as set forth above, are serious injuries which have resulted in a serious impairment of bodily functions. 8. As a further result of this accident, Plaintiff has been obliged to receive and undergo medical attention and care and to incur various expenses which expenses have exceeded the sum recoverable under the limits in 75 P.S. Section 1711 and may be obliged to continue to expend such sums or incur such expenditures for an indefinite time in the future. 3 , L_' -.'~-" " 1j 9. As a further result of this accident, Plaintiff has suffered a severe loss of earnings and impairment of earning capacity which such loss of income and/or impairment of earning capacity or power have exceeded the sum recoverable under the limits in 75 P.S. 1711. 10. As a further result of this accident, Plaintiff has suffered severe physical pain, mental anguish, inconvenience, humiliation, and loss of life's pleasures and may continue to suffer the same for an indefinite time in the future. COUNT II Veeta L. Bonner v. William C. Murdort 11. Paragraphs 1 through 10 are incorporated by reference herein. 12. As a result of said injuries, Plaintiff has suffered a loss of services and society of her spouse during the time that said spouse has suffered from said injuries and will continue to suffer such a loss in the future. 4 ~'.,- ",' "'.';-- -' ~ - - 1> WHEREFORE, Plaintiffs demand judgment against the Defendant in an amount in excess of $35,000.00 plus costs of suit. Respectfully Submitted, Date: 9/JS)JoOc) 1 ' 5 ,--~- -. ~ '='"' "-''',-,~''. "-w ^, ". -:'! VERIFICA TlON I verify that the statements made in the attached Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: '1 /~2 / dOOO I f ~~~fI. Jimmie L. Bonner, Jr. p~~ Veeta L. Bonner :: ~liiiilii"OO.il'-~ ii!I~!ii1~~!ii~"14""i~~lliI.m . '.4iliil I ~_.' """- ~ , ~ ~ v-.. ~ 0 C~ r-. \ (~' 1:J ' , , C -:1 ~ ~ s:. V> ~ t... ""OeD ;'q ~fT1 -" :;IJ -,:,.,'.-, ~ '\~ \. zc f'-' , '~',C-:l " \ CfJ~:; a. ;-., ' ::;L _<C) C) .'\ r.;.o .'T.J- ..L---;'-1 ....... '\ ~o -,,- ;;:~~ -0 ~ )>c: u , :;; ~ ~ 1J1 'D ~ co '-< ',~.--,',,--,, _-':'_<,:J .,~"_",,,,"_,,__~..,,"'_,~',_." "--:1'-' ~-- "C'_ _.',~" ':~I ,",,:-__,., ^ ,~ < . -,- ..,.' -'.-,-- -~.. ~" ~ , "",,"-,",,, "","' . <"._~ ,- , -~.~ " . ~-, - , -, , -,,,,,, SHERIFF'S RETURN - REGULAR CASE NO: 2000-06534 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BONNER JIMMIE L JR ET AL VS MURDORF WILLIAM C HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MURDORF WILLIAM C the DEFENDANT , at 0016:04 HOURS, on the 28th day of September, 2000 at 15 BIRCH STREET MECHANICSBURG, PA 17055 by handing to WILLIAM MURDORF a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.20 .00 10.00 .00 34.20 So Answers: ~~r~~~< R. Thomas Kline 09/29/2000 LAWRENCE NEARY Sworn and Subscribed to before By: ~~er~ me this S-'t:: day of ()~ ~-tni!> A.D. ~.>a,~~ Prothonotary I - '-~ ~ . ", 00 ,,' d ,,--'",--, . ,_,_;,~_2!1 - , > Jimmy 1. Bonner, Jr. and Veeta 1. Bonner, his wife IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 00-6534 CIVIL v. CIVIL ACTION-LAW William C. Murdorf Defendant JURY TRIAL DEMANDED Ili..~ilili.llii._.I) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter the appearance of Thomas E. Brenner, Esquire, of Goldberg, Katzman & Shipman, P.e. as counsel on behalf of Defendant William C. Murdorf. By: Respectfully submitted, ~& 320 Market Street, Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorney J.D. #32085 Date: (0 -,).-t. -01) AttornlJ' for Difendant William C. Murdorf .',--,'; '-" ~, ' .0{ji . ' . CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon the person(s) indicated below by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania and addressed as follows: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101 GOLDBERG, KATZMAN & SHIPMAN, P.C. BY: (lhlP'~ G. ~ Thomas E. Brenner, Esquire Date: October 30, 2000 53973.1 , . 7. " __~_~-"'_" __0," ,. - ".-',....""'" '--" ...<'~..... . ~ , ~" (') c: 3': "Orr fTlfTl Z:X:' Z'--' c6~--: ~-'~ ~C] ~o =0 .....c ~ -< (--. cS c:> " ...... [-.) _c. L ~~ tl~ i5r'1 ~ )::,,; ::D -< -0 -rr- ..-'.. N ''':> 1''';; 'U"( n_~ "h" ,- ~" , Thomas E. Brenner, Esquire In # 32085 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Slreet p, 0, Box 1268 Harrisburg, PA 17108,]268 (717) 234,4161 h,,'-__' ~,' ~- -,-- ,. ,-".::_f"'.:-,,,,_' -- ~". & '''',< Counsel for Defendant JIMMY 1. BONNER, JR. and VEETA1. BONNER, his wife Plaintiffs v, WILLIAM C. MURDORF, Defendant TO: Plaintiffs, Jimmy 1. Bonner, Jr. and Veeta 1. Bonner c/o Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, P A 17101 - IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO, 00-6534 CIVIL CIVIL ACTION-LAW JURY TRIAL DEMANDED NOTICE TO PLEAD You are hereby notified to plead to the enclosed Answer with New Matter within twenty (20) days from service hereof or a default judgment may be entered against you, Date: II _ ID/oj) Respectfully submitted, BY: GOL KATZMAN & SHIPMAN, P.c. -~ Thomas E. Brenner, Esquire ID#: 32085 PO Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorney for Defendant, William C. Murdorf , Thomas E. Brenner, Esquire LD. # 32085 GOLDBERG, KATZMAN & SHIPMAN, P.e. 320 Market Street p, 0, Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 ,-- - "--- ,-"^" Counsel for Defendant JIMMY L. BONNER, JR, and VEETA L. BONNER, his wife Plaintiffs v, WILLIAM C. MURDORF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 00-6534 CIVIL CIVIL ACTION-LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANT. WILLIAM C. MURDORF COUNT I JIMMIE L. BONNER, JR. v. WILLIAM C. MuRDORF AND NOW, comes the Defendant, Willialn C. Murdorf, by his attorneys, Goldberg, Katzman & Shipman, p,c. who state: 1. Admitted, 2, Admitted, 3, Denied, This paragraph is denied pursuant to the Pa.R.C,P 1029(e) and proof thereof is demanded, 4, Denied, This paragraph states a serious oflega! conclusions to which no response is necessary, 5, Denied, This paragraph is denied pursuant to the PaR c.p, 1 029( e) and proofthereof is demanded, , '<~-~ ",~, ,;,' *~ " , - ~ --', ~ "L'-',.,-_"",',.,___ ",-,~-,-,;" ,. , - ,,, .- "-:,,";'-',::5:i/L:",V":'; "'~ .",~,,,~)"-,,,;'. ... 6. Denied, This paragraph is denied pursuant to the Pa.R, c.p, 1 029( e) and proof thereof is demanded. 7, Denied, This paragraph is denied pursuantto the Pa.R. C,P. 1 029( e) and proof thereof is demanded. 8, Denied, This paragraph is denied purSUant to the Pa.R. C,P, 1 029( e) and proof thereof is demanded, 9, Denied, This paragraph is denied pursuant to the Pa,R. c.p, 1029( e) and proof thereof is demanded, 10, Denied, This paragraph is denied pursuantto the Pa.R. C.P. 1 029( e) and proofthereof is demanded, WHEREFORE, Defendant, William C. Murdorf requests that Count I of the Plaintiffs' Complaint be dismissed with prejudice, COUNT IT VEETA L. BONNER, JR. v. WILLIAM C. MURDORF 11, The answers to paragraphs 1-10 are incorporated herein by reference, 12. Denied. This paragraph is denied pursuant to the Pa,R. C.P. 1 029( e) and proof thereof is demanded, WHEREFORE, Defendant, William C. Murdon requests that Count II of the Plaintiffs' Complaint be dismissed with prejudice, 2 -"0'. ,- "'-''';:-'''",,~'',''''''',' . '~o_ _ "'~ '" "_-__, '\ "" __ ,',-',=:-.:i NEW MATTER 13, Plaintiff s IDJunes, if any, arose from his comparative negligence under the circumstances, 14, Plaintiffs injuries, ifany, arose from events unrelated to the motor vehicle accident of November 25, 1998, 15, Plaintiff s injuries, if any, arose from his assumption of the risk. WHEREFORE, Defendant, William C. Murdorf, requests that the Plaintiffs' Complaint be dismissed with prejudice, Respectfully Submitted, Date: ~ ~ By: Thomas E. Brenner, Esquire 320 Market Street, Strawberry Square P,O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorney J.D. #32085 Attorney for Defendant William C. Murdorf 54371.1 3 ,_,C, f_-:~-'_,,_, ~-"-,~,,_,,-,,...O~_"~_';"'_'.' '_c;; ;,',;_. VERIFICATION I, William C, Murdorf, hereby acknowledge that I am the Defendant in this action and that I have read the foregoing document 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, Date /1/ ~1"' / ~, 'J-aZ;O l1J~ e~ William C. Murdorf '.'.-"" -;i.--,'\.,,~ C:.'__", ',-e' 'O"'-'I; -- ~-.-~ ,.-~'" c .. ~,CT-<".".-;~ "q_- "C' -'-, . ",=' ',- ','-" - -" -.~-; ,,,,--,~,; o. ~.-~. ,,',,--,-=' .- "' ."t',;"C n . . . . . . CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon the person(s) indicated below by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania and addressed as follows: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, P A l7I 0 I BY: & SHIPMAN, P.c. Date: November 13, 2000 53973.1 '^ ,.I , ~,' .-,^ " ,~ ,," ",. ~-,-~ ' "... -~Iti '"" ~, ',---- ~ "'-"'~-' -'-'~ '~ '-~' -~, - ~ - 11III ~ >, ~ , .., 0 r~" (~; ,-~i C, C.J .,,\ < -U , en r~" ..:::, ," " r:;, en -,/ ~ ..C' ~~- -" )~: C) r C .-7 A~, ::> :'2 \,,) '" . . "-, ~ "" -', CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JIMMIE L. BONNER, JR, ET AL TERM, -VS- CASE NO: 00-6534 WILLIAM C. MURDORF As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of THOMAS E. BRENNER, ESQUIRE 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 04/05/2001 {<ifS on ~~ ~~ ~RENNER, ESQUIRE Attorney for DEFENDANT . DE12-212930 56502 - LO 1 ';-0 ~1i301.04"L?J!:, 12I1l0? '.jj,' tm 001 ths6 P.Sl/01 . ~"J;i 04/06/01 FRI 10:20 FAX 111 238 4193 , LAW OFFICES 1601 M~,I:<( SITeet, Suire SOO, :Pbiladelphi. PennsylviUli. 19103 (215) 246 ,Il900 Fax Numl>e, (215) Z46 _ (J959 <Mai") URGENT!!!!! URGENT!!!!! URGENT!!!! ! &'RlL 5, 2001 J'lM'llJ:; I.. ffiNNER. JR JlM1IE L. ~. JR. E'f AL V, Wl!.I.lAM. c. t1lRlIlRF GlJ1.IJB/!IlG, K'lT7.WJ\I. ET N. 'lBMAsJ::. ~ ~_ ()_ ~ have l-"'=Ul. ~S;t.od ~ "..he .;t'b::nn:!-m=ntla:1er1 COlJr'l:"-Iel to obtain IIBter~l on an ~tacl basis iron tl.. leJ.a,; li<ted cu..tali",,". In on:ler: ~ c<llp4> with this ..,quesr: "" In.1St. b""" )'tur sigPatua :i1>rlicaHng <hat. ycu w.ll"'" ,.he lOIa1ty-dBy ll<ll:ice l"'riDd I>alU'i<Iad in Ill:U,",s 4009.ll !lI)d 4QQ~.?'?'. Plea"" fax this form t." \Ill ll:nmd:iately aC (ill) 2."6-09S9 wirlz YL>J~ ""~ .0 that "'" ""'y cOIply ...;,>h thi. """"'... Yoor cCDp',r"Ucn ""'-lld I:e greatly "l'J?I'OCi.atod. S:1n.f;lo-!re 1 y. Sl\lCINl\!i PI'.Icr ~~:iJt" 'IRIS'IJoN J\S!Q:IIl:I1:5 lWlRT.5BUPL: lillSPl:J:AL !fJ[,y ,,pTRlT !IlJ5PI'l'AL - X"AAV C\l!LY - X'~ <'lNLy - X-RAY ONLY O:unse!:;, ~ J.~. ~ rY~~l3 L'!- /, / I agrrn ;:" '-'Oi"", Wliting ~ric>.i, . 'UM .Th.te: ~!,-,11 Copies, 'fe. _ tb_ I do ilL''', /s{7'~ to wai~ L'1.I!~;; I, _. . _Iht.e~__~ RR\/'l.-132694 5650:2.-CO:L. ." >.--- ~-r"''''IiiIlm-;, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JIMMIE L. BONNER, JR, ET AL TERM, -VS- CASE NO: 00-6534 WILLIAM C. MURDORF NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TRISTAN ASSOCIATES HARRISBURG HOSPITAL HOLY SPIRIT HOSPITAL X-RAY ONLY X-RAY ONLY X-RAY ONLY TO: LAWRENCE J. NEARY, ESQUIRE KCS on behalf of THOMAS E. BRENNER, ESQUIRE 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 undersigned 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 completing the attached counsel card and returning same to KCS or by contacting our local KCS office. DATE: 04/05/2001 KCS on behalf of THOMAS E. BRENNER, ESQUIRE Attorney for DEFENDANT CC: THOMAS E. BRENNER, ESQUIRE - 22740.1005 Any questions regarding this matter, contact THE KCS GROUP IHC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-149515 56502 - C O:L mr ~ " ,,' ~' COMMOM-VEAL TH OF PENN5YL VANIA - COUNTY OF CUMBERLA.."D JIMMIE J. BONNER, JR. , ET AL VS FileNo. 00-6534 WILLIAM C. MURDORF SUBPOENA TO PRODUCE DOCUMTh,.S OR THI='IGS FOR DISCOVERY PURSU A..I\,. TO RUl.E 4009.22 TO: CUSTODIAN OF RECORDS FOR:TRISTAN ASSOCIATES' (N.me of Penon ot Entiry) \\'ithin rwe~'I2O) days oiler se",'i<e of this subp~na.youue ordered by the C'Ourt to produce the following documents or things: SEE ATTACHED at MCS GROUP INC.. 1601 MARKET ST., 1/800, PHlLA. ,PA 19103 (Addrft.) You may deih-I!T or maUlegible copies of th. documents or produce thinp requested by this subpoena. logelher with the certific.te 0: compli.nc.. to the puty making this r.qu.st .tthe .ddzess listed abov.. You h....th. right to seek. in ad\'anc.. th. ,,"uonable cost of pr.paring th. copies or producing the things _gilt. If you fail to "oducethe docum.nt. or things requir.d by this subpoena. witl-.in tw.nty (20) cays after its s.",'jce. the party se",'ing this subpoena may seek a court ord.r compelling you to comply with i-_ THIS SLllPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: THOMAS F.. RRRNNRR. F.SO~ 320 MARKET ST. PO 1268 HARRISBURG, PA 17108 TELEPHOS:: 215-246'-0900 SUPREME COURT 10 II: ATTOR.'.;E'!'FOR: DEFENDANT SAME: ADDRESS: DATE: ~ J dl, .:J,ry'J/ BY THE C~~T: , w A" /?.. ~ I'rDrnoftotary/O ivil Division 1-;416" ~_.x,h 9f 0cJN'Y ' Seal of the Court (Eff 7(97) -' - ~ .~ ~ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TRISTAN ASSOCIATES 4518 UNION DEPOSIT RD. HARRISBURG, PA 17111 RE: 56502 JIMMIE L. BONNER, JR INCLUDING MRI SCANS, CT SCANS, EMG'S & EEGS Any and all X-Rays pertaining to patient. Dates Requested: up to and including the present. Subject: JIMMIE L. BONNER, JR 545 S. 16TH STREET, HARRISBURG, PA Social Security #: 198-54-0481 Date of Birth: 07-23-1960 SU10-298774 56502-LOl :,~ ~ ~ - - '""'j CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JIMMIE L. BONNER, JR, ET AL TERM, -VS- CASE NO: 00-6534 WILLIAM C. MURDORF As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of THOMAS E. BRENNER, ESQUIRE 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 04/05/2001 THOMAS E. BRENNER, ESQUIRE Attorney for DEFENDANT DE12-212977 56502-L03 C~~_~_O <" O-"['t COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JIMMIE L. BONNER, JR, ET AL TERM, -VS- CASE NO: 00-6534 WILLIAM C. MURDORF NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT 'l'O~R~ 4009.21 TRISTAN ASSOCIATES HARRISBURG HOSPITAL HOLY SPIRIT HOSPITAL X-RAY ONLY X-RAY ONLY X-RAY ONLY TO: LAWRENCE J. NEARY, ESQUIRE MCS on behalf of THOKAS E. BRENNER, ESQUIRE 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 undersigned 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 completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/05/2001 MCS on behalf of THOKAS E. BRENNER, ESQUIRE Attorney for DEFENDANT CC: THOMAS E. BRENNER, ESQUIRE - 22740 .100S Any questions regarding this matter, coatact THE MCS GROUP IlIIC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-149515 56502 - CO]" -. "'~ ~"':: COMMONWEALTH OF PENN'SYL VANIA . COUNTY OF CUMBERLA..'m JIMMIE J.BONNER,JR., ET AL VS FileNo. 00-6534 WILLIAM C. MURDORF SUBPOENA TO PRODUCE DOCUMTh"TS OR THI~GS FOR DISCOVERY PURSUA.1\"T TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR:HARRISBURG HOSPITAL (N..m~ of P,"on or E:u::iry) Within ",..~. (Ul) days aft.. s.rv;.. of this subpOtna. you art ordered by the court to produce the following docum.nts or things: SEE ATTACHED al MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Addtes'l You may dein.... or maill'gible copies of the documents or produce thin9 requested by this subpOtn.. logtlhtr with tho c.rtifiealt of compliance. to the pany making this request at the address listed above. You have the right to s.ok. in ad\'ance. Ih. ",asonabl. cost of proparing the copi.. or producing the things _ght. If you fail to ;roodu.. the documents or things r.quired by this subpoena. wiu-..in twenty (:!O) days aiter its s",'ico. tho party ,o,,'ing liUs ......poena may seek a court oreler compelling you to comply with it. THIS Sl:BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: 'FHO'MAS R. RRF.NNER. ESO. 320 MARKET ST. PO 1268 HARRISBURG, PA 17108 TELEPHO~:: 215-246-0900 StJPREME CO\J1l.T 10 It: A TIOR.'-:n' FOR: DEFENDANT NAME: ADDRESS: DATE: 1oA./ ;;1 02a1/ BY 'THE COUl\T: , /$1 AI4,~' ,tC' ~ ProthonocarylOerJc. iI DiYision , r if}:'4J ~.x,~ W Deputy Seal of the Court (Sff. i /97) ...... <--,k,:_ EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL 111 S. FRONT STREET HARRISBURG, PA 17101 RE: 56502 JIMMIE L. BONNER, JR INCLUDING MRI SCANS, CT SCANS, EMG'S, EEG'S Any and all X-Rays pertaining to patient. Dates Requested: up to and including the present. Subject: JIMMIE L. BONNER, JR 545 S. 16m STREET, HARRISBURG, PA Social Security #: 198-54-0481 Date of Birth: 07-23-1960 SUlO-298776 56502-L03 -"'" ..~. " -~Iii!,:, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JIMMIE L. BONNER, JR, ET AL TERM, -VS- CASE NO: 00-6534 WILLIAM C. MURDORF As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of THOMAS E. BRENNER, ESQUIRE 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 prior to . the date on "hich 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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. HCS on behalf of DATE: 04/05/2001 THOMAS E. BRENNER, ESQUIRE Attorney for DEFENDANT .DEI2-212978 56502-L04 . " " -0 ~i COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JIMMIE L. BONNER, JR, ET AL TERM, -VS- CASE NO: 00-6534 WILLIAM C. MURDORF NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TRISTAN ASSOCIATES HARRISBURG HOSPITAL HOLY SPIRIT HOSPITAL X-RAY OIlLY X-RAY OIlLY X-RAY OIlLY TO: LAWRENCE J. NEARY. ESQUIRE KCS on behalf of THOMAS E. BREIlIlER. ESQUIRE 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 undersigned 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 completing the attached counsel card and returning same to KCS or by contacting our local KCS office. DATg: 04/05/2001 KCS on behalf of THOMAS E. BRENIlER, ESQUlU Attorney for DEFENDAIT CC: THOMAS E. BRENlIER. ESQUIRE - 22740.1005 . Any questions regarding this matter, contact THE KCS GROUP IIIIC. 1601 HARKET STREET #800 PHILADELPHIA. PA 1910) (215) 246-0900 DE02-149515 56502 -CO 1 ~- " . J 'lilli: -, - ~,gJc COMMONWEALTH OF PENNSYLVANIA - COUNTY OF CUMBERLA..'iD JIMMIE J,BONNER,JR., ET AL VS 00-6534 FileNo. WILLIAM C. MURDORF TO: SUBPOENA TO PRODUCE DOCUMB-o!S OR THI~GS FOR DISCOVERY PURSUA..1'I;! TO RULE 4009.22 CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL (N.aml!' of Pl!'non or E:u:iry) Within twe~' (20) days after servi<e of this subP"'!&EY'A't~R~ed by the court to produce the following documents or things: Mes GROUP INC., 1601 MARKET ST., #800, PHlLA"PA l~lUj .t (....d<lreo.) You may deliver or mail legible copies of the documents or produce things requested by this subpoena. together with the certificate of <ompHance,to the party making this request at the address listed above. You have the right to seek. in advance, the ~..onable cost of preparing the copies or producing the things sought. If you fail to ?,oduce the documents or things required by this subpoeM. within twenty (20) c!a~'s after its servi<e, the party serving this subpoena may seek a court order <ompeUing you to comply with i'_ THIS SCBPOENA WAS ISSUED AT THE REQUCST OF THE FOLLOWING PERSON: ~'\ME: THOMAS E, BRENNER, ESQ. . . ~ ,j~u I'18.N.\.r..~ 51. '0 11.68 ADDRESS: HARRISBURG, PA 171UH 215-L4b-UYUU TELEPHOXE: SUPRE.l"fE COURT 10 #: DEFENDANT A TIOR.'-:EY FOR: DATE: ~.JJ ~. c4Q;7/ BY THE C~T: 16( ~JA f~ Pruthonotary/Oerk. vii Division ~A44: K~~~ 91 Seal of the Court (Ef!. i /97) -,.,..... ~ " .... ~" - < "'4fw' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 N. 21ST ST, CAMP HILL, PA 17011 RE: 56502 JIMMIE L. BONNER, JR INCLUDING MRI'S, CT SCANS, EMGS & EEGS Any and all X-Rays pertaining to patient. Dates Requested: up to and including the present, Subject: JIMMIE L, BONNER, JR 545 S, 16TH STREET, HARRISBURG, PA Social Security #: 198-54-0481 Date of Birth: 07-23-1960 5UlO-298778 56502-L04 -,- . -'I~l!1 ;.. U11l~M~~~,",,,"',~~~S"""'" - '''' .il . -"' .-~ .~ -"""'-'"_.~' i4i.fi'j~ o S;~ ..:;-~ -0 Gf"' [T'll ~;t. Cij L~ ~1~ ~ -<. ", c) -~~ -;:~} .-J :c.. _'_0" ~. -..) -}~ ;,-::;-r:l '--; :3 c::> ''r_; -,,", .-- -< N .. JIMMIE L. BONNER, JR. and VEETAL. BONNER, his wife Plaintiffs v. WILLIAM C. MURDORF, Defendant - ,. - ",-,-"~^.~<", ~_. -,,- ,-,--",~.-,' r <-'~-d,",.~_ +, ~>"- -'~M.~<,-.o-,'-"""""o.,,"~i'.'''.i,;-"'\>-c.4-;:-,~, _~. <,;.,.~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-6534 CIVIL CIVIL ACTION-LAW JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE Please mark this action as settled and discontinued. Date: I ';;l/3/ a J- .. . CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon the person(s) indicated below by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania and addressed as follows: Lawrence 1. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101 GOLDBERG, KATZMAN & SIllPMAN, P.C BY: Thomas E. Brenner, Esquire Date: I ')oj (D IV.;L- ._ _~. ~"_.' .1< ci~;~'" .,;".' ~~~:] i .~~".=" ".~~"^'-~ .<. ^...., ~, -"-j '",~~-- " , ". -~. o c: :< ~C:f, rr1rr: ;z:"'" zC ~~;::, ~f~ j..-::(::l. ~ --< --~ ,,~=~ CJ it'..1- ? rq n o 'I1 ._' ~, . '0 ';~'.~ ;:n ~nm -(~::c) ;;~i.~~ '~~ff; ~~ :';:J ~~ .-n ~-v .-.... -:.....) ;....., ('.) ~ 11 j I 1 I I ,I j , 1 1 1 il ~I ,I ! I ., .