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Home My WebLink About00-07994 ill 1/ " .. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VERNON LEE MOORE, JR. :NO 2000 - '799'1 Plaintiff : CIVIL ACTION - LAW v. LEE A. PRIAR, JULIE L. HAWKINS, ALLSTATE INDEMNITY COMPANY Defendant WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. {$/ C~ -R 1; Prothonotary a:;J JJov I~ 8a:.t\ Date -I8~'!f ~ Deputy it"!~, _, ,'" ,,, I . . ~ ~~~Lo'''' rr . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VERNON LEE MOORE, JR. Plaintiff :NO 2000 : CIVIL ACTION - LAW v. LEE A. PRIAR, JULIE L. HAWKINS, ALLSTATE INDEMNITY COMPANY Defendant PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Write of Summons on the above named Defendant at the following address: Lee A. Priar 18 E. Maplewood Avenue Mechanicsburg, PA 17055 Julie L. Hawkins 128 Center Street Duncannon, PA 17020 Allstate Indemnity Company 701 Lee Road Wayne, PA 19087 Respectfully Submitted TURO LAW OFFICES Dat!l~k; David A. Greene, Supreme Court ID 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff I - --- ..:l J ~, . ~ . -~ . _ ,_", .g!Wl~rT! Jr-" , IH _._o.-'"~~~ 'd ,'" '" ''''M ilirlr~mTI ~ ]illr I n.l'''rn\' ~ 0 a c C) ~ :::e ,{:,- ki3 -Oc.U 0 1% 0' mfT <;[f;': \I' "'7-.." ~ ' I ZC g ~ (j) ~, Go l^ -<2 0 ~o """ - <:I)""""" ~o C'> ~ ~ _.i.... ~ <;;>... --c ~ '--; >c ~ :::t:, :p z ~ ~~ j =< <.11 ~ .<cl a :I> ~) " -h--. c! -.0, >,j \~,~ '.~~?~3 ;'::::::'Tl ,...-' jj ::,< ff~ ~ - . ~~ ~_~e -....:.::s.~~.3 ~ .~ t l!Il!!lIIJilfI;Jl_lll. _~,_"..~~: .""4J~~~,>\f>lli!;~~.t.;,,,,~~..-m~~~!I[~~jr,"l!i'i~J!~~""i""""_-""""" ,>$!~ If ~ ~ ,I 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VERNON LEE MOORE, JR. Plaintiff :NO 2000-7994 : CIVIL ACTION - LAW v. LEE A. PRIAR, JULIE L. HAWKINS, ALLSTATE INDEMNITY COMPANY Defendant PRAECIPE TO RE-ISSUE WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Pursuant to Rule 401 of the Pa. R.C.P. , please re-issue the attached Write of Summons in the above captioned matter. Respectfully Submitted TURO LAW OFFICES 12~zj()? Date I David A. Greene, Es uire Supreme Court ID No. 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff 1",J[llnL 0 ~,'" ~'" .^,' .,- _ 'I . '" '" , " ~-- <-, -" - ~~ ~ . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VERNON LEE MOORE, JR. :NO 2000 - 7119'/ Plaintiff : CIVIL ACTION - LAW v. (') C) C CCl -r; ~~~ ~ n~Jr: -'.::) 7"1' Zi~ S::']'c" ~:T \.- -- :c.: -, -<..' (' ) --1--; (.1. ' LEE A. PRIAR, JULIE L. HAWKINS, ALLSTATE INDEMNITY COMPANY Defendant , ., -, " (f1 --j :..-u ~, WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANTS: YOU ARE NOTIFIED THAT THE ABOVE NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. /JJ(l.,jMb;; ~'~ Prothonotary u !1Jov /3. ~ Date .J?~~~!!!j. ~ Deputy I' \ TRue COPY FROM;RECORO fA TlIStilllORy WIllnOf, I '*' U(ItO'$lIt my hanc and the _ of said. .. Cat1lsll. '4. this IJ l. day C .' JJMJ ::>"1., , "_~'--~_ ." _ .-, - - " , Ulllt Ji'li!R,U ~"~ \'> ''''-',: ',,-,? __"r\-I"'- '<'.'-". "-.' , "," '""""' """, "..w."""",".".""t"'"&"""d""",,"" "1'\'("'" ,~""", ""'''-<:1111 [iJjIIIllFIl"""'" "" "'111'1' . '. .~.; ~~~~ t ~ ~~C -4- ?; ( ~ .s, <:> "" <) ~ ~ " '+-=0 t ~r Jt iI!!~~~~m_wr>ll~'~!'<ffl~~~_,_'~,e_,.~,w,<":~"n$~'p~',~",~,:;~",-,,,'!""""'''I'''I'--''''''t'*'''tO:'~'lW~~\~~,j"''''''H,n''''','[C"l'~l'li1'~'\1iliIIIfflii~Iro~'~ .I . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VERNON LEE MOORE, JR. Plaintiff :NO 2000 : CIVIL ACTION - LAW v. LEE A. PRIM, JULIE L. HAWKINS, ALLSTATE INDEMNITY COMPANY Defendant PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Write of Summons on the above named Defendant at the foUowing address: Lee A. Priar 18 E. Maplewood Avenue Mechanicsburg, PA 17055 Julie L. HawkinS 128 Center Street Duncannon, PA 17020 Allstate Indemnity Company 701 Lee Road Wayne, PA 19087 Respectfully Submitted TURO LAW OFFICES Dat:lo/f19 David A. Greene, sq re Supreme Court ID 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff ,-"""W~ '^""~" ~- " " "" ."" - '-"""" ~,""-"'~ -~~""",k' ,>'-,,-ll-',) '" _"", ,'0',', _'-L .. ,",,,_,,,-~,._,,,,< C;,'''''",,,,,-,-'''',.'^'' ''''''c''''~'' r-T . 0 0 ('j C- O -':-~ ~. :::::J i ~ ""Ore P1 : ~:-; ~:o n1rn n >',- z__" ~~,~;; ~.5 zt;:.: N ~Z i~;:;-:::) r-c: -0 -",., -~--. '< ~~ ~G 3 -~C) r. ,_~;)fn )>c: ~l Z ":;:) S5 ~ en -< ~ ,41 'Il'l'l~~~~~~f~~J,1I;:;~--;"";1l;i<,.".~~i'1i&'if!!~~'<"!Ii=<It',"-1i!!'1~~i>lt\~N"",,1'i)\\""~"~~_..,, -Jf~'2"'{":"'!""w"':-'-P!-,oY"'~""ii'\'f"'l11hj;;wrn;~lJ'~",;:<.'i""~~g,,---;_"'"_!I';"_""!~'''Hlw!r~--'.l!>~'''''Ii1f'('''~ l/.e~fltJJII ( iPe NtJrYlP/ JR. In the Court of Common Pleas of Cumberland County, Pennsylvania VS. ~~~.~N ,Jvoe I. l/h>>ljJi~ l?P1!'E0 PE 10 No. '1 tf/ 'I Civil. ~ }00(6 (:;hi- /J(!7101i - c...&v q-/<;,{ff tIL/r 6 5(jJl1hlt'WS 10 7lff fefflbrorl/Jey oF 51ttl) ('tWe.! PUfy/lftJf- k tole. 4~ of-) tie {{P. f e ~ I~ _ r;;:;:; '/I.:/:I: tvd.f' 5fP1#JM.5 IA ;f", ~ To Prothonotary ,,4_, , ,. , -- ~' ~, , m ,:1._ t: : "J :-:,,; 2:1.7 CUt\,':~,b'-\\ ,- ,,-;:~, COU[',ny FENNSYLH~,,!\jrl\ ".'1 ,", ..-~ ~. "~, .~81~:t'l).!lI"itIRP7~~ftmlIR'iIll_ ." -"~" ..'~~' '~.." ",.", ON"- -.'~- - '<<k-",,_",""'-'~>'_'<h' .',/",'"~-<- ,,,-," "","", "", - "'1~"~~"<~1'"'' ""'rj'''r'''''T:'I1~'lf~ No. Term, 19 _ VS. PRAECIPE Filed 19 , Atty. 1f!ilI~1 "~" ~'if>l!IfllIh__~~~~~li~~JIl.'i'1~._,," \f_~~~I'MJ'![:!, .,,"'. "~.,..",~!: SHERIFF'S RETURN - REGULAR CASE NO: 2000-07994 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MOORE VERNON LEE JR VS PRIAR LEE A RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon PRIAR LEE A the DEFENDANT , at 0019:45 HOURS, on the 31st day of January ,2001 at 18 EAST MAPLE WOOD AVENUE MECHANICBURG, PA 17055 by handing to LEE PRIAR a true and attested copy of WRIT OF SUMMONS 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: f!"'.a~1~?Ji~<:~~ R. Thomas Kline 02/01/2001 TURO LAW OFFICES Sworn and Subscribed to before me this 6- ~ day of J~ -;;; A.D. 1 YM~"~, -' # r thonotary By: D '''" ~-", - M m:lhomelbqallitigatlstatefrmlpriarlentryappearance.wpd Draft #1 February 22, 2001 . Jeffrey E. Piccola, Esquire Supreme Court LD. #18018 Brigid Q. Alford, Esquire Supreme Court I.D. #38590 BOSWEll, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 74] Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant, Lee A. Priar I v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-7994 VERNON MOORE, JR., Plaintiff LEE A. PRIAR, JULIE L. HAWKINS, ALLSTATE INDEMNITY COMPANY, Defendants : CIVIL ACTON - LAW PRAECIPE FOR ENTRY OF APPEARANCE Kindly enter the appearances ofBrigid Q. Alford, Esquire, Jeffrey E. Piccola, Esquire, and Boswell, Tintner, Piccola & Wickersham on behalf of Defendant Lee A. Priar. Respectfully submitted, By: Date: ;2../.91010} ! I Brigid lfor ,Esq Supreme Court I.D. # 590 Jeffrey E. Piccola, Esquire Supreme Court I.D. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Lee A. Priar ~'" - ..." , '-: - ""9;lh:,7..- _ .,_,:",,,,,,. ',-'C_"_ ;-' ,"'1';----'" ,". . :;,".""!." '"'~_\q"_-;A-~^~'{',_',' """~~ "'. "'_ '.~. ' ~-. ,," " .,_ ,""-'. '. '>_ """" "_~,~ -"~, _ ._. .~~ "'''',,,_ '..~~",,'~ "_~, ,~,~ ~ _~ , ,. .It' CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Praecipe for Entry of Appearance by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: David A. Greene, Esquire Turo Law Offices 28 S. Pitt Street Carlisle,PA 17013 Attorneys for Plaintiff Julie L. Hawkins 128 Center Street Duncannon, P A 17020 Allstate Indenmity Company 701 Lee Road Wayne, PA 19087 By: ~~-~ B igid . Alford, Esqu' Date: -4.21. (D( ,,_^," '_C"',_ n~~o''''_,,','',''_~'t,___ ~,"Ci'F';~,.~t,,-,-, '~'-~- ~~~ -, _,e _'''~___', - _"'1__.-,. ..-- ,. < . o. ~ ! I , I. Ii I Ii Ii , I ! il Ii II 11 !i J1 h ~; ).1 I;:i , " Ii l~ J: l~ Ii [I II I:, 'I'; , L ~~~!""'!"!'" , ~ ""7"~~" ~ ,- ,-. .1" .",...."" ""'. .<<. .,", ,-\-,,",,' ~1)'WiP'!!t!l1!ll'-I"I~~IIl@!"1'f .,,"~ """ ", ... o ~ ,jlt' QJC_' ~~._. ,--" ~. , -~ '--.' ~, ~~~ ::~ -"; -< ri\!li1l~'~,'lI::,.,., ,~~ '" ~ A , C) C) "'1 -,., ,-q . ~-=~ '~;..J I',) c;-,) '~~"", ,..,,~~ v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 2000-7994 VERNON LEE MOORE, JR. Plaintiff, LEE A. PRIAR, JULIE L. HAWKINS, ALLSTATE INDEMNITY COMPANY, Defendants. CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant Allstate Insurance Company with regard to the above-captioned matter. Respectfully submitted, By: ( Date: 4 -I ~-{)j James G. Nealon, III, Esquire 1.0.#:46457 2411 North Front Street Harrisburg, PA 17110 717/232-9900 f'''-}-'''o-o__ ,,_ ,".,~_m','_""",_~ ._",=__ _."~' "~,~_ c"..,"''''"','''''''''.", "'.,.,..~. =? " , . ~- " CERTIFICATE OF SERVICE AND NOW, this /0VJ--day of April, 2001, I hereby certify that I have served the foregoing PRAECIPE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: David A. Greene, Esquire TURO LAW OFFICES 28 South Pitt Street Carlisle, PA 17013 Brigid Q. Alford, Esquire BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street P.O. Box 741 Harrisburg, PA 17108-0741 Julie L. Hawkins 128 Center Street Duncannon, PA 17020 q- t' James G. Nealon, III, Esquire 0-"" ',_ ~.1~-_ v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 2000-7994 VERNON LEE MOORE, JR, Plaintiff, LEE A. PRIAR, JULIE L. HAWKINS, ALLSTATE INDEMNITY COMPANY, Defendants. CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, By: Q- NEALON & GO Date: 4 -/0-0/ James G. Nealon, III, Esquire 1.0. #: 46457 2411 North Front Street Harrisburg, PA 17110 717/232-9900 RULE TO THE PLAINTIFF: A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. DATED: {J.1;)fL~ \. Ii', .;1..co' ~. Prothonotary ,- ,~ - ,~ ._~,,~ . -~- CERTIFICATE OF SERVICE AND NOW, this I ro ~ay of April, 2001, I hereby certify that I have served the foregoing PRAECIPE AND RULE TO FILE COMPLAINT on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: David A. Greene, Esquire TURO LAW OFFICES 28 South Pitt Street Carlisle, PA 17013 Brigid Q. Alford, Esquire BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street P.O. Box 741 Harrisburg, PA 17108-0741 Julie L. Hawkins 128 Center Street Duncannon,PA 17020 q~ James G. Nealon, III, Esquire I.,.".. "'~ '.' ~'--~""""-<~'_"""'_'t_."~"",,,.~ _ _ ." -",. h ''''',':'<,e_",. ,""~'1"C' ',_ c_"_~,, _,~,,_"' ~ _"" ,',H:,,_ ,~. _ '__,__ ., -., ~ ,." ~"', --- ,.-" . . ~ VERNON LEE MOORE, JR. Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. NO.: 2000-7994 LEE A. PRIAR, JULIE L. HAWKINS, ALLSTATE INDEMNITY COMPANY, Defendants. CIVIL ACTION - LAW NOTICE OF PRAECIPE TO ENTER JUDGMENT OF NON PROS TO: Vernon L. Moore, Jr., and his attorney, David A. Greene, Esquire TURO LAW OFFICES 28 South Pitt Street Carlisle, PA 17013 Date of Notice: June f? ,2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO FILE A COMPLAINT IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR RIGHT TO SUE THE DEFENDANT AND THEREBY LOSE PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Respectfully submitted, By: NEALON & GO Date: ~(-.:(o r James G. Nealon, III, Esquire 1.0. #: 46457 2411 North Front Street Harrisburg,PA 17110 717/232-9900 \'-'-'-'f',: > - _"'''''''' "'"'A,-'.""~"','.'''"_''''__-'_r;',.'_",,_,_,._'gi:''',,,,".,,,...._,"",,"_,'O"'W~'='" ^_,_ ~~""~'~ ._,,~ , CERTIFICATE OF SERVICE AND NOW, this r day of June, 2001, I hereby certify that I have served the foregoing NOTICE OF PRAECIPE TO ENTER JUDGMENT OF NON PROS on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: David A. Greene, Esquire TURO LAW OFFICES 28 South Pitt Street Carlisle, PA 17013 Brigid Q. Alford, Esquire BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street P.O. Box 741 Harrisburg, PA 17108-0741 Julie L. Hawkins 128 Center Street Duncannon,PA 17020 ~- James G. Nealon, III, Esquire '-. '" -- ~:"'-~'p-_-_ "___~':__-"_<_ -.:__+ __'''',~^,-",,~~ ,_t' ,_,;,;/",.""",,,,,",' '''___''''r,'''' . ., _~_ ___'."". -..'..0..,.__- v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.: 2000-7994 VERNON LEE MOORE, JR. Plaintiff, LEE A. PRIAR, JULIE L. HAWKINS, ALLSTATE INDEMNITY COMPANY, Defendants. CIVIL ACTION - LAW AGREEMENT PURSUANT TO RULE 237.2 TO EXTEND TIME TO PLEAD FOLLOWING 10-DAY NOTICE It is agreed that Plaintiff is granted an extension of time through August 8, 2001 to file a Complaint. After the above date, a judgment of non pros by default, as may be appropriate, may be entered upon Praecipe without further notice. D,eli yft>/ Iv (J){ dJ'I / (J I Date I James G. Nealon, III, Esquire, Attorney for Allstate Insurance Company > "'-^''''' ,,~,w,',.".", -",--~_,_, "'''T"'_-_",r_~' ~, " - 'e. -"",~, '1 _ ".,_-~,___~ '.-~ _". ___~ _, ", .'^' " _ , -~-~ ,~_. __,0, .__~., . "n'_ "<'__" "" ' CERTIFICATE OF SERVICE AND NOW, this 21st day of June, 2001, I hereby certify that I have served the foregoing AGREEMENT PURSUANT TO RULE 237.2 TO EXTEND TIME TO PLEAD FOllOWING 10-DAY NOTICE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Ron Turo, Esquire TURO lAW OFFICES 28 South Pitt Street Carlisle, PA 17013 Brigid Q. Alford, Esquire BOSWEll, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street P.O. Box 741 Harrisburg, PA 17108-0741 '="l L~~ James G. Nealon, III, Esquire ~';:"~ ';' ->,-",~,_:,jl,_~,"___:,,_':'[,_*,'~'~~__''''':~l""~_"'~' ':~ ",_~_~<_o '''')-,'-' -;>:~,,_-,:_-~_,-,:-""'~_"'C' ~ . '-~" -.'-' - ~~-~",..- _...',- - " -, . ~~" ~ Jeffrey E. Piccola, Esquire Supreme CourtI.D. #18018 Brigid Q. Alford, Esquire Supreme Court 1.0. #38590 BOSWElL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant, LeeA.Priar v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 2000-7994 VERNON MOORE, JR., Plaintiff LEE A. PRIAR, JULIE L. HAWKINS, ALLSTATE INDEMNITY COMPANY, Defendants : CIVIL ACTON - LAW PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Enter a rule upon the Plaintiff to file a Complaint within twenty (20) days after service of the Rule, or Judgment of Non Pros will be entered. Date: August 13, 2001 BJ' B~-h.~- :-,'1, '0. '_'_""__,"':~ ,,"'1y.r -.--,~,,,,>,,"'- _ -~",:"""'f',~_~,'_"'" no' ,'- ., ',""-." ',-",- ~ <1"" _' ...", " . ,r" . ,.'f' '~.__,"_ _, ~ . .,.' '_~,'_ -~,.,."". ,'_'F,"'~~ ~,--- , , !: I: I' 1 i k. ""''',.,,,,, VERNON MOORE, JR., Plaintiff v. LEE A. PRIAR, JULIE L. HAWKINS, ALLSTATE INDEMNITY COMPANY, Defendants TO THE PLAINTIFF: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . : NO. 2000-7994 : CIVIL ACTON -LAW RULE You are ruled to file a Complaint within twenty (20) days after service hereof. Dated: !J"f ;)0, .206/ 7',_,"-_":";~~'<<_o:-"'~T:.'?""__-' < ''C -> ,'c',"," ~- Ol...-Iui ) J) ~ PROTHONOTAR-Y .- "~,__"1" '" ,. '" :~ , ,-" - -~.,.~~- '-' ",-". "".-.,. <- CERTIFICATE OF SERVICE I do hereby certify that I have served on this date a true and correct copy of the foregoing Rule to File Complaint on the following by first-class mail, postage prepaid and addressed as follows: Ron Turo, Esquire Turo Law Offices 28 S. Pitt Street Carlisle, PA 17013 Attorneys for Plaintiff James G. Nealon, III, Esquire Nealon & Gover 2411 North Front Street Harrisburg, P A 17110 Attorneys for Allstate Indemnity Company and Julie L. Hawkins By: Date: <il/If/i)I t - ~;::;-",,-:>_ _..,__"_~."""',~, "-,F _", ,'0,,,.'''',__,___ ,_",~_ ,. .">___~N _,_,___' ,__". >._","" ,", _7~ =""~"_". ~ ,.. ~ '. ~ , ,...., .Ai, " ~ " ." 1l!'~"';'> - >~' "-~'" .'. '--.-'. -,A-, ,g ~ ,-j",^~ -."'-" ,',' .,,'1'" "", -'."~~''''''''''''~"'''''''','' 'X~",-~" - ~ -- ~'f!~~i;!~Ft'll_J:lRil,_ 0 C::::.: .--) C I , :;,= "'" "TI f-:f; m Po'] :7) Z '" r-- tv en )> c::. -< r- "'" ---', ;,e C) ;;.~~ 1'.,) : - --,' - Z 'h' =-,2 :::J ~-' :;--:J -< _'Ii 'I!I'JI)'!Ih':'~;Il" J.U~~~ ",-,-'<- " IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VERNON LEE MOORE, JR. Plaintiff :NO 2000-7994 : CIVIL ACTION - LAW v. LEE A. PRIAR, JULIE L. HAWKINS, ALLSTATE INDEMNITY COMPANY Defendants PRAECIPE TO THE PROTHONOTARY OF SAID COURT: Please settle, discontinue and mark settled the above captioned matter against Defendants, Julie L. Hawkins and Allstate Indemnity Company only on behalf of the Plaintiff. ~/u/ Dat Respectfully Submitted TURO LAW OFFICES iw--/ Roo T"ro, :!1 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff ,,;/7101 Date! ! 4-lo.fot Dat~ I q- James G. Nealon, III, Esquire Attorney Julie Hawkins and Allstate Indemnity Company . = ~ ., -', '-1" . '~, ~,- ~- ,~- ~ = ~,~". ~" o ~ "'ot1::; ITlfrr ~~~:' -< ~C~ "" ~C-~, ~('"-) )>~ =< ~"'=, .C.C"HCiiin Cd ,- :'--'" ~ GJ r,) ~"~,' 1O co "1> :0 -< ",':,~- ~~~~!;I9OO~M;lIj~'ll~!\!!_,",~~~"J@1_!l!l",'%!!i~""~~""'IIi'W#f>"'"j;i;!ii~F';-"",~".rl""~!!i~"f,f~<1l<"#fajf~~&.'W'lli,~~~r!M'lR$ili':{~~r,!~ " I. VERNON MOORE, JR.. Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY. PENNSYLVANIA :NO.2000-7994 CIVIL TERM v. LEE A. PRIAR, Defendant :JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served. by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further.notice for any money claimed in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle. PA 17013 (717) 249-3166 -, ., ~ -= I! , . VERNON LEE MOORE, JR., Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :NO.2000-7994 CIVIL TERM LEE A. PRIAR, Defendant :JURY TRIAL DEMANDED COMPLAINT 1. The Plaintiff, Vernon Moore, Jr., is an adult individual currently residing at 128 Center Street, Duncannon, Perry County, Pennsylvania, 17020. 2. The Defendant, Lee A. Priar, is an adult individual with a last known address of 18 East Maplewood Avenue, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. On November 16, 1998 the Defendant, Lee A. Priar, was the owner and operator of a 1995 Ford Contour with a registration plate of BL V-8398. 4. On this said date and time, November 16, 1998, in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, at the intersection of York and West Main Streets, the Defendant was the operator of the vehicle while traveling on Pennsylvania Route 641, West Main Street in an easterly direction. 5. At the said time and place, the Defendant, while operating the said vehicle, did enter the intersection at South York Street and struck a vehicle driven by Terry Lee Drebot of Dover, York, Pennsylvania. 6. On the said date, at that time and place, the Plaintiff, Vernon Lee Moore, Jr., was a passenger in the automobile driven by Defendant, Lee A. Priar, as previously described. 7. It was the duty of the Defendant, Lee A. Priar, to operate his motor vehicle with due care and caution in accordance with the applicable Statutes and Ordinances, in effect at that said time and place. 8. At the said and time aforesaid the Defendant, Lee A. Priar, was guilty of one or more of the following careless and negligence acts or omissions: " A. B. The said Defendant, Lee A. Priar, did enter the intersection at an extremely high rate of speed showing reckless indifference for the safety of life and property; The said Defendant, Lee A. Priar, did enter the intersection at the time that the traffic control signal was red in his direction and in violation of appropriate Statutes and the requirement to stop his vehicle and not enter said intersection at the time he had a red light; The said Defendant, Lee A. Priar, did operate his vehicle at the said time and the said place while under the influence of alcohol to a degree which rendered him incapable of safe driving and in serious and reckless disregard for the life, property and safety of others; The said Defendant, Lee A. Priar, did fail to control his vehicle in such a way as to prevent it from colliding with other vehicles specifically the vehicle driven by Terry Lee Drebot at the said time and place. As a direct and proximate result of one or more of the aforesaid careless and negligence acts or omissions by the Defendant, the automobile being driven by the Defendant, Lee A. Priar, did violently collide with that vehicle driven by Terry Lee Drebot. As a direct and proximate result of the aforesaid, the Plaintiff, Vernon Lee Moore, Jr., suffered injuries of a permanent and pecuniary nature including but not limited to loss wages, medical expenses, pain and suffering and physical and emotional trauma, all of which are permanent. c. D. E. F. 11,_.",W " WHEREFORE, the Plaintiff, Vernon Lee Moore, Jr., demands judgment against the Defendant, Lee A. Priar, in a sum in excess of $1 00,000.00 which will fairly compensate the Plaintiff for the injuries sustained. Respectfully Submitted, 9/;/k/ Date Ron Turo, Esquire Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 " VERIFICATION I, Ron Turo, Esquire, attorney for the Plaintiff herein, have sufficient knowledge of the facts contained in this Complaint and verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, based upon information received from the Plaintiff. I understand that false statements herein made are subject to the penalties of 18 Pa. C.SA 94904 relating to unsworn falsification to authorities. 9!I!o; Date o Ro 1< " " CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint upon Brigid Q. Alford, Esquire, by depositing same in the nited States Mail, first class, postage pre-paid on the / ) day of S 2001, from Carlisle, Pennsylvania, addressed as follows: Brigid Q. Alford, Esquire Bosweell, Tintner, Piccola & Wickersham 315 North Front Street P.O. Box 741 Harrisburg, PA 17108-0741 LAW OFFICES ~1 Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff -.".-'-"",' ".,.. f" ~-, ! ~: ~i ~l II ~! " II 'I I, II !I II ~J ~! II ~,< -"-"~ " .., . -",' .~,,; o,v__ <<-~,.. -~ () 0 c, C '-"n ~".. ~~ (J') ":;1 CTl -0 !ll " I":::':::' t;s ~-~) 1" " (....,} -y) ..,..' ~2~; ,',.j C) .., P-. ""tJ -~- -Tj -zb ::c ;~ J ~:s )> 1~-? O;-n C L. -, :< ,;:> ~ -< r-liI<rl",~~ "!l!l"""'!!lI~~~~lfil1llR'~ffil$!ilI$i:'~llj*~I!~H~~a;1I!>1~!.lri\~V~!'*"lr,'."""f~iJ?;~~M,-W.'ll.:!~il:ii'!,,~wmr$~~1i',~r'I1l'W'~~Ji"N'~'~';'Wi;~~'i!l!I'1'T~!~ Jeffrey E. Piccola, Esquire Supreme Courtl.D. #18018 Brigid Q. Alford, Esquire Supreme Court LD. #38590 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108~074l Attorneys for Defendant Lee A. Priar VERNON MOORE, JR., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. No. 2000-7994 LEE A. PRIAR, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED NOTICE TO PLEAD ,I .. , I J ;1) ;:! TO: Vernon Moore, Jr. C/O Ron Turo, Esquire Turo Law Offices 28 South Pitt Street Carlisle, P A 17013 You are hereby notified to file a written response to the enclosed New Matter, within twenty (20) days from service hereof or a judgment may be entered against you. BOSWELL, TINTNER, PICCOLA & WICKERSHAM By: ~)~~ Brigid . Alford, Es rre Date: loll (OJ , - '.- _h ,,- ".' "', ".c___ ,~-",_~.., o.~ ,,< ",,"""'.'.'-' '-,-, -"'="'.-' - '" <, ~- -'-.'-,-.~-,~- '''''.' """.1'_ :1~,~ ,.,,!,"" ,~- m:\home\bqa\litigat\statefrm\priar\answernmt.wpd Draft #2 September 27, 2001 Jeffrey E. Piccola, Esquire Supreme Courtl.D. #18018 Brigid Q. Alford, Esquire Supreme Court ID. #38590 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 HarrisbW'g, Pennsylvania 17I08~0741 Attorneys for Defendant lee A. Priar VERNON MOORE, JR., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. No. 2000-7994 LEE A. PRIAR, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED DEFENDANT'S ANSWER TO COMPLAINT WITH NEW MATTER Defendant Lee A. Priar, by his attorneys, Brigid Q. Alford, Esquire and Boswell, Tintner, Piccola & Wickersham, answers Plaintiffs Complaint, as follows; I. Admitted that Plaintiff is an adult individual. Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments as to Plaintiff s current residence address; proof thereof is demanded. 2. Admitted. 3. Admitted. 4. Admitted. 5. Defendant denies the allegations as set forth in Paragraph 5 of the Complaint; proof thereof is demanded. ... - , ""_~. __ ,c,." '0" ,~ ,__ ,. ,," -,-- -. .,." '. '.n - --- , ". -~ ... "J ,-_-.' "'.".' .' " .,. . ~. 6. Admitted. 7. Paragraph 7 sets forth a conclusion oflaw to which no response is required. To the extent a response is deemed required, Defendant denies the implication in Paragraph 7 that he did not operate his motor vehicle with due care and caution in accordance with applicable statutes and ordinances in effect at the said time and place. 8. Paragraph 8 sets forth a conclusion oflaw to which no response is required. To the extent a response is deemed required, Defendant: A. Denies that he entered the intersection at an extremely high rate of speed showing reckless indifference for the safety of life and property; B. Denies that he entered the intersection at the time that the traffic control signal was red in his direction and in violation of appropriate statutes and the requirement to stop his vehicle and not enter said intersection at the time he had a red light; C. Denies that he operated his vehicle at the said time and place while under the influence of alcohol to a degree which rendered him incapable of safe driving and in serious and reckless disregard for the life, property and safety of others; D. Denies that he failed to control his vehicle in such a way as to prevent it from colliding with other vehicles specifically the vehicle driven by Terry Lee Drebot at the said time and place. E. Paragraph 8(E) sets forth a conclusion of law to which no response is required. Should a response be deemed required, Defendant denies the same. -2- , 1-: <~- ~ .~. ~,'~'_ ~<r".',',~__ _ ~ "" ~,_ , --1"-" ..- -" ~ I" . ~ ,--,- F. Paragraph 8(F) sets forth a conclusion of law to which no response is required. Should a response be deemed required, Defendant denies the averments or allusions to his acts or omissions. As to the averments of injury and damage, Defendant is without knowledge or information sufficient to form a belief as to the truth ofthose averments; proofthereof is demanded. WHEREFORE, Defendant respectfully demands judgment in his favor and against the Plaintiff. NEW MATTER 9. Plaintiff has failed to state a claim upon which relief can be granted. 10. Pennsylvania's comparative negligence statute bars Plaintiffs claims. 11. Plaintiff s claims are barred by the doctrine of assumption of risk. 12. Plaintiff and/or his representative have received and accepted payment of monies for damages allegedly incurred as a result of the accident at issue. 13. The doctrine of accord and satisfaction bars all or part of Plaintiffs claim. 14. The doctrine of waiver bars all or part of Plaintiffs claim. 15. Plaintiff s injuries and damages, if any, were caused by the acts or omissions of persons other than Defendant. -3- '---" " " -. - ~'- ',' _ ,'e_", _ <__~ H,' ~__"'_.~ '". -~..':-'" -.,-" '-''''__ >-, _~ > <cl- ~ rJ .--.~ WHEREFORE, Defendant respectfully demands judgment in his favor and against the Plaintiff. Respectfully submitted, By: ~z~ Brigid Q. ford, Esqui Supreme Court LD. #38590 Jeffrey E. Piccola, Esquire Supreme Court LD. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Lee A. Priar Date: IOf for l {j': "c" ~ ._._ c---"-" ",,,'""'.:'_,'_ ~c"O,.,"-~"-"'~ -, - -- .~_. "'>'ov_ ~_ 1:'-'- ~, -~ --, VERIFICATION Brigid Q. Alford, Esquire, being duly sworn according to law, deposes and says that she is the attorney for Defendant Lee A. Priar, that said Defendant cannot make the verification to the foregoing Answer with New Matter to Plaintiff s Complaint because Defendant Priar' s verification cannot be obtained within the time allowed for filing, and that the facts set forth in the foregoing are true and correct upon her personal knowledge, information and belief. ~~,uJ cl t1~ -> Brigif! Q. Alford J Date: October 1,2001 ',',','''"-,=-,,--.",,.,,-,-""]--,- -','",-. . -~~ ,"' --> ,-- ""I ~, - ": ~- ,." ",~.- -'," ., _no_ . ' CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Defendant's Answer to Complaint with New Matter by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Ron Turo, Esquire Turo Law Offices 28 South Pitt Street Carlisle, P A 17013 By: Bri~~~ Date: lolllo( , r;~,~~ ,_ I;; ,'.-" .,,", ,~~ , - '.~ - - '=-.- ,<., _",p,""" ,- '.- """ 'r -" . . 'r:--'C --~ <"> -q .- _ ~_~ r'~ - ~J Ch .~ ~~~~~~~~~-,~---" c:,~ ("j ." :':') '-:, -.~.,., r'. f'.: :-7 ~~ '>O'j f~~. ,J II . II VERNON LEE MOORE, JR., Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :NO.2000-7994 CIVIL TERM LEE A. PRIAR, Defendant :JURY TRIAL DEMANDED ANSWER TO NEW MATTER 9. Denied. This allegation is a conclusion of law to which no responsive pleading is required; however, by way of further answer, Plaintiff realleges the allegations set forth above and is entitled to recovery as a matter of law. 10. Denied. This allegation is a conclusion of law to which no responsive pleading is required; however, by way of further answer, Plaintiff realleges the allegations set forth above and is entitled to recovery as a matter of law. 11. Denied. This allegation is a conclusion of law to which no responsive pleading is required; however, by way of further answer, Plaintiff realleges the allegations set forth above and is entitled to recovery as a matter of law. 12. Denied. Plaintiff has not received and accepted payment of monies for these damages. Proof of the same is demanded at trial. 13. Denied. This allegation is a conclusion of law to which no responsive pleading is required; however, by way of further answer, Plaintiff realleges the allegations set forth above and is entitled to recovery as a matter of law. 14. Denied. This allegation is a conclusion of law to which no responsive pleading is required; however, by way of further answer, Plaintiff realleges the allegations set forth above and is entitled to recovery as a matter of law. ,',~-". ,_o"_"'P__" C,,,___ - ~~ .,.. -, ' II C. 15. Denied. This allegation is a conclusion of law to which no responsive pleading is required; however, by way of further answer, Plaintiff realleges the allegations set forth above and is entitled to recovery as a matter of law. WHEREFORE, Plaintiff demands judgment in his favor against the Defendant. Respectfully Submitted, /0 ICJ/oI Date Ron Turo, Esquire Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 I:;'~ ~" ,_'0. . _~_ , II . CERTIFICATE OF SERVICE I do hereby certify that I served a true and correct copy of the aforegoing Plaintiffs Answer to New Matter by placing the same in United States mail, first class, postage prepaid, at Carlisle, Pennsylvania addressed as follows: Brigid Q. Alford, Esquire 315 N. Front Street P. O. Box 741 Harrisburg, PA 17108-0741 (otO(C/1 u~. Ifl-/ it Ron Turo, Esquire Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Date " -~" .. " .- '" . ... "~,. , ~< , ~~.,~ -, ~-) ~ \::':.' .-.1" . ~-, "." (..';:' - ~o,~~~~~~~""II!~~~17f'-lJ~~ ~'~"'I<~"'l'~!!>'I'!I'~2"~'0'-:-~~"j""~'l\"~"i~t"f""",I~"f<~~",J:!;,,,_"!I/~~~Il&t~'lI~"~~P!ll~~~ Jeffrey E. Piccola, Esquire Supreme Cow1I.D. #18018 Brigid Q. Alford, Esquire Supreme Cow1 I.D. #38590 BOSWEll, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, P~nnsylvania 17108-0741 Attorneys for Defendant LeeA.Priar v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2000-7994 VERNON MOORE, JR., Plaintiff Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED LEE A. PRIAR, CERTIFICATE PREREOUlSITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rille 4009.22, Defendant certifies that: (1) a notice ofintent to serve the subpoenas with copies of the subpoenas attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, (3) no objection to the subpoenas has been received, and f-1\'L ;~'. -. ',-~ -"'H'-~~,!" .__';',,?,c,p,-,",_ -I-'"h_ ,."". ,_','_N".. <..--'t'-< "_r"- _,~.? " ,~" '-.'- ..,,' -,'~ '-':". ,,--~ , e ,,_ _ ~~,. ~, -~ " i); (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. Respectfully submitted, By: ~=o( a~ Brigi . Alford, Esq e Supreme Court #38590 Jeffrey E. Piccola, Esquire Supreme Court #18018 Boswell, Tintner, Piccola & Wickersham 315 North Front Street Harrisburg, PA 17101 (717) 236-9377 Attorneys for Defendant Priar Date: 3 /2() /0 l-- !~'-'- ,,_,C', -"_--''~-_ ,",__ ,r,_1',,,,i_,_"_.,'" _ _'", ,. _ _, . <,_T__ . ,!-",' "',-0-__ o ::-,_,.T." _ '_'-" _~_-_,_ ,-"'-. , -i ,-,' ,'''_', ~ ,< . -_^",,". "".., " ~ .....__ _~ " ~ Jeffrey E. Piccola. Esquire Supreme Court LD. #18018 Brigi<l. Q. Alford. Esquire Supreme Court LD. #38590 BOSWELL. TINTNER. PICCOLA & WlCKERSHAl\1 315 North Front Street Post Office Box 741 Harriliburg. Pennsylvania 17108-0741 Attol"l1eys for Defendant Lee A.. Priar v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA No. 2000-7994 VERNON MOORE, JR., Plaintiff Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED LEE A. PRIAR, NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant Priar intends to serve subpoenas identical to the ones that are attached to this notice upon the following: 1. Giant Foods 2. Winding Hill Window Cleaning 3.' Rite Aid Corporation 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. Ifno objection is made, the subpoena may be served. Respectfully submitted, By: Brigid . Alford, Es Suprerne Court #38 0 Boswell, Tintner, Piccola & Wickersham 315 North Front Street Harrisburg, PA 17101 (717) 236-9377 Attorneys for Defendant Priar Date: "I;2.0(? ( I:,:".' . ., '""--'~"'';-, ~~,~n.', .-- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ' VERNON MOORE, JR., Plaintiff v. LEE A. PRIAR, File No. 2000-7994 Defendant SUBPOENA TO PRODUCE DOCUMENTS ORTHINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 TO: Giant Foods (Name of Person or Entity) Nithin twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: . Any and all employment records. personnel records, perfoDn~nce evaluations, salary records. employment applications, etc.. for Vernon Moore, Jr., Social Security No. 199-54-3073. ~t 315 North Front Street. Harrisburcr, PA 17101 (Address) You may deliver or mail legible copies 01 the documents or produce things requested by this subpoena, rogether Nith the certificate of compliance, to the party making this request at the address listed above. You have the right :0 seek in advance the reascnable cost 01 preparing the copies or producing the things sought. 1 you fail to produce the doc:Jments or things required by this subpoena within twenty (20) days after its service, :he party ser/ing this sui:poena may seek a court order compelling you to comply with it. THIS SlJBPOENA WAS ISSUELJ AT THE REQUEST OFTHE FOllOWING PERSON: ,\Jame Briqid Q. Alford, Esquire 315 North Front Street Post Office Box 741 :'dcress: Harrisburq, PA 17108-0741 Telephene: (717) 23'6-9377 3upreme Court 10 ifr 38590 -'trorney For: Defendant Priar BY THE COURT: Prothonotary/Clerk. Civil Division ............~. .....O'L_. Seal of the COLlrt Deputy (Elf. 7/97) ~--- "'" - ~-~_.--.- - ,-,,--- c". '.,~-, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERNON MOORE, JR., Plaintiff v. LEE A. PRIAR, Defendant File No. 2000-7994' SUBPOENA TO PRODUCE DOCUMENTS ORTHINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 TO: Windinq Hill Window Cleaninq (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: Any and all emplovmp.nt rp.~nrrl~. personnel rp.coms.performance evaluations. salary records. emp]oymp.nt applications. etc.. for Vp.rnon Monrp. ,Tr . Social Securitv No. 199-~4-1071 at 315 North Front Street. H~rris~lrq. pa 17101 (Address) 'fou may deliver or mail legible copies of the documents or produce things requested by this subpoena, together Nith the certificate of compliance, to the party making this request at the address listed above. You have the right :0 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. :he party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OFTHE FOLLOWING PERSON: Name Briqid O. Alford. F,,,<;!uirp. 315 North Front Street .J.,ddress: Post Office Box 741 Harrisburg, PA 17108-0741 Telephone: (717) 236~'9377 3iJpreme Court iD ;# 38590 .J.,ttorney Fer: Defendant l'riar BY THE COURT: Prothonotary/Clerk. Civil Divisien :Jate: Seal of the Court Deputy (Eft. 7/97) "":'? - ~ '\ '-"'~j'fo/',,,, _',' ., -,~, ,,-.%~. " " ,- <,:~", _ _ , o. ~ ", - ." COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERNON MOORE, JR., Plaintiff v. LEE A. PRIAR, File No. 2000-7994 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 fO: Rite Aid Corporation (Name of Person or Entity) Nithin l'Nenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all employment records. personnel records. performance evaluations. salary records. employment applicatinn~ etc.. for Vernon Moore. Jr.. Social Security No. 199-S4-3073 3t 31~ Nnr+h ~rnM+ ~+rp~~ R~rr~a~t'r~. PA 17101 (Address) (ou may deliver or mail1egible copies of the documents or produce things requested by this subpoena, together Nith the certificate of compliance, to the party making this request at the address listed above. Vou have the right :':: seek in advance the reasonable cost of preparing the copies or producing the things sought. f you fail to produce the documents or things required by this subpoena within l'Nenty (20) days after its service, :~e party serving this subpoena may seek a court order compelling you to comply with it. fHIS SUBPOENA WAS ISSUED AT THE REQUEST OFTHE FOllOWING PERSON: ~ame Brigid Q. Alford, Esquire 315 North Front Street .l.,ddress: Post Office Box 741 HarriSburg, PA 17108-0741 feiephone: (717l 236-9377 Supreme Court 10 # 3RS90 ..l.~!orriey For: Defendant priar BY THE COURT: Prothonotary/Clerk, Civil DivisIon :Jate: Deputy Seal of the Court (Eft. 7/97) ,,'" ~,.- -.' -.,-'. -'; ,.'"-' " '." ~.~" . ~, '. CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Defendant Priar's Notice of Intent to Serve Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 by frrst-class United States mail upon the following parties at the addresses set forth below: Ron Turo, Esquire Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 Attorneys for Plaintiffs By: B~~E~ Date: 11 / ~/O{ I l '~_,_,_~"" ,,","'"': r'H~' _. _ !';'_-"'_"'.,-,." ~ ~__, . ~ CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena on the following by first-class mail, postage prepaid and addressed as follows: Ron Turo, Esquire Turo Law Offices 28 South Pitt Street Carlisle, P A 17013 Attorneys for Plaintiffs By: Date: 3!;:;,o./od.. ".',- .~-,,"::~, -w~'< ~_c _ ." ~-_"~__."_-- ",,~~-p._,_'1",'_,~_ ,-" , l'~-'__ '- -'_'~.__ _"", ,"_,.." _,^, _-""" ~~__~ _~ , ~"_, _ . . ""'~<~. ~ ~, ~. '-',- "' --,""~,,"- ~'-". .', _<_-' -',"_'~,H~"'I,^".o'_-',""_~'_ o c:: :?' -Ve': nlrr ~fL' ~;~-- ~ cC :_.,Ci C' =2 . ...,~, -,. C::l r"-.) ::JC C") -','1 ):71>> N --r:) .) "-.)- .-J - . _~'!!"tflllil!i';1~~flIMllll!l!J!!~,,~< ~_, Il'!ll!l ~__~_w"" '.-_,""'" ,._ w."I/l. { T Brigid Q. Alford. Esquire Supreme Court ID. #38590 Jeffrey E. Piccola, Esquire Supreme Court LD. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 3] 5 North Front Street Post Office Box 741 Harrisburg, Pennsylvania ]7108-074] Attorneys for Defendant Lee A. Priar v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2000-7994 VERNON MOORE, JR., Plaintiff Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED LEE A, PRIAR, CERTIFICATE PREREOUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: (1) counsel for Plaintiff waived the twenty (20) day appeal period; (2) copies of the proposed subpoenas are attached to this certificate; and (3) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. Respectfully submitted, Brigid . Alford, Esq Supreme Court #3859 Boswell, Tintner, Piccola & Wickersham 315 North Front Street Harrisburg, P A 1710 I (717) 236-9377 Attorneys for Defendant Priar By: Date: ((1-1,11)")-- 1< < <; ,,~yq .,.0<;', , ,<,< ^"~, m""1., '.~..," -,~ .-~^ I.;.-,~ ~'r- ~- 'M _.~,~u ,_'p ~_ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERNON MOORE, JR., Plaintiff v. LEE A. PRIAR" File No. 2000-7994 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PINNACLE HEALTH HOSPITAL - PHYSICAL THERAPY (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: Any and all medical records, treatment records, correspondence, referrals, etc. . for VErnon Moore, Jr., (Social Security #199-54-3073) (Date of Birth: Dec. 5, 1969) from 1998 to present. at 315 North Front Street, Harrisburg, PA 17101 (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 Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & Wickersham Address: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 Telephone: (717) 236-9377 Supreme Court 10 # 38590 Attorney For: Defendant Priar Seal of the Court Date: 7Ku :( 1. ).o-r; J... (Elf. 7/97) ~rc",," A"",~ C^"""i ~"'~~,"'-", .~ '-"~-,.' ",'" "~""'~" -= ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERNON MOORE, JR" Plaintiff v. LEE A. PRIAR, File No. 2000-7994 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 TO: STUART A. HARTMAN, D.O. (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: Any and all medical records, treatment records, correspondence, referrals, etc. for VErnon Moore, Jr., (Social Security #199-54-3073) (Date of Birth: Dec. 5, 1969) from 1998 to present. at 315 North Front Street, Harrisburg, PA 17101 (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 Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & Wickersham Address: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 Telephone: (717) 236-9377 Supreme Court 10 # 38590 Attorney For: Defendant Priar BY~ Prothon Date: 71~~ ~ ) . dJ)' () ).. Seal of the Court (Elf. 7/97) ,x-~,_ '_,- ,- 1>',""""' ~c, ,,---< "', .. ,;.."' .-., , ,~" , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERNON MOORE, JR., Plaintiff v. LEE A. PRIAR, , File No. 2000-7994 Defendant SUBPOENA TO PRODUCE DOCUMENTS ORTHINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL (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: Any and all medical records, treatment records, correspondence, referrals, etc. for VErnon Moore, Jr., (Social Security #199-54-3073) (Date of Birth: Dec. 5, 1969) from 1998 to present. at 315 North Front Street, Harrisburg, PA 17101 (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 Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & Wickersham Address: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 Telephone: (717) 236-9377 Supreme Court ID # 38590 Attorney For: _ Defendant Priar BYTHE COURT: (; t:i4 Date: n~ d{ ).. d &-rJ J... Seal of the Court Deputy (Elf. 7/97) ",., ~,,--', COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERNON MOORE, JR., Plaintiff v. LEE A. PRIAR, , File No. 2000-7994 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 TO: SCHEIN ERNST F.YF. ASSOC.TA~F.S (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: Any and all medical records, treatment records, correspondence, referrals, etc. for VErnon Moore, Jr., (Social Security #199-54-3073) (Date of Birth: Dec. 5, 1969) from 1998 to present. at 315 North Front Street, Harrisburg, PA 17101 (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 ISSUEDATTHE REQUEST OF THE FOllOWING PERSON: Name Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & Wickersham Address: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 Telephone: (717) 236-9377 Supreme Court 10 # 38590 Attorney For: Defendant Priar BY lHE COURT. : \' - _~[{A Prothonot Date: It~ J.. lc ~ CTlJ J.. Seal of the Court (Elf. 7/97) CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena on the following by first-class mail, postage prepaid and addressed as follows: Carol L. Cingranelli, Esquire Turo Law Offices 28 South Pitt Street Carlisle, P A 17013 Attorneys for Plaintiffs By: Date: ,/J3/;) r I t '~,~ ",,&, ""'/'ry,_'Cl_",_'h~"_",,, ''''^'''';'_ !~_""M."",",o',~ c"- ". ,_ '. "", __~N , " '. ,< . < - ~, ' -. C'_~m"___ ~" ~HC~ - - ,.. m ,-, u -~- ,. --~-~ - "~~__ .;.'. "r.~"", ._.""'~ '~'" ,. - "~~ _'_''''"''_ ,-" '", ", _"""_-"'V~".."T ~~~ ~".~,~" ,~~_^ ll)~'_~!"'-_"~7"'l'ffi!'""I!ffi!Ii!!lli$l~~ \'ll ~ (; C ~;: ~ -C .." ::..,..) ::-"~ -':,) .','-' '''= '--:1 I, ) ~_I ~i:.l =<. :,:, <0 .." ~~, -"'~""~r' :c . Brigid Q. Alford, Esquire Supreme Court ID. #38590 Jeffrey E. Piccola, Esquire Supreme Courtl.D. #18018 BOSWELl., TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Lee A. Priar v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No, 2000-7994 VERNON MOORE, JR., Plaintiff Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED LEE A. PRIAR, CERTIFICATE PREREOUlSITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009 .22, Defendant certifies that: (1) counsel for Plaintiff waived the twenty (20) day appeal period; (2) copies of the proposed subpoenas are attached to this certificate; and (3) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. Respectfully submitted, Brigid Q. ~ford, Esquir Supreme Court #38590 Boswell, Tintner, Piccola & Wickersham 315 North Front Street Harrisburg,PA 17101 (717) 236-9377 Attorneys for Defendant Priar By: Date: ""11.<f/n~ { J.'f..," -:-:''''~'''''..1~-~ '~".. ~'ip. -~F 'c.' ~~ _ 00' _ > _ _,.,.d'" ,,_~_ . - .'"~'. .,~.. ___~ ~., H.~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERNON MOORE, JR., Plaintiff v. LEE A. PRIAR, File No. 2000-7994 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Jack H. Moody, M.D. (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: Any and all medical records.-treatment records. correspondence, referrals. etc. for Vernon Moore. Jr., (Social Security #199-54-3073); Date of Birth: Dec. 4, 1969; from 1995 to present. at 315 North Front Street, Harrisburq, PA 17101 (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 reasonabie 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 ATTHE REQUEST OF THE FOLLOWING PERSON: Briqid Q. Alford. Esquire Boswell, Tintner, Piccola & Wickersham 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 Telephone: (717) 236-9377 Name Address: Supreme Court ID # 38590 Attorney For: Defendant Priar BY THE COURT: Prothonotary/Clerk, Civil Division Date: Seal of the Court Deputy (Eft. 7/97) , ""'1',<=., . ..,.y" '.'<""''<'' ",''e.,- . '- , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERNON MOORE, JR., Plaintiff v. LEE A. PRIAR, File No. 2000-7994 Defendant SUBPOENA TO PRODUCE DOCUMENTS ORTHINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 TO: Pinnacle Health - Polyclinic (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: Any and all medical records.-treatment records. correspondence, referrals, etc. for Vernon Moore, Jr.. (Social Security #199-54-3073); Date of Birth: Dec. 4, 1969; from 1995 to present. at 315 North Front Street, Harrisburq, PA 17101 (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: Briqid O. Alford, Esquire Boswell, Tintner, Piccola & Wickersham 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 Telephone: (717) 236-9377 Name Address: Supreme Court 10 # 38590 Attorney For: Defendant Priar BY THE COURT: Prothonotary/Clerk, Civil Division Date: Seal of the Court Deputy (Eft. 7/97) '.'\---'->., -" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERNON MOORE, JR., Plaintiff v. LEE A. PRIAR, File No. 2000-7994 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 TO: Magnetic Imaqinq Center (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: Any and all medical records.-treatment records. correspondence. referrals. etc. for Vernon Moore. Jr.. (Social Security #199-54-3073); Date of Birth: Dec. 4. 1969; from 1995 to present. at 315 North Front Street, Harrisburq, PA 17101 (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: Briqid O. Alford. Esquire Boswell, Tintner, piccola & Wickersham 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 Telephone: (717) 236-9377 Name Address: Supreme Court ID # 38590 Attorney For: Defendant Priar BY THE COURT: Prothonotary/Clerk, Civil Division Date: Seal of the Court Deputy (Elf. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERNON MOORE, JR., Plaintiff v. LEE A. PRIAR, File No. 2000-7994 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 TO: John S. Rychak, M.D. and Orthopedic Surqeons of Central PA (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: Any and nll medical records..treatment records. correspondence. referrals. etc. for Vernon Moore. Jr.. (Social Securitv *199-54-3073), Date of Birth: Dec. 4, 1969, from 1995 to present. at 315 North Front Street, Harrisburq, PA 17101 (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: Briqid Q. Alford. Esquire Boswell, Tintner, piccola & Wickersham 315 North Front Street Post Office Box 741 Harrisburg, FA 17108-0741 Telephone: (717) 236-9377 Name Address: Supreme Court 10 # 38590 Attorney For: Defendant Priar BY THE COURT: Prothonotary/Clerk, Civil Division Date: Seal of the Court Deputy (Elf. 7/97) :>'-~'"-" "~--', ".. -, f._,_ .,- ., 'O?" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VERNON MOORE, JR., Plaintiff v. LEE A. PRIAR, File No. 2000-7994 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 TO: HealthSouth - Mechanicsburq (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: Any and all medical records,. treatment records. corresPondence, referrals, etc. for Vernon Moore. Jr.. (Social Security *199-54-3073); Date of Birth: Dec. 4, 1969; from 1995 to present. at 315 North Front Street, Harrisburg, PA 17101 (Address) You may deliver or mail iegible 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: Briqid O. Alford. Esquire Boswell, Tintner, Piccola & Wickersham 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 Telephone: (717) 236-9377 Name Address: Supreme Court 10 # 38590 Attorney For: Defendant Priar BY THE COURT: Prothonotary/Clerk, Civil Division Date: Seal of the Court Deputy (Elf. 7/97) CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena on the following by first-class mail, postage prepaid and addressed as follows: Carol L. Cingranelli, Esquire Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 Attorneys for Plaintiffs By: Date: 1/1{J;2.. ( f",._,,,,.,o~__~~~ 0'__<' ',' "-n~""<"(,,,,,""'~- ",,~ '-"_,,',<.r< .o-~-. ~_,,_,_,_, _ _""",'''n_ - - ,,,' - - -,~- -~--'- -- - "~' . ',_ "',"' __ _ c,_" ,e,_, _,~ ",. '- ~~.," _~~~_~~,,"'. .~ " ""'""!~"."... .~~ ~,- l!Ift ~=~_ "'=' ,--'--~~~'"~- , -'~,"y~, o___"~~J\.,,,,~ -~- o C 'Z" ~i~ t:}J,<- ce., ~F\ :~'s'~; ~ ',-~'; ,.."" ~-,_.--"" c. ~j ,'-"J t":::= \.....J <.j. ~-~ d';~T-",",' '''''"~~',.' 'O-<~',_,' .,....._.. .C'''_''-:-' '~; ~~ -,'>' () ~J,j C) ,r"r;-\ ~ '< C? :..n - ~~ .. , VERNON MOORE, JR., Plaintiff v. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 2000-7994 CIVIL TERM LEE A. PRIAR, Defendant :JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please settle, withdraw and discontinue the above-captioned matter on behalf of the Plaintiff. Respectfully Submitted TU LAW OFFICES J-h) Ron Turo, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff J-,'.'''', 'II "I j~ ". . '.0"1" ~ . .,~!UiI1I~!U!Ii!!'~M"" ~. ',~ -".""'-. .. ,,,,,. '~,_,_". ,,'~~,. ~"'"_"'" -"'~""7 ,",,' .,;; L ..~" ...""" 'd""">" "'~ -c>-,__. ~,,.,, ..~ o ~ ~ [Up ....- ,. 6!'~~ . -.-.,"', r::r :s:: ~. f: 2~~~;- 5": =2 ~.....) .~J L "'1"; :,-) ---.' -~. ' .--!..i -~':" :.'1~~~~~MWij/<1!.,\'=.;;jq(,"'J~Wo<1.t!w-m~!c,liW~AAl!i"JMllli~I~~~:P;;r'_ __~_ """J;1,"1ilI\!,~