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Home My WebLink About00-07083 ->.,~'"-,, '~ ',~"' -',"1-"";' 0,<"" ;h' . STEPHANIE M. HURLEY and BILLY J. HURLEY, her husband, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO.OV .10& CIVIL 2000 GEORGE A. STAMBAUGH, individually and VdIb/a STAMBAUGH FARMS, Defendants PRAECIPE FOR A WRIT OF SUMMONS TO: CURTIS R. LONG, PROTHONOTARY Please enter my appearance on behalf of the Plaintiffs, Stephanie M. Hurley and Billy J. Hurley. Please issue a Writ of Summons upon the Defendants, George A. Stambaugh, individually and tfdlb/a Stambaugh Farms. Please have the Sheriff serve the Defendants at the following address: George A. Stambaugh, individually and tfdlb/a Stambaugh Farms 3419 Ritner Highway Newville, PA 17241 By: ark D. Schwartz, Esquire 60 West Pomfret Street Carlisle, P A 17013 (717) 249-2353 Supreme Court LD. No 70216 Date: October 13, 2000 To: George A. Stambaugh, indvidually and t/dIb/a Stambaugh Farms You are hereby notified that Stephanie M. Hurley and Billy J. Hurley, the Plaintiffs, have commenced an action against you which you are required to defend or a default judgment may be entered against you. Date: Of;;:/:". _ 1.3 ,2000 (luau' !? /? 14.. . PROTitMOTARY By: C)7'" 0 }2/, ee.L~' DEPUTY ~ ~ , ,~ o j!, C.),-~~ ~:':' ~':') i_ ~, ~" " i---. u. o -,.. <.0 C\., 2:: 7 ::s E3J -~ :.::.~ -:-'~ ,::"-1 ',--...:-- '--':::0) '~i~~ ;,,;)11] ~;i~ u.. :5 () (:.j .,':~~ '-'~" D_ ':-V--) ~- C c) C:~ (:;) _" ~ ~. r, , ,~ ". ~ c",.-~ ,", _, ">._, J ~ ~ S 6 lQ ~ ::t' Il! g ~ ::r \~ . -~ --,,- " ~ ~ ., -I"'~=_"="'~" "'0' ." ""'~", _0,- .'~ ..'"'~N"""""" ..~.' "-"~11l "",,,.,WI -"""nllir'''''-l <>... G.. "" ~ >- ') '" ') ~ ~d "" """","""",,,",,,,,,,,,, -';".-,'""",,, ~ - "'''''';_10&.:'-''" .. SHERIFF'S RETURN - REGULAR l - CASE NO: 2000-07083 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HURLEY STEPHANIE M ET AL VS STAMBAUGH GEORGE A ET AL DOUGLAS DONS EN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon STAMBAUGH GEORGE A the DEFENDANT , at 0014:30 HOURS, on the 25th day of October ,2000 at 3419 RITNER HIGHWAY NEWVILLE, PA 17241 by handing to SHIRLEY STAMBAUGH (WIFE) a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.82 .00 10.00 .00 34.82 So AnSW~ -,/A* ~~:;.~-~~~ R. Thomas Kline 10/26/2000 MARK D. SCHWARTZ Sworn and Subscribed to before By: Q~ Gcno- eputy Sheriff me this 31.v-- day of G'e~ ~ A.D. ~ r::: ll1..;p, ) ~ P othonotary I ~ ^ ,,- '" "~~._~,,'- "~~ ~ ~'", ~~. ~. -..JJ _J ... 1II.lIliillli!il.ilillljldlll'llli;;!i_~..-" ,- . . . ~ SHERIFF'S RETURN - REGULAR CASE NO: 2000-07083 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HURLEY STEPHANIE M ET AL VS STAMBAUGH GEORGE A ET AL DOUGLAS DONS EN , Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon STAMBAUGH GEORGE T/D/B/A STAMBAUGH FARMS the DEFENDANT , at 0014:30 HOURS, on the 25th day of October 2000 at 3419 RITNER HIGHWAY NEWVILLE, PA 17241 by handing to SHIRLEY STAMBAUGH (WIFE) a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: ~~~..~~~ R. Thomas Kline 10/26/2000 MARK D. SCHWARTZ Sworn and Subscribed to before By: C;)~./ O~ Deputy Sheriff me this d/.v- day of ()~ dAvtJ A.D. o (-,-_J2. /vtJ ilJ 1j~) P othonotary ~& '. .. STEPHANIE M. HURLEY and BILLY J. HURLEY, her husband, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-7083 CIVIL 2000 GEORGE A. STAMBAUGH, individually and t/d/bla STAMBAUGH FARMS, Defendants NOTICE TO DEFEND 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, order and notice are served, by entering a written appearance personally or by attorney and by 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 TillS 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. Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, Peunsylvania 17013 (717) 240-6200 Americans with Disabilities Act of1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable' accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ,I'; , i 1 ~" , STEPHANIE M. HURLEY and BILLY J. HURLEY, her husband, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-7083 CIVIL 2000 GEORGE A. STAMBAUGH, individually and tJdlb/a STAMBAUGH FARMS, Defendants COMPLAINT AND NOW COME the Plaintiffs, Stephanie M. Hurley and Billy J. Hurley, by and through their attorneys, Irwin, McKnight & Hughes, to make the following Complaint, and in support thereof aver as follows: I. Plaintiffs, Stephanie M. Hurley and Billy J. Hurley, are adult individuals residing at 43 Country View Estates, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant, George A. Stambaugh, individually and t/d/b/a Stambaugh Farms, has his principal place of business located at 3419 Ritner Highway, Newville, Cumberland County, Pennsylvania 17241. COUNT I (STEPHANIE M. HURLEY and BILLY J. HURLEY v. GEORGE A. STAMBAUGH) 3. Paragraphs I through 2 inclusive are incorporated herein as though fully set forth below. - ~l. :1."" ~, , 4. On or about October 29, 1998, at approximately 11:25 a.m., the Plaintiff, Stephanie M. Hurley, was lawfully operating her automobile on Route 533 west toward Shippensburg from Newville. 5. On or about October 29, 1998, at approximately 11:25 a.m., the Defendant, George A. Stambaugh, was traveling on Oakville Road approaching Route ;533. 6. Plaintiff, Stephanie M. Hurley, was lawfully operating her ahtomobile and had the right-of-way on Route 533. 7. Defendant, George A. Stambaugh, did not lawfully obey the posted Stop Sign at the intersection of Route 533 and the road upon which he was travelling, Oakville Road. 8. Plaintiff, Stephanie M. Hurley, was lawfully operating her automobile and was suddenly struck by Defendant, George A. Stambaugh's automobile as he attempted to cross Route 533 in front of Plaintiff. 9. The Plaintiff, Stephanie M. Hurley, was unable to avoid the Defendant's vehicle. 10. The actions on the Defendant, George A. Stambaugh; were negligent, careless and reckless in that he: a. failed to obey a traffic sign; b. failed to operate his automobile in a safe manner; c. failed to yield the right of way to traffic on Route 533; I, ", C",-,' " d. failed to avoid striking Plaintiff's vehicle; e. failed to look for approaching traffic; f. failed to observe Plaintiff's vehicle; g. otherwise failed to exercise due and proper care under the circumstances. II. The impact between the Plaintiff's automobile and the Defendant's automobile on the highway caused the front of the Plaintiffs automobile to be completely demolished. The driver's side of the Plaintiff's automobile was also crushed from the impact of Defendant's automobile. The rear driver's side of the Plaintiff's automobile also suffered damage. 12. As a result of the accident, the Plaintiff, Stephanie M. Hurley, suffered severe injuries to her head, back, left clavicle, nose, knees, right wrist, chest and arms. 13. The negligent, careless and reckless actions of the Defendant, George A. Stambaugh, are the proximate cause of the injuries to the Plaintiff, Stephanie M. Hurley. 14. Defendant, George A. Stambaugh, received a traffic citation for his negligence in this accident. 15. Plaintiff, Stephanie M. Hurley, seeks compensation for the pain and suffering she has endured since the date of the accident. '"b 'c ,_ I", -,; , 16. Plaintiff, Stephanie M. Hurley, seeks compensation for the medical expenses incurred as a result of the accident as well as the continuing medical expenses which will possible accrue in the future as her need for medical care continues. 17. The Plaintiff, Stephanie M. Hurley, seeks compensation for the wage loss which she has incurred as a result of the injuries suffered in the accident as well as continuing wage loss if it should occur in the future. 18. The Plaintiff, Stephanie M. Hurley, seeks compensation for the permanent injuries she suffered to her right wrist as a result of the accident which have made it more difficult for her to perform the daily activities and duties which she was able to perform prior to the accident. 19. The Plaintiff, Stephanie M. Hurley, seeks compensation for the injuries she suffered to her knees as a result of the accident which have rendered her great pain when walking up and down stairs and when engaging in physical activity. 20. The Plaintiff, Stephanie M. Hurley, seeks compensation for future medical care, wage loss and the continued pain and suffering due to her injuries which resulted from the accident. 21. The Plaintiff, Billy J. Hurley, seeks compensation for the loss of companionship and society as a consequence of the injuries to his wife, Stephanie M. I;Iurley, caused by the accident. ";"+" ,I - I" ~-, " WHEREFORE, the Plaintiffs, Stephanie M. Hurley and Billy 1. Hurley, demand judgment against Defendant, George A. Stambaugh, in an amount in excess of twenty-five thousand dollars ($25,000.00) Dollars, plus costs, interest, and all other relief this Honorable Court deems fair and just. COUNT II (STEPHANIE M. HURLEY and BILLY J. HURLEY v. STAMBAUGH FARMS) 22. Paragraphs I through 21 inclusive are incorporated herein by reference thereto as though more fully set forth below. 23. At the, time of the accident, Defendant, George A. Stambaugh, was employed by and/or an owner/agent of Defendant, Stambaugh Farms and was acting in his capacity as its owner/agent in furtherance of the business of said Stambaugh Farms. 24. The Defendant, Stambaugh Farms, is responsible for the negligent acts of the Defendant, George A. Stambaugh, at the time of the accident since Defendant, George A. Stambaugh, was engaged as an agent/workman and/or employee in conducting business on behalf of the Defendant, Stambaugh Farms. 25. The negligent, careless and reckless actions of the Defendant, Stambaugh Farms, are the proximate cause of the injuries to Plaintiff, Stephanie M. Hurley. . ~, ~-~,,! " '. 26. The Plaintiffs, Stephanie M. Hurley and Billy J. Hurley suffered injuries and damages as a result of the accident as pled above and seek compensation for the same. WHEREFORE, the Plaintiffs, Stephanie M. Hurley and Billy J. Hurley, demand judgment against Defendant, Stambaugh Farms, in an amount in excess of twenty-five thousand dollars ($25,000.00) Dollars, plus costs, interest, and all other relief this Honorable Court deems fair and just. Respectfully submitted, IRWIN, 1(cKNIGHT & HUGHES By ;/~~M7 Mark D. Schwartz, Esquire Supreme Court J.D. #70216 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Attorney for the Plaintiffs, Stephanie M. Hurley and Billy J. Hurley Date: March 2. \ ,2001 ,~ .~__.T~Y'I'_~ ,,_ u__~ -" "~"~ "'-'-'. " '. VERIFICATION The foregoing Complaint is based upon information which has been gathered by counsel and us in the preparation of this action. We have read the statements made in this document and they are true and correct to the best of our knowledge, information and belief. We understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. %~ I.?.A ~ ~ BILL YJ.'HURLE Date: MARCH 21 .2001 STEPHANIE M. HURLEY and BILLY J. HURLEY, her husband, Plaintiffs v. GEORGE A. STAMBAUGH, individually and tJd/b/a STAMBAUGH FARMS, Defendants > " "'" "z I ~i .' J\; 'i ".. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-7083 CIVIL 2000 CERTIFICATE OF SERVICE I, Mark D. Schwartz, III, Esquire, hereby certify that a copy of attached Complaint was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: George A. Stambaugh 3419 Ritner Highway Newville, PA 17241 Stambaugh Farms George A. Stambaugh 3419 Ritner Highway Newville, PA 17241 HUGHES By: Mark D. Schwartz, Esquire 60 West Pomfret Street Carlisle, P A 17013 (717) 249-2353 Supreme Court I.D. No. 70216 Attorney for the Plaintiffs, Stephanie M. Hurley and Billy J. Hurley Date: March 21,2001 ~~~J:I1-" 'lllillllilit;ji '"'""';"""'-"~~~OO~;:1~.'illi;Y- _iIli'~-" '.....lIiq;.lll'~Ji..o ." L _:}.~, ,,",~, ,,," ~'P ~~= , "'="'~ ~~ ~ ~,,,,,,'1",C'''''.'c ,_~ 'B~ "~-'~'c ~",_-'\'. '~""~ ,"'",,,",- " , .-'0 "'~ ''-'''''-_ .',~~, ", """'-' > - r "",,-,.-, "I""", "', ". .'~~ ",~, ~~ .- ~ln () C) ,--, C ""-..' y6S -n :,:,:J'" 111fT, :~ i;) ~~c' f'v ,~ ~C" ',~) ~ " ---::-i 0 ::lC pO :'J is \~ c :z """ 'r:! :< r'1'} 01-- =< n ~ .. .. STEPHANIE M. HURLEY and BILLY J. HURLEY, her husband PLAINTIFFS, v. GEORGE A. STAMBAUGH, Individually and tldlh/a STAMBAUGH FARMS, DEFENDANT TO THE PROTHONOTARY: ~~~' ','"",, '''.','' , >;'-,~"I, , ~~~',~~~ ',';-'''',,' ' " IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 00-7083-CIVIL 2000 JURY TRIAL DEMANDED PRAECIPE Please enter the undersigned's appearance on behalf of the Defendant, George A. Stambaugh, Individually and t/d/b/a Stambaugh Farms, regarding the above-captioned matter. Date: ~--tl1)t Respectfully submitted, NEALON & GOVER, P.C. ~-~& L . '~i' J= ,G. NiiiiO~ II , E'q= ' LD. #: 46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 By: ,--~' _ - '., '--' , ,,~', """,,'''''' o~"" I . " , ," ~ ' , ~,,, ";:'-~', . CERTIFICATE OF SERVICE AND NOW, this II th day of April, 2001, I hereby certify that I have served the foregoing Praecipe on the following via first class mail, addressed to: Mark D. Schwartz, Esquire IRWIN, McKNIGHT & HUGHES 60 West Pomftet Street Carlisle, P A 17103 ~~~ James G. Nealon, III, Esquire < , .. STEPHANIE M. HURLEY and BILLY J. HURLEY, her husband Plaintiffs, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.: 00-7083-CIVIL 2000 GEORGE A. STAMBAUGH, Individually and t/d/b/a STAMBAUGH FARMS, Defendant. JURY TRIAL DEMANDED ANSWER OF DEFENDANT, GEORGE A. STAMBAUGH, INDIVIDUALLY AND t/d/b/a STAMBAUGH FARMS 1, Admitted. 2. Admitted. COUNT 1 Stephanie M. Hurley and Billy J. Hurley v. George A. Stambaugh 3, Paragraphs 1-2 above are incorporated herein by reference, 4,-13. It is admitted that on October 29, 1998, at approximately 11:25a.m" Defendant, George A. Stambaugh, was operating his 1992 Chevrolet Silverado pickup truck on Oakville Road, approaching Route 533, North Newton Township, Cumberland County, Pennsylvania; it is further admitted that at that time and place, Plaintiff, Stephanie M. Hurley, was operating an automobile on Route 533 in a westbound direction approaching its intersection with Oakville Road; it is further admitted that collision occurred between the Stambaugh and Hurley vehicles; the remaining averments contained in Paragraphs 4 through 9 of the Complaint are denied pursuant to Pa,R.C,P.1029(e). ",__,' -- ""><.,c,,,,= --. '"' ,""~v~, -- ~=',^'.."" ,,~, '," -- ,'""'",< "",,' '~'I"i"'^''-''~'___(''"'' ""'"'-',"",H'~' _-', ._ '"I I 14, It is admitted Defendant, George A. Stambaugh, received a traffic citation. It is denied that the citation is relevant or admissible, 15,-21, Denied pursuant to PaR.C.P, 1029(e), COUNT 2 Stephanie M. Hurley and Billy J. Hurley v. Stambaugh Farms 22, Paragraphs 1 through 21 above are incorporated herein by reference. 23. Admitted. 24,-26, Denied pursuant to Pa.R.C,P, 1029(e). Respectfully submitted, NEALON & By: q~ Date: S' (& 10 r James G, Nealon, III, Esquire I.D. #: 46457 2411 North Front Street Harrisburg, PA 17110 717/232-9900 ,'~'" , "~,--,, '- r."'~' ". , ,~".-- . ~~.'. ., ,~~,.' ' '''''I ,',~,' "0" ~ "<,,,..t~-"" -",=,>, ,'"~, .,'.'_' ~ '" """",,, VERIFICATION I, GEORGE A. STAMBAUGH, verify that the statements made in the foregoing ANSWER are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S.A. 4904 relating to unsworn falsification to authorities. Dated: ~ J-SIJo( ~f}'~~/ GEORGEA.STAMBAUGH - ~ . .. ~-- ~'.' "..-- ~"".,1 i I ; CERTIFICATE OF SERVICE AND NOW, Ihl, And- d'yof Yfla;( , 2001, I h"eby certify 'h,' I have served the foregoing Praecipe on the following via first class mail, addressed to: Mark D, Schwartz, Esquire IRWIN, McKNIGHT & HUGHES 60 West Pomfret Street Carlisle, PA 17103 ','l,"J'_ '^' '-~:~"<-S>-, >';f"r~ r-,:<,';,,', '" '0(1,>,,00'0"""0' '1"";-';1';<',,\'P'-",,"'> STEPHANIE M. HURLEY and BILLY J. HURLEY, her hnsband Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.: 00-7083-CIVIL 2000 GEORGE A. STAMBAUGH, Individnally and tldlb/a STAMBAUGH FARMS, Defendant JURY TRIAL DEMANDED CERTIFICATE PREREOmSITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a Subpoena for documents and things pursuant to Rule 4009.22, Defendant, George A. Stambaugh, Individually and Vd/b/a Stambaugh Farms, certifies that: I. A Notice of Intent to Serve the Subpoena with a copy of the Subpoena attached thereto was mailed or delivered to each party, 2. A copy of the Notice of Intent, including the proposed Subpoena, is attached to this Certificate. 3. No objection to the Subpoena has been received. 4. The Subpoena which will be served is identical to the Subpoena which is attached to the Notice ofIntent to Serve the Subpoena. Respectfully submitted, NEALON & GOVER, P.C. By: Date: 08/28/0 I James G. ealon, III, Esquire I.D. #: 46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 .. """"-"':~V ,--"",,^,,<;;'~'::'" '-, - STEPHANIE M. HURLEY and BILLY J. HURLEY, her husband Plaintiffs v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 00-7083-CML 2000 GEORGE A. STAMBAUGH, Individually and t1dlb/a STAMBAUGH FARMS, Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant, George A. Stambaugh, Individually and t/d/b/a Stambaugh Farms, intends to serve Subpoenas identical to the ones that are 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 Subpoenas. Ifno objections are made the Subpoenas may be served. Respectfully submitted, NEALON & GOVER, P.c. By: James G. Nealon, Ill, Esquire I.D. #: 46457 2411 North Front Street Harrisburg,PA 17110 (717) 232-9900 Date: 08/06/0 I "I "'L- -'"" .....~ , , - STEPHANIE M. HURLEY and BILLY J. HURLEY, her husband Plaintiffs v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 00-7083-CIVIL 2000 GEORGE A. STAMBAUGH, Individually and t/dlb/a STAMBAUGH FARMS, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: William J. Phelan, M.D. 2 Tyler Court Carlisle,P A 17013 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110: Any and all medical records, office notes, correspondence, memorandum, insurance forms, progress notes, reports or other documents relating to any examination, consultation, care or treatment of Stephanie Hurley, Date of Birth 07/01/77, and Social Security Number 176-70-5214. You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the Certificate of Comp'l~ance, 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: James G. Nealon, ill, Esquire NEAL9N&GOVER, P.C. o 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant Seal of the Court PROTHONOTARY ~2. 1=J)P6 DATED: (.J.w:r.lsJ- PI ;)66/ I~ ~~ 'P'1flj~; STEPHANIE M. HURLEY and BILLY J. HURLEY, her husband Plaintiffs v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO.: 00-7083-CIVIL 2000 GEORGE A. STAMBAUGH, Individually and t/dIb/a STAMBAUGH FARMS, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Graham Medical Clinic 100 South High Street Newville, PA 17241 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following docinnents or things; at the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110: Any and all medical records, office notes, correspondence, memorandum, insurance forms, progress notes, reports or other documents relating to any examination, consultation, care or treatment of Stephanie Hurley, Date of Birth 07/01/77, and Social Security Number 176-70-5214. You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the Certificate of Conipliance, 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 co~pelling you to comply with it. This Subpoena was issued at the request of the following person: James G. Nealon, ill, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant DATED: {Ju. crUS:+- JY, c:2DdJ Seal of the Court PROTHONOTARY , ~O/1-P P7iJ~ ~~ CERTIFICATE OF SERVICE AND NOW, this 28th day of August, 2001, I hereby certify that I have served the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Mark D. Scwartz, Esquire IRWIN, McKNIGHT & HUGHES 60 West Pomfret Street Carlisle, PA 17103 , , \j r 1.1 " I Ii I I, 11 i: p i " I' i' I' , ~\\\'sue:- J es G. N eaJon, III, Esquire ", ;: ~N" ,',._.",~ "h','"" ,',',." .=,,",,,",,",,, ,"~'o ii""';; ,,; "ii'. .. ,i " ~''''.' '. <;]~~' '::}~;~--'~'" >".-<< ,i-_~,:; ,_ ' ,',' .. . . r'_'~, <, _"'" ~--, ',',r, ~- , J i,i,'i,;""'" i" ,:"ic'.:,;;.:;";,,,,;"':::;,:, ~: '~-:"b~::')~4:"'~ f<-"- I .1 11.1 ,;"'",, "i+ "';" 0 '.,",,1 l-:i So; , U) "0 [" "-'1 'T! -'0 :2::: ;'? I (/) L, -< ~ -, C ~=, ) ,.. " ~~ :_,) 5J -< (11 -< '"' H'--"' ''''',-'''"0'.''''''' "'> " ,,,, ",^" "'-- ~'--" . '> --~"" ,'-, -I' '" "'-,,,,;,;,'""" ',='- ,""~,~~,.,~',, '",' , '-'~-- ' -'liDli I' ;1 I" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA tl I:' il I: 1:1 Ii STEPHANIE M. HURLEY and BILLY J. HURLEY, her husband, Plaintiffs v. GEORGE A. STAMBAUGH, individually and t/dlh/a STAMBAUGH FARMS, Defendants NO. 00-7083 CIVIL 2000 ,: .'; I: " n !~ PRAECIPE TO SETTLE AND DISCONTINUE To Curtis R. Long, Prothonotary: Please mark the above-captioned case settled and discontinued and issue a Settlement 1;\ !i Certificate to Marcus A. McKnight, III, Esquire, at 60 West Pomfret Street, Carlisle, Pennsylvania 17013, Date: January 24, 2003 Respectfully submitted, , III, Esquire 60 est Pom t Street Carlisle, Pennsylvania 17013 (717) 249-2353 . _0 n, ._~ .;, ,_"__ ~ . "'-" -"-,"' I'..,:.;", ' - ~';:"~-'-'" + ,", , STEPHANIE M. HURLEY and BILLY J. HURLEY, her husband, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-7083 CIVIL 2000 GEORGE A. STAMBAUGH, individually and t/dIb/a STAMBAUGH FARMS, Defendants CERTIFICATE OF SERVICE I, Marcus A. McKnight, ill, Esquire, hereby certify that a copy of attached Praecipe to Settle and Discontinue was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Michael Smoluk, Claims Adjuster Allstate Insurance Company Market Claim Office 6345 Flank Drive, Ste. 1000 Harrisburg, PA 17112-2765 IRWIN, McI)NlGHT, "1 ."; ,',' ~/< ", 1'7}'/' 1" j II /0 / ,; i '// By: Marcus. cKnight, III, Esquire 60 West, omfret Street Carlisle, PA 17013 (717) 249-2353 Supreme Court LD. No. 25476 Date: January 24, 2003 - ~ ,~- oih=-t..,,,,,S.,,. -,,"~ -',~"'; -<C~'-f>' +~,,,,,,~L:n,J: ~. ~~lm.M,_.~,:.!!.~L~t ,~ ,,,,"-"'>"-"';'- )"""", -$. ""--"-- ",,,"-f- .1__.__.," ,,'..' .", ,'..,' ~ 8 -oS:: ,..,..,rIJ ~r--' S~ft! 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