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HomeMy WebLinkAbout00-08209t S IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA AMY DEVINS 363 South Main Street Marysville, PA 17053 Plaintiff(s) and Address(es) NO. S 2000 Oo - ?c2O9 Civil Action - Law VS. KEITH A. HOCKER 704 Ridge Road Lewisberry, PA 17339 Defendant(s) and Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF CUMBERLAND COUNTY: r Please issue a Writ of Summons in the above-captioned action. Said Writ of Summons shall be issued and forwarded to the Cumberland County Sheriff in order to deputize York County Sheriff in order to complete service upon Defendant. Dennis R. Sheaffer TUCKER ARENSBERG & SWARTZ 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 Signature Attom y Supreme Court I.D. #39182 Date: 1?' 2d "DT WRIT OF SUMMONS TO THE ABOVE-NAMED DEFENDANT: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. L Prothonotary 34386.1 SHERIFF'S RETURN - OUT OF COUNTY CA& N0: 2000-08209 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEVINS VS HOCKER KEITH A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: HOCKER KEITH A but was unable to locate Him deputized the sheriff of YORK in his bailiwick. He therefore serve the within WRIT OF SUMMONS County, Pennsylvania, to On December 6th , 2000 , this office was in receipt of the attached return from YORK Sheriff's Costs: So ans s Docketing 18.00 Out of County 9.00 -" Surcharge 10.00 . Thomas Kline DEP. YORK CO 29.75 Sheriff of Cumberland County .00 66.75 12/06/2000 TUCKER, ARENSBERG & SWARTZ Sworn and subscribed to before me this jy? day of ?Gyi) A. D. " ho ? r Prothonot ry COUNTY OF YORK OFFICE OF THE SHERIFF S(R;I719 0 L 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN De-1-ns 3. 2. 4. TYPE OF WRIT OR COMPLAINT 14TRTT Or SUMMONS SERE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. Keith A. Hacker 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT. NO., CITY, BORO, TWP., STATE AND ZIP CODE) AT 704 Ridge Rd, 1,ewi-sber.rv, PA 1'' 39 7. INDICATE SERVICE: O PERSONAL O PERSON IN CHARGE 7R DEPUTIZE a 1S CLASS MAIL .42,0 TED ? OTHER NOW 1 ??? no 20 I, SHERIFF OF h ethe sheriff of York COUNT to ex ®e t t and mak return thereof according to law. This deputization being made at the request and risk of the plaintiff. ` SHERIFF OFjOUNTY 6. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: .--------- -- -- Cumberland Co. OUT OF COUNTY CUMBERLAND ADVANCE FEE PAID BY CUMBERLAND COUNTY SHERIFF NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN -Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9. TY n AD RN RIGINATOR and SIGNATURE 10. TELEPHONE NUMBER Ill. DATE FILED , 111 N. FRONT ST., PO BOX 889, HARRISBURG, PA 17108-0889 (717) 234-4121 11/21/00 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). CUMBERLAND COUNTY SHERIFF 13. 1 acknowledge receipt of the writ or complaint as indicated above. J. LUDWIG 14. DATE RECEIVED 15. 12E/ration/Hearing 11/27/00 1/00 16. HOW SERVED: PERSONAL( ) ' RESIDENCEK POSTED( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17. O 1 hereby certify and return a NOT FOUND because l am unable to locate the individual, company, etc. named above. (See remarks below.) 1 E AND TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. to of ervice 20. Time of Service L)c? cK wY?F l/d9?o WI& 21.ATTEMPTS Date Time Miles Int. Date Time Miles Int. Date Time Miles Int. Date Time Miles Int. Date Time Miles Int. Date Time Miles Int. 50 22. REMARKS V123. Advance Costs 24. Service Costs 25. N/F 26. Mileage 27. Postage 28. Sub Total 29. Pound 30. Notary 31. Surchg. Ica- 100.00 18.00 9.75 27.75 2.00 34. Foreign County Costs 35. Advance Costs 36. Service Costs 37. Notary Cert. 38. Mileage/Postage/Not Found 3 41. AFFIRMEp?gpMsuulZs5rribed to before me this 4z. day Of UU ?? tt kk ; 20 _ 004 Notarial Seal James V. Vangreen, Notary Public York, York County, PA My Commission Expires Jan. 22, 2001 Dep. Sheriff 46. Signature of York Coun Sheriff WIMAM M. HOSE 48. Signature of Foreign County Sheriff 50. 1 ACKNOWLEDGE RECEIP' OF AUTHORIZED ISSUING ? ?a-7(< eldJ Tot. Costs 33. Casts Du Refund Check No. 29-T 70-25 rtal Costs 40. Costs Due or Refund 45. D E 06 47. fjfp E1 _O0 ? 38x8x 49. DATE 1. WHITE- Issuing Authority 2.PINK -Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sheriffs Office COUNTY OF YORK OFFICE F THE SHERIFF 28 EAST MARKET ST., YORK, PA 17401 SERVICE CALL (717) 771-9601 SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINE 1 THRU 12 DO' NOT DETACH ANY COPIES 3. Amv De-i.ns 4. TYPE. OF WRIT OR COMPLAINT WIRTT OI SUMMONS SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. Keith A. Hockey 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT. NO, CITY, BORO, TWP., STATE AND ZIP CODE) AT 704 Ridge Rd, Tew;.sherrv, PA 17'3'39 7. INDICATE SERVICE: QPERSONAL Q PERSON IN CHARGE. V DEPUTIZE ;. GIST CLASS MAIL .,_,??,STED OOTHER NOW 11 ri 7 /O (1 20 I, SHERIFF OF . h 3itti?e the sheriff of vork COUNTY to ex ® -e t ? It and mak return thereof according to law. This deputization being made at the request and risk of the plaintiff. SHERIFF OF-Y OUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE:.: Cumber-land Co. OUT OF COUNTY CUMBERLAND ADVANCE FEE PAID BY CUMBERLAND COUNTY SHERIFF NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN -Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof 111 N. FRONT ST., PO-BOX 889, HARRISBURG, PA 17108-0889 1(717) 234-4121 111/21/00 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). CUMBERLAND COUNTY SHERIFF SPACE BELOW FOR USE OF THE SHERIFF - DO NOT WRITE BELOW THIS LINE 13. l acknowledge receipt of the writ 14. DATE RECEIVED 15. EX irationlHearing Date or complaint as indicated above. J. LUDWIG 11/27/00 12. 1/00 16. HOW SERVED: PERSONAL( ) RESIDENC POSTED( ) POE( ) SHERIFFS OFFICE( ) OTHER( ) SEE REMARKS BELOW 17. O f hereby certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.) 1 NA?ME A_ND TI?TL(E OF INgDIVIDUAL SERVED /LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 79. Ito of/gervice 20. Time of/Service .L9.-"? 'C" N7P A , A7 1C Tr S-C?F { /? 1 or, 1. (!J A' Date Time I Miles I Int. I Date I Time I, Miles I Int. Jodie 7 Y)23. Advance Costs 24. Service Costs 25. N/F 26. Mileage 27. Postage 28. Sub Total 29. Pound 30. Notary 37. Surchg. 32. Tot. Cost33. CASLS Du Refund Cheek No ® 100.00 ?tw 18.00 9.75 27.75 2.00 29-71, 70.75 34. Foreign County Costs 35. Advance Costs 36. Service Costs 37. Notary Cert. 38. Mileage/Postage/Not Found 39. Total Costs 40. Costs Due or Refund 41. AFFIR si?bs ribed to before me this - - 'nature of 45. D E 4 d az.davot ME?2 2b J043 ' 1 De0.Sheriff q?1-00 '!NO RY ' 'ael , N Seat- . - p 46. Signature York 47 Q(- TE i James V Nangrngreen Notary Public County Sheriff York, York County, PA 66 WILLIAM M. HOSE 8*8x My Commission Expires Jan. 22, 2001 48, Signature of Foreign 49. DATE County Sheriff 50. 1 ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE 51. DATE RECEIVED 1. WHITE- Issuing Authority 2. PINK- C. CANARY-Sheriffs Office 4. BLUE-Sheriffs Office `` ?.EGEIyED" DFFIGE GF SHERIFF YORK, FA ° 00 fdOU 27 R[? 11 `46 COUNTY OF YORK OFFICE O-FTHE SHERIFF SERVI77 CE CALL _ 28 E(yST MARKET ST.; YORK PA 17401 _ SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN 1. PLAINTIFF/S/ 2 _ C2OdRTjJ1I fl €R Amy ©P,?r7.nS- tSS L? 3. DEFENDANT/S/ - 4. TYPE OF,WRIT OR COMPLAINT WRTT OF SUMMONS Keith -? SERE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. Keith A. Hooker 6. ADDRESS (STREET OR RFO BOX NUMBER, APT. NO., CITY, BORO, TWP., STATE AND ZIP CODE) AT 704 Ridge Rd, Lewisberry, PA 17339 7. INDICATE SERVICE: O PERSONAL 17 PERSON IN CHARGE V DEPUTIZEr. E;0Tl MAIL. ? 1ST CLASS MAIL ? POSTED - ? OTHER NOW l? rk0 2Q -1; SHERIFF OFC?7FC70U1TY, PA, do hereby deputize the sheriff of COUNTYto execute this?Nrit and make return thereof according to law. This deputization being made at the request and risk of the plaintiff. -SHERIFF OF -8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE OUNTY : - ' Cumber?-and Co. OUT OF 03UNTY CUMBERLAND ADVANCE FEE EM BY CUMBERLAND COUNTY SHERIFF NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN -Any deputy sheriff levying upon or attaching any property under within writ may leave Same without a watchman, in. custody of Whomever Is found'"M possession, after notifyrng person of levy or attachment; without liability on the part of such'deputy orthesheriffto any¢ia'inbff - - heFeinfor any loss, tiestnuction, or removal of any property before sheriffs sale thereof. - 9 TY E NAME an}dr?ADDRgESpS? oyfr ATTORNEY/ ORIGINATOR and SIGNATURE - 10 TELEPHONE NUMBER 1 i. DATE FILED 1?ENNIS $. ; SHEAFFER, ESQ.- Ill N. F[AONT 5T .r FO BOX $81, HARRISBURG, HA (17108 X389 (717) 234-4121 11/2110fl 12 SEND NQTICEOF-SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed. if notice is to be mailed) - - - CUMBERLM COUNTY SHERIFF r s. 43. I-acknowledge receipt of the writ - - _ - - - 74:' DATE REIVED- 15. Expiration/Hearing Date or complaint as indicated above. J. LUDWIG 11/27/0CE0 12/21/00 16. HOW SERVED: ? PERSONAL( ) RESIDENCE. - POSTED( )- POE ( ) SHERIFF'S OFFICE /` ( ) OTHER ( ) SEE REMARKS BELOW 17. ? I hereby certify and return a-NOT FOUND because I am unable to locate the individual, company, etc. named above. {See remarks below.) - 18 1NAME AND TITLE OF INDIVIDUAL SERVED / LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19.: 7te of ervice 20. Time of Service '21. ATTEMPTS Date Time- Miles Int. Date me Miles Int. -Date -Time -Miles -Int: Date. Time Miles Int. Date Time Miles Int. Date Time Miles Int. 3 " 22. REMARKS: ...<p ,.. .? w s P 23: Advance Costs - 24. Service: Costs 25. N/F - 26. Mileage 27. Postage 28. Sub Total 29. Pound 30. Notary - 31. Su_ 32. Tot. Cgsts 33. Costs Due or Refuntl Check No -.100.00 :S -;9' "q I 7c t' 70 34 Foreign County Costs ` 35, Advance Posts 36. Service Costs-- 37. Notary Cert. -' 38. Mileage/Postage/Not Found 39. Total Costs - 40. Costs Due or Refund 41 AFFIRMED and sub cribed t f 7 - b the - SO ANSWERS - - - s DECEMBER q2 day f o , o e ore me 00 43 20 R 44 gi Sign If p. S Sh heriff D TE j 45. -? ^ /NOT Tk Y P RY 46. Signature f York 47. DAATE - - - "" - - County Sheriff WILLIAM 14. HOSE f < '- «: - ?? td 8x 48. Signature of Foreign 49. DATE County Sheriff - k 50. 1 ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE - 51. DATE RECEIVED OF AUTHORIZED ISSUING AUTHORITY AND TITLE - 1. WHITE-Issuing Authority 2.PINK-Attorney 3.CANARY-Sheriffs Office 4. BLUE. Sheriffs Office AMY DEVINS, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-8209 0 C:) c o 0 KEITH A. ROCKER, CIVIL ACTION -LAW J v F T7 C::? Defendant JURY TRIAL DEMANDED z 57 , PRAECIPE ? TO THE PROTHONOTARY: cn K Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, NEALON & GOVER Rv J"WNI14k David J. Freed, Esquire Atty. I.D. 76622 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 TO THE PLAINTIFF: RULE 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. _(?-v -12. '-?" Prothonotary Of- David J. Freed, Esquire, NEALON & GOVER, P.C., 2411 North Front Street, Harrisburg, PA 17110 Dennis R. Sheaffer, Esquire, TUCKER, ARENSBERG & SWARTZ, 111 North Front Street, P.O. Box 889 Harrisburg, PA 17108-0889 a w AMY DEVINS, V. Plaintiff KEITH A. HOCKER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8209 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER By:--?'`- -? David J. Freed, Esquire Atty. I.D. #76622 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this 7th day of December, 2000, 1 hereby certify that I have served the foregoing Praecipe entering my appearance on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Dennis R. Sheaffer, Esquire TUCKER, ARENSBERG & SWARTZ 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 David J. Freed, Esquire AMY DEVINS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-8209 : CIVIL ACTION - LAW KEITH A. HOCKER, Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 NOTICIA Le ban demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en las paquinas siguientes, demanda y la notification. Usted debe presentar una apariencia escrita o en persona o per abogado y archivar en la torte enforma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la torte tomara medidas y puede entrar una Orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 TUCKER ARENSBERG & SWARTZ r By r Dennis R. 4D39r.82 Attorney I111 North Front Street P. O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 Attorneys for Plaintiff 2 _VO -61 AMY DEVINS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-8209 CIVIL ACTION - LAW KEITH A. HOCKER, Defendant JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, Amy Devins, by and through her attorneys, TUCKER ARENSBERG & SWARTZ, and brings this Complaint against Defendant Keith A. Hocker, and avers as follows: Plaintiff, Amy Devins, is an adult individual residing at 363 South Main Street, Marysville, Perry County, Pennsylvania 17053 (hereinafter known as 'Plaintiff'). 2. It is believed, and therefore averred, that Defendant Keith A. Hocker is an adult individual who resides at, 704 Ridge Road, Lewisberry, York County, Pennsylvania 17339 (hereinafter known as "Defendant"). 3. This Court has jurisdiction over this matter on the grounds that the facts and circumstances of the automobile accident giving rise to this action occurred on November 27, 1998, at a stop sign located at the on-ramp at Brandt Street to Interstate 83 northbound (hereinafter 183) in New Cumberland, Cumberland County, Pennsylvania. 4. At approximately 10:30 a.m. on November 27, 1998, Plaintiff was the owner and operator of a 1985 Audi Sedan. 5. At the aforesaid time and place, Plaintiffs vehicle was stopped at a stop sign located at the on-ramp at Brandt Street to 183 northbound. 6. At the aforesaid time and place, Defendant was the owner and driver of a 1989 Chevrolet Camero. Defendant was also travelling on the on-ramp to 183 northbound behind Plaintiffs vehicle. 7. At the aforesaid time and place, Defendant was operating his vehicle in an unsafe manner such that Defendant failed to stop and struck into the rear of Plaintiffs vehicle. 8. As a direct and proximate result of the aforesaid collision, Plaintiff suffered severe and permanent injuries. 9. The aforesaid accident was caused soley by the negligence, carelessness, and recklessness conduct of Defendant and was due in no part to the actions or inaction of Plaintiff. 10. Defendant was negligent, careless and reckless as follows: (a) Failing to have his vehicle under proper and adequate control at all times; (b) Failing to observe Plaintiffs vehicle on the roadway and apply his brakes and/or take other appropriate or evasive action to avoid the collision with Plaintiffs vehicle; (c) Failing to keep a reasonable lookout for stopped traffic located in front of him, so as to avoid a collision with Plaintiffs vehicle; (d) Operating his vehicle with careless disregard for the safety of other persons, including Plaintiff, in violation of the Pennsylvania Motor Vehicle Code: 75 Pa.C.S.A. § 3714; (e) Operating his vehicle in a manner in violation of the Pennsylvania Motor Vehicle Code: 75 Pa.C.S.A. §3310, by following too closely; (f) Failing to stop within an assured clear distance from Plaintiffs vehicle; (g) Failing to drive at a speed and in a manner that would allow him to stop within an assured clear distance ahead; and (h) Failing to operate his vehicle at a safe speed pursuant to the Pennsylvania Motor Vehicle Code: 75 Pa.C.S.A. §3361. 11. As a direct and proximate result of the aforesaid accident, Plaintiff suffered severe injuries that include, but are not limited to, the following: (a) Cervical, thoracic, lumbar musculoligament strain with chronic deconiditoning problem; (b) Induced premature labor; (c) Bilateral thoracic outlet syndrome; (d) Aggravation of pre-existing fibromyositis; (e) Myofascial pain with malignant fibromyositis; (f) Severe headaches with muscle spasms in the neck; (g) Anxiety and sleeping disorders; (h) Depression; (i) Bilateral hand and clavicular pain as well as bilateral feet numbness; 0) Aggravation of bilateral cervical rib condition; (k) Bilateral neurovascular compression syndrome at the thoracic outlet; and (1) Various other contusions and abrasions. 12. As a result of the injuries, Plaintiff has suffered and in the future will continue to suffer severe physical pain, mental anguish and suffering, humiliation, inconvenience, scarring, embarrassment and loss of life's pleasures. 13. As a further direct and proximate result of the aforesaid accident and related injuries, Plaintiff has and will continue to be limited in her normal and daily activities. 14. As a further direct and proximate result of the aforesaid accident and related injuries, Plaintiff has and will continue to suffer great physical nervous, mental and emotional distress. 15. As a further direct and proximate result of the aforesaid accident and related injuries, Plaintiff has and will continue to suffer impairment to her health, strength and vitality. 16. As a further direct and proximate result of the aforesaid accident and related injuries, Plaintiff has and will continue to be required to spend money for medicine, medical care, nursing, hospital and/or surgical attention, medical appliances and household care beyond that which she might otherwise recover. 17. As a further direct and proximate result of the aforesaid accident and related injuries, Plaintiff has and will continue to suffer loss of income and earning capacity beyond that which she may be otherwise entitled to recover. 18. As a further direct and proximate result of the aforesaid accident and related injuries, Plaintiff has and will continue to suffer other financial losses beyond that which she may otherwise be entitled to recover. WHEREFORE, Plaintiff demands judgment against Defendant, Keith A. Hocker in an amount in excess of the limits for mandatory arbitration, together with interest and costs of this proceeding and such other relief as this Honorable Court deems proper under the circumstances. Respectfully Submitted, TUCKER ARENSBERG & SWARTZ By: Dennis R. She er Attorney I.D. #39182 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 Dated: ATTORNEYS FOR PLAINTIFF 35640.1 VERIFICATION I, the undersigned, AMY DEVINS, do hereby certify that I am a PLAINTIFF in the foregoing action, and that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements made to this verification are subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. DATE: S D? AMY DE S 36244.1 CERTIFICATE OF SERVICE AND NOW, this *:?/day of February, 2001, I, Cathleen A. Kohr, for the firm of TUCKER ARENSBERG & SWARTZ, attorneys for Plaintiff, hereby certify that I have this day served a copy of the Complaint, by causing a copy of the same to be sent in the United States Mail, First Class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: David I Freed, Esquire NEALON & GOVER P.C. 2411 North Front Street Harrisburg, PA 17110 d"mL Cathleen A. Kohr F. ?? AMY DEVINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH A. HOCKER, Defendant NO. 00-8209 CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER TO THE COMPLAINT AND NOW, comes Defendant, Keith A. Hocker, by and through his attorneys, Nealon & Gover, P.C., and files the following Answer: 1. Admitted, upon information and belief. 2. Admitted. 3. Admitted. 4. Admitted, upon information and belief. 5. Admitted. 6. Admitted. 7. Admitted in part and denied in part. It is admitted that the vehicle operated by Defendant struck the rear of the vehicle operated by the Plaintiff. The remainder of this paragraph is denied pursuant to Pa. R.C.P. 1029(e). 8-18. These paragraphs contain conclusion of law to which no responsive pleading is required. To the extent that they are construed to allege facts, the same are denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, Defendant, Keith A. Hocker, respectfully requests that the Complaint against him to dismissed. Respectfully submitted, NEALON & GOVER By: David J. Freed, Esquire Atty. I.D. 76622 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this 24th day of February, 2001, 1 hereby certify that I have served the foregoing Answer to the Complaint on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Dennis R. Sheaffer, Esquire TUCKER, ARENSBERG & SWARTZ 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 -I _I-W 1 David J. Freed, Esquire VERIFICATION I, Keith A. Hocker, verify that the statements made in the foregoing Answer to the Complaint 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. KEITH A. HOCKER Dated: Z- 23 -o I CERTIFICATE OF SERVICE AND NOW, this 23rd day of February, 2001, 1 hereby certify that I have served the foregoing Answer to the Complaint on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Dennis R. Sheaffer, Esquire TUCKER, ARENSBERG & SWARTZ 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 David J. Freed, Esquire ' r AMY DEVINS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-8209 : CIVIL ACTION - LAW KEITH A. HOCKER, Defendant JURY TRIAL DEMANDED PLAINTIFF'S OBJECTIONS TO DEFENDANT'S INTERROGATORIES 9. Objection. This interrogatory asks for information that is beyond the scope of permissible discovery under the Pennsylvania Rules of Civil Procedure and will not tend to lead to any admissible information. TUCKER ARENSBERG & SWARTZ BY: Dennis R. eaffel Attorney I.D. #39182 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 DATED: ATTORNEYS FOR PLAINTIFF 38117.1 CERTIFICATE OF SERVICE AND NOW, this latday of March, 2001, I, Cathleen A. Kohr, for the firm of TUCKER ARENSBERG & SWARTZ, attorneys for Plaintiff, hereby certify that I have this day served a copy of Plaintiffs Objections to Defendant's Interrogatories, by causing a copy of the same to be sent in the United States Mail, First Class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: David J. Freed, Esquire NEALON & GOVER 2411 North Front Street Harrisburg, PA 17110 Cathleen A. Kohr AMY DEVINS, V. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA KEITH A. HOCKER, Defendant : NO. 00-8209 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED CERTIFICATE PREREOUISITE 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, Keith A. Hocker, 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. 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 of Intent to Serve the Subpoena. Respectfully submitted, NEALON & GOVER, P.C. By: k, A-Aff:bdi?? Brian N. ZuTli, Esquire Atty. I.D. #85948 2411 North Front Street Harrisburg, PA 17110 Date: 09/13/01 (717) 232-9900 AMY DEVINS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH A. HOCKER, Defendant NO. 00-8209 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant, Keith A. Hocker, 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. If no objection is made the Subpoenas may be served. Date: 08/20/01 Respectfully submitted, NEALON & GOVER, P.C. By: s Brian N. Zulli, Esquire Atty. I.D. #85948 2411 North Front Street Harrisburg, PA'-17110 (717) 232-9900 Attorney for Defendant, Keith A. Hocker AMY DEVINS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8209 CIVIL ACTION - LAW JURY TRIAL DEMANDED V. KEITH A. HOCKER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Jay J. Cho, M.D. 5124 East Trindle Road Mechanicsburg, PA 17055 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things to 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 Amy Faye Devins, Date of Birth 11/02/72 and Social Security Number 188-56-8066. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATED: on' -?y L PROTHONOTARY Seal of the Court <-? 2 AMY DEVINS, V. BY THE COURT: : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8209 KEITH A. HOCKER, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Thomas Becker, H, D.C. Becker Chiropractic 501 Market Street Lemoyne, PA 17043 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things to 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 Amy Faye Devins, Date of Birth 11102/72 and Social Security Number 188-56-8066. 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: DATED: a ?ppI Seal of the Court Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant PROTHONOTARY E. 1 AMY DEVINS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH A. HOCKER, Defendant NO. 00-8209 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: William B. Isms, M.D. 423 North 21st Street Camp Hill, PA 17011 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things to 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 Amy Faye Devins, Date of Birth 11102/72 and Social Security Number 188-56-8066. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATFD: LtD 3° 'An o Seal of the Court AMY DEVINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH A. HOCKER, Defendant NO. 00-8209 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Family Medicine Center of Camp Hill 4076 Market Street Camp Hill, PA 17011 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things to 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 Amy Faye Devins, Date of Birth 11/02/72 and Social Security Number 188-56-8066. 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: Brian N. ZuIU, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant DATED: A d, ?? ?3U? avU I BY THE COURT: Seal of the Court AMY DEVINS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8209 CIVIL ACTION - LAW JURY TRIAL DEMANDED V. KEITH A. HOCKER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Polyclinic Hospital 2601 North Third Street Harrisburg, PA 17105 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things to 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 Amy Faye Devins, Date of Birth 11/02/72 and Social Security Number 188-56-8066. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATED: A _[ Of 4061 PROTHONOTARY Seal of the Court AMY DEVINS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-8209 KEITH A. HOCKER, : CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: flealthsouth Rehab $03 Bridge Street New Cumberland, PA 17070 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things to 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 Amy Faye Devins, Date of Birth 11/02/72 and Social Security Number 188-56-8066. 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 parry 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: Brian N. Zulli, Esquire NEALON & GOVER P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATED: ?r aprj/ Seal of the Court P AMY DEVINS, Plaintiff V. KEITH A. HOCKER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8209 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Holyspirit Hospital 503 North 21st Street Camp Hill, PA 17011 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things to 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 Amy Faye Devins, Date of Birth 11/02/72 and Social Security Number 188-56-8066. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATED: _JU Seal of the Court AMY DEVINS, V. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8209 KEITH A. HOCKER, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Harrisburg Hospital 111 South Front Street Harrisburg, PA 17101 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things to 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 Amy Faye Devins, Date of Birth 11102/72 and Social Security Number 188-56-8066. 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: Brian N. Zulli, Esquire NEALON & COVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATED: L'9" 01 oZG151 Seal of the Court r AMY DEVINS, V. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8209 KEITH A. HOCKER, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Orthopedic Surgeons of Central PA 99 November Drive Camp Hill, PA 17011 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things to 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 Amy Faye Devins, Date of Birth 11/02/72 and Social Security Number 188-56-8066. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATED: or._ ?D aco Seal of the Court ?e. AMY DEVINS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-8209 KEITH A. HOCKE11, : CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Allstate Insurance Company 6345 Flank Drive, Suite 1000 Harrisburg, PA 17112 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things to the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110: All documents including but not limited to, statements, photographs, medical records, medical bills, peer review, reports or other documents pertaining to a claim made by Amy Faye Devins, Date of Birth 11102/72 and Social Security Number 188-56-8066 as a result of an automobile accident that occurred on November 27, 1998. It is believed that the Claim No. is 1553246321 3K7. 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: Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATED: A/ ,'Z00/ Seal of the Court PROTHONOTARY AMY DEVINS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8209 CIVIL ACTION - LAW JURY TRIAL DEMANDED V. KEITH A. HOCKER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Keystone Health Plan 300 Corporate Center Drive Camp Hill, PA 17011 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things to the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110: Entire personnel file, including but not limited to applications for employment, correspondence, memorandum, health records, workers compensation records, payroll records or other documents pertaining to Amy Faye Devins, Date of Birth 11102/72 and Social Security Number 188-56-8066. 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: Brian N. Zuni, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: J DATED: A ?Q aU,, PROTHONOTARY Seal of the Court AMY DEVINS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-8209 KEITH A. HOCKER, : CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Capital Blue Cross 2500 Elmerton Avenue Harrisburg, PA 17110 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things to the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110: Entire personnel file, including but not limited to applications for employment, correspondence, memorandum, health records, workers compensation records, payroll records or other documents pertaining to' Amy Faye Devins, Date of Birth 11/02/72 and Social Security Number 188-56-8066. 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: DATED: ~? Ur 0 / Seal of the Court Brian N. Zulli, Esquire NEALON & GOVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: AMY DEVINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH A. HOCKER, Defendant : NO. 00-8209 CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Restart Temps 3820 Market Street Camp Hill, PA 17011 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things to the offices of Nealon & Gover, P.C., 2411 North Front Street, Harrisburg, Pennsylvania 17110: Entire personnel file, including but not limited to applications for employment, correspondence, memorandum, health records, workers compensation records, payroll records or other documents pertaining to Amy Faye Devins, Date of Birth 11/02/72 and Social Security Number 188-56-8066. 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: Brian N. Zulll, Esquire NEALON & COVER, P.C. 2411 North Front Street Harrisburg, PA 17110 717-232-9900 Attorney for Defendant BY THE COURT: DATED: .t ?JOf oAGU J Sea] of the Court CERTIFICATE OF SERVICE AND NOW, this 13th day of September, 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: Dennis R. Sheaffer, Esquire TUCKER, ARENSBERG & SWARTZ 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 r Bnan N. Zulli, Esquire CG, f? l c ; C -U 1 ? CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: AMY FAYE DEVINS -VS- HOCKER TERM, CASE NO: 00-8209 As a prerequisite to service of a subpoena for documents and to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI certifies that i G C F f-n T W y?rs ua at `L 0 W Cn) K (1) A notice of intent to serve the subpoena with a copy of the subpoena 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 subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, 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: 12/26/2001 COURT OF COMMON PLEAS RCS? own behalf / o?f?{?, L• gh4li.'ZULLI, SSE Q. O•_ Attorney for DEFENDANT DE11-300213 7 8 4 4 0- L 0 1 i P E NN S YLVAN ZA C OMN1O NWEAL T H OE;' COUNT Y O F CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS AMY FAYE DEVINS TERM, -VS- CASE NO: 00-8209 HOCKER AND ANN BOGDAN, MD TO: DENNIS R. SHEAFFER, ESQUIRE MEDICAL MCS on behalf of BRIAN N. ZULLI, ESQ. 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: 12(0312001 CC: BRIAN N. ZULLI, ESQ. - 00-480 Any questions regarding this matter, contact MCS on behalf of BRIAN N. ZULLI, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-172082 7 8 4 4 0- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAIND AMY FAYE DEVINS VS HOCKER File No. 00-8209 SUBPOENA TO PRODUCE DOC'UMMNTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009-22) TO: CUSTODIAN OF RECORDS FOR: ANN M. BOGDAN, M.D. (%ame of Person or saes) Within rwe.-y (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SF.F. ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800, PHILA..,PA 19103 (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. It you fail to roduce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving tnas subpoena may seek a court order compelling you to comply with it. THIS SL SPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NA.titH BRIAN N. ZULLI, ESQ. ADDRESS: 2411 NORTH. FRONT ST. HARRISBURG, PA 17110 TELEPHONE 215-246-0900 SUPREME COURT ID g: ATTORNEY FOR: DEFENDANT n 1 BY CRT: DATE /(?CX? I Ptethsnesrary Gv vision /-?- ry Seal of the Court (°-ff. 7/977) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ANN BOGDAN, MD 9 FLOWERS DRIVE MECHANICSBURG, PA 17055 RE: 78440 AMY FAYE DEVINS A/K/A AMY Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : AMY FAYE DEVINS A/K/A AMY BRUDOWSKY, MARYSVILLE, PA 17053 Social Security #: 188-56-8066 Date of Birth: 11-02-1972 SU10-342382 78440-1-03 ?r PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: AMY FAYE DEVINS -VS- HOCKER COURT OF COMMON PLEAS TERM, CASE NO: 00-8209 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI, ESQ. 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 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 subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, 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: 01/16/2002 0 MCSn beYLIES(JJ BAN N. f IAN Attorney for DEFENDANT DEII-304930 8 0 5 0 6- 1-0 1 C01-24014WEALTH OF PENNSYLVAN=A COUNTY OE' CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS AMY FAYE DEVINS -VS- HOCKER A DR. KATHERINE GALLAGHER MEDICAL TO: DENNIS R. SHHAFFER, ESQUIRE TERM, CASE NO: 00-8209 MCS on behalf of BRIAN N. ZULLI, ESQ. intends to serve a subpoena i4p4tical 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: 12/2712001 MCS on behalf of BRIAN N. ZULLI, ESQ. Attorney for DEFENDANT CC: BRIAN N. ZULLI, ESQ. - 00480 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-174178 8 0 5 0 6- C O 1 J COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERL?\eD DEVINS VS File No. 00-8209 HOCKER TO: CUSTODIAN OF RECORDS FOR: KATHERINE GALLAGHER, MD. (tiane of Person or -Emery) Within rwe-.-Y (2M days after service of this subpoena, you are ordered by the court to produce the following documents or chinas: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (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. 11 you fail to roduce the documents or things required by this subpoena, within twenty (20) days after its service, the parry serving this subpoena may seek a court order compelling you to comply with 1L THIS SLBPOLNA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NA.ti(E BRIAN N. .Lit.. . .SO. ADDRESS: 2411 NORTH FRONT ST. HARRISBURG, PA 17110 TELEPHON=• 215-246-0900 SUPREME COURT IV •t ATTORNEY FOR DEFENDANT ?aooa ?ou ?E? ?? t7 Ptattseneeasy it Division DATE: YR Seal of the Court (T-ff. 7/97) i EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. KATHERINE GALLAGHER 4076 MARKET STREET CAMP HILL, PA 17011 RE: 80506 AMY FAYE BRUDOWSKY DEVINS Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : AMY FAYE BRUDOWSKY DEVINS 363 S. MAIN STREET, MARYSVILLE, PA 17053 Social Security A 188-56-8066 Date of Birth: 11-02-1972 SU10-346552 8 0 5 0 6- 1-0 1 < cz:? _7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: AMY FAY DEVINS BRUDOWSKY -VS- KEITH HOCKER COURT OF COMMON PLEAS TERM, CASE NO: 00-8209 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI, ESQ. 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 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 subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, 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. /?R S onha of DATE: 07/0512002 IAN N I. ESQ Attorney for DEFENDANT DE11-343740 9 7 1 2 9- L 0 1 COMMONWEALTH 0V P E NN S YLVAN ZA COUNTY O V CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS AMY FAY DEVINS BRUDOWSKY -VS- KEITH HOCKER TERM, CASE NO: 00-8209 COMMUNITY GENERAL HOSPITAL MEDICAL RECORDS JAMES L. WHARTON, D.C. MEDICAL RECORDS LAWRENCE G. COB, D.O. MEDICAL RECORDS TO: DENNIS R. SHEAF FER, ESQUIRE MCS on behalf of BRIAN N. ZULLI, ESQ. 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: 06/1412002 CC: BRIAN N. ZULLI, ESQ. - 00-480 Any questions regarding this matter, contact MCS on behalf of BRIAN N. ZULLI, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-190139 9 7 1 2 9- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANY FAY DEVINS VS HOCKER File No. 00-8209 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: COMMUNITY GENERAL OSTEPATHIC GEN.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: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST, 11800, PHILA.,PA 19103 (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: BRIAN ZULLI, ESQ. ADDRESS: 2411 NORTH FRONT ST. HARRISBURG, PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: JU-0 F 1 r36 D. Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMUNITY GENERAL HOSPITAL 4300 LONDONDERRY RD. P.O. BOX 3000 HARRISBURG, PA 17105 RE: 97129 AMY FAY DEVINS BRUDOWSKY Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject : AMY FAY DEVINS BRUDOWSKY 363 SOUTH MAIN STREET, MARYSVILLE, PA 17053 Social Security #: 188-56-8066 Date of Birth: 11-02-1972 SU10-380482 9 7 1 2 9- L 0-L PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: AMY FAY DEVINS BRUDOWSKY -VS- COURT OF COMMON PLEAS TERM, CASE NO: 00-8209 KEITH HOCKER As a prerequisite to service of a subpoena for documents and things pursuant to. Rule 4009.22 MCS on behalf of BRIAN N. ZULLI, ESQ. 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 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 subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, 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: 07/0512002 BRIAN N. ZULLI, ESQ. Attorney for DEFENDANT DE11-343741 973-29-1-02- COMMONWEALTH OP P E NN S YLVAN =A COUNTY OP CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS AMY FAY DEVINS BRUDOWSKY -VS- KEITH HOCKER TERM, CASE NO: 00-8209 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 COMMUNITY GENERAL HOSPITAL MEDICAL RECORDS JAMES L. WHARTON, D.C. MEDICAL RECORDS LAWRENCE G. COX, D.O. MEDICAL RECORDS TO: DENNIS R. SHEAFFER, ESQUIRE MCS on behalf of BRIAN N. ZULLI, ESQ. 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: 06/1412002 CC: BRIAN N. ZULLI, ESQ. - 00-480 Any questions regarding this matter, contact MCS on behalf of BRIAN N. ZULLI, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-190139 9 7 1 2 9- C 0 1 I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AMY FAY DEVINS VS HOCKER File No. 00-8209 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: JAMES L. WHARTON, D.C. (Name of Penon or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST, #800, PHILA.,PA 19103 (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: BRIAN ZULLI. ES ADDRESS: 2411 NORTH FRONT ST. HARRISBURG, PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: t 16) t &C,61,. Seal of the Court (Eff.7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JAMES L. WHARTON, D.C. 5257 E. SIMPSON FERRY RD. MECHANICSBURG, PA 17055 RE: 97129 AMY FAY DEVINS BRUDOWSKY Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : AMY FAY DEVINS BRUDOWSKY 363 SOUTH MAIN STREET, MARYSVILLE, PA 17053 Social Security A 188-56-8066 Date of Birth: 11-02-1972 SU10-380484 9 7 1 2 9- 1- 0 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANY FAY DEVINS BRUDOWSKY TERM, -VS- CASE NO: 00-8209 KEITH HOCKER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI, ESQ. 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 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 subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, 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: 07/05/2002 BRIAN N. ZULLI, ESQ. Attorney for DEFENDANT DE11-343742 973-2-9-1-03 COINIIKONWHALTH OF PENNSYLVAN2A COUNTY OF CTJMBERLANV IN THE MATTER OF: COURT OF COMMON PLEAS AMY FAY DEVINS HUDOWSKY _VS_ KEITH HOCKER COMMUNITY GENERAL HOSPITAL JAMS L. WHARTON, D.C. LAWRENCE G. COX, D.O. TO: DENNIS R. SHEAFFER, ESQUIRE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TERM, CASE NO: 00-8209 MCS on behalf of BRIAN N. ZULLI, ESQ. 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: 06/14/2002 CC: BRIAN N. ZULLI, ESQ. - 00-480 Any questions regarding this matter, contact MCS on behalf of BRIAN N. ZULLI, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-190139 9 7 1 2 9- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AMY FAY DEVINS VS HOCKER Fite No. 00-8209 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: LAWRENCE G. COX, 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: SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST, #800, PHILA.,PA 19103 (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: BRIAN ZULLI, ES ADDRESS: 2411 NORTH FRONT ST. HARRISBURG, PA 17110 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: J/ /17 . =,l- Seal of the Court m (Eff.7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: LAWRENCE G. COX, D.O. 522 LOCUST ROAD NEW CUMBERLAND, PA 17070 RE: 97129 AMY FAY DEVINS BRUDOWSKY Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : AMY FAY DEVINS BRUDOWSKY 363 SOUTH MAIN STREET, MARYSVILLE, PA 17053 Social Security A 188-56-8066 Date of Birth: 11-02-1972 SU10-380486 9 71.2 9- 1-0 3 v" CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: AMY DEVINS -VS- KEITH A. HOCKER COURT OF COMMON PLEAS TERM, CASE NO: 00-8209 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. 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 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 subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, 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: 04/11/2005 ,?'[v1C on behalf V MI AEL ON, ES . Attorney for DEFENDANT DE11-554449 85785-L 03- COMMONWEALTH OP P E NN S Y L VANS A COUNTY OP CUMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS AMY DEVINS -VS- KEITH A. HOCKER SERVE A DR. STEPHEN POWERS WILLIAMS B. IAMS, M.D MEDICAL RECORDS & %RAYS MEDICAL RECORDS & KRAYS TERM, CASE NO: 00-8209 T0: DENNIS R_ SHEAFFER, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. 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: 03/22/2005 CCs MICHAEL FERGUSON, ESQ. - 00-480 PATRICIA HOFFMAN - 1553281666 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-295964 8 5 7 8 5- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AMY DEVINS vs. KEITH A. HOCKER File No. 00-8209 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. STEPHEN POWERS (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: **** SEE ATTACHED RIDER **** at The MCS Groun. Inc 1601 Market Street. Suite 800 Philadelphia PA 19103 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: MICHAEL FERGUSON, ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant }fp APR Y ? 2000 aG?05' Date: _ 411(Ul 1-7 Seal of the Court BY THE CO Prothonot ry/Clerk ivisi .L ?i Deputy 85785-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. STEPHEN POWERS 4310 LONDONDERRY RD. HARRISBURG, PA 17109 RE: 85785 AMY DEVINS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, han dwritten notes, history and physical reports, medic ation/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to Dates Requested: up to and including the present. Subject: AMY DEVINS 363 SOUTH MAIN STREET, MARYSVILLE, PA 17053 Social Security #: 188-56-8066 Date of Birth: 11-02-1972 SU10-554594 8578-9-L 03- I CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: AMY DEVINS -VS- KEITH A. HOCKER COURT OF COMMON PLEAS TERM, CASE NO: 00-8209 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. 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 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 subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, 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: 04/11/2005 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-554450 85785-L 02 C O M M O NW E A L T H op P E NN S W L VANS A COUNTY OP CUMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS AMY DEVINS -VS- KEITH A. HOCKER CE OF INTENT TO SERVE A TERM, CASE NO: 00-8209 PRODUCE DOCUDEEM"S AND DR. STEPHEN POWERS MEDICAL RECORDS 6 KRAYS WILLIA14S B. IAMS, M.D. MEDICAL RECORDS 6 BRAYS TO: DENNIS R. SHEAFFER, ESQUIRE, PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. 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: 03/22/2005 CC: MICHAEL FERGUSON, ESQ. - 00-480 PATRICIA HOFFMAN - 1553281666 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGDSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-295964 8 5 7 8 5- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AMY DEVINS VS. KEITH A. HOCKER File No. 00-8209 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for WILLIAMS B. JAMS, 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: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street_ Suite 800. Philadelphia. PA 19103 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: MICHAEL FERGUSON, ESO. ADDRESS: 2411 N. FRONT ST. HARWSBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE APR l 1 2005 ?n Deputy Date: ??11??? /? d it?05 Seal of the Court 85785-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WILLIAMS B. IAMS, M.D. CARDIOVASCULAR SURG. INST 423 N. 21ST ST CAMP HILL, PA 17011 RE: 85785 AMY DEVINS Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING DIAGNOSTIC FILMS Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : AMY DEVINS 363 SOUTH MAIN STREET, MARYSVILLE, PA 17053 Social Security #: 188-56-8066 Date of Birth: 11-02-1972 SU10-554596 8 5 7 8 5- 1, 0 2 cs C ^? o ? er+ J3 ? IJ W 0{a Cat co ?? came: ma?n?anR= .. -su+a??z i y .:.,.:.x? ,ar??nrers8e3+??a?wn?rre, si.swsr#!?a4lw. r w ?r : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA AMY DEVINS, V. KEITH A. HOCKER, Defendant NO. 00-8209 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendant, Keith A. Hocker, with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY By: Y Michael S. Ferguson, Esquire Attorney I.D. No. 83882 2411 North Front St. Harrisburg, PA 17110 Date: IU 6 (717) 232-9900 1' . CERTIFICATE OF SERVICE AND NOW, this day of October, 2006, 1 hereby certify that I have served the foregoing Withdrawal of Appearance on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Dennis R. Sheaffer, Esquire TUCKER, ARENSBERG, P.C. 111 North Front Street Harrisburg, PA 17101 Michael S. Ferguson, Esquire _, C ? -n fir' f D : 2 _ W ? r- CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Keith A. Hocker, with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY By: Jenni a len, Esquire Attorn I.D. No. 84311 2411 o h Front St. Harrisburg, PA 17110 Date: Aj(_k? (717) 232-9900 AMY DEVINS, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8209 KEITH A. HOCKER, Defendant r . CERTIFICATE OF SERVICE AND NOW, this -lam day of October, 2006, 1 hereby certify that I have served the foregoing Entry of Appearance on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Dennis R. Sheaffer, Esquire TUCKER, ARENSBERG, P.C. 111 North Front Street Harrisburg, PA 17101 0 Q l 4. C _. W vfn co 7? -C AS OF 8'-- ado? CASE# x.660 - e;?-10q HAS BEEN SCANNED. ALL EARLIER FILINGS TO THIS CASE HAVE BEEN MICROFILMED. PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case: (Check One) (X ) for JURY trial at the next term of civil court. ( ) for trial without a jury. (CAPTION OF CASE, entire caption must be state in full) (check one) (X) Civil Action - Law ( ) Appeal from Arbitration (other) AMY DEVINS, Vs. KEITH A. HOCKER, The trial list will be called on May 22, 2007 and Trials commence on June 18, 2007 Pretrials will be held on May 30, 2007 (Briefs are due 5 days pretrial.) (The party listing this case for trial shall provide forthwith a copy of the Praecipe to all counsel, pursuant to Local Rule 214.1.) No. 00-8209 Indicate the attorney who will try case for the party who files this Praecipe: Jenni Henley Allen, Esquire Indicate trial counsel for other parties if known: Dennis R. Sheaffer, Esquire This case is ready for trial. Date: Al I S?l O Plaintiff(s) Defendant(s) NEALON"VIER & PERRY By: Pen i Henley Allen, Esquire k'kttorpey I.D. No. 84311 ey for Keith A. Hocker 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 _ -V M .` CO t=> -ra -7j CA3 ;- m _? cxl AMY DEVINS, Plaintiff V. KEITH A. HOCKER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-8209 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE TO REMOVE TO THE PROTHONOTARY: PLEASE REMOVE THE ABOVE MATTER FROM THE JUNE TERM OF COURT BY AGREEMENT OF ALL COUNSEL. Respectfully submitted, NEALON GOVER & PERRY Matthew R. Gover, Esquire Attorney I.D. No. 47593 2411 North Front Street Harrisburg, PA 17110 Date: ?/?'i L. r' 0 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this L 4 day of April, 2007, 1 hereby certify that I have served the foregoing Praecipe to Remove Case From Trial List on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Dennis R. Sheaffer, Esquire TUCKER ARENSBERG, P.C. 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 A9141j, atthew R. Gover, Esquire C`j r_- r . PRAECIPE FOR LISTING CASE FOR TRIAL -(Must be typewritten and submitted in dupllcate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: ® for JURY trial at the next term of civil court. ? for trial without a jury. CAPTION OF CASE (entire caption must be stated in full) AMY DEVINS, KEITH A. HOCKER, VS. (check one) ® Civil Action - Law ? Appeal from arbitration (other) The trial list will be called onMarch 17, 2009 and Trials commence on Apr i 1 13, 2009 VS. (Plaintiff) (Defendant) Pretrials willbe held on March 25, 20 0 9 (Briefs are due S days before pretrials No. 00-8209 Term Indicate the attorney who will try case for the party who files this praecipe: Dennis R. Sheaffer, Esquire Indicate trial counsel for other parties if known: Casey Shore, Esquire =e2r?r be g, P. C. This case is ready for trial. Signed: Print Name: Den is R. Shea f f er NO. 39182 Date.February 12, 2009 Attorney for: Plaintiff Ill or ron reet Harrisburg, PA 17101 (717) 234-4121 (717) 232-6802 4 ? l ? "7 v Q'I z a( r 1 n 1 #10 AMY DEVINS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KEITH A. HOCKER, Defendant NO. 00-8209 CIVIL TERM PRETRIAL CONFERENCE AND NOW, this 25th day of March, 2009, before Edgar B. Bayley, Judge, present for the plaintiff was Dennis R. Sheaffer, Esquire, and for the defendant, Casey G. Shore, Esquire. Plaintiff and defendant were involved in an automobile accident on November 27, 1998. Defendant rear ended the plaintiff and liability is admitted. Plaintiff incurred injuries to the neck, shoulders and back which she claims resulted in bilateral thoracic outlet syndrome. She has undergone three separate surgeries. She seeks general damages and some lost wages. It is estimated that the trial will last for two days. Dennis R. Sheaffer, Esquire For Plaintiff Casey G. Shore, Esquire For Defendant prs zr- CL c t N r,i" AMY DEVINS, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH A. HOCKER, DEFENDANT NO. 00-8209 CIVIL ORDER OF COURT AND NOW this 8th day of April, 2009, it appearing that this case has now been assigned to Judge Ebert for jury trial starting the week of April 13, 2009, IT IS HEREBY ORDERED AND DIRECTED that Counsel shall file with the Court by the close of business on Thursday, April 9, 2009, the following: 1. A list of the numbered standard jury instructions the party is requesting. If a party is proposing a unique jury instruction or requesting significant modification of a standard instruction, it shall provide the full text of the proposed instruction to the Court. 2. The parties will provide a proposed verdict slip to the Court for review. By the Court, N 71 -Qw? I 'V M. L. Ebert, Jr., J. Z 'Dennis R. Sheaffer, Esquire For Plaintiff XCasey G. Shore, Esquire For Defendant bas eo i 'es m L I :0I WV 6-88V6901 AdVJ ?"4u;-f :JJ 3 3Hl ?O 3J# ?A AMY DEVINS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-8209 CIVIL ACTION - LAW KEITH A. HOCKER, Defendant JURY TRIAL DEMANDED PLAINTIFF'S MOTION FOR DELAY DAMAGES AND NOW, comes the Plaintiff, Amy Devins, by and through her attorneys, Tucker Arensberg, P.C., and moves this Honorable Court, pursuant to Pa.R.C.P. 238 for an award of delay damages, and in support thereof alleges as follows: 1. Plaintiffs cause of action accrued as a result of a motor vehicle accident which occurred on November 27, 1998. 2. Plaintiff instituted suit in this matter on November 21, 2000. 3. Plaintiff served original process on Defendant on November 29, 2000. (See attached Affidavit of Return of Service from York County Sheriffs Department marked Exhibit "A" and incorporated herein by reference). 4. Plaintiff is entitled to damages for delay from one year of the service of original process up to the date of the verdict, which was November 29, 2001, through April 14, 2009. 5. On April 14, 2009, Plaintiff received a verdict after trial by jury in the amount of Thirty-Four Thousand and Twenty-Seven and 52/100 ($34,027.52) Dollars. 6. Plaintiff is entitled to delay damages from November 29, 2001, until April 14, 2009, calculated as follows: 16 Date Days/Year Annual Percentage Delay Rate/ 9-1/4% Damages 11/29/01 -01/01/02 138. days 10-1/2% $1,350.84 01/02/02 - 01 /01 /03 1 year 5-3/4% $1,956.58 01/02/03 - 01 /01 /04 1 year 5-1/4% $1,786.44 01/02/04 - 01/02/05 1 year 5 % $1,701.38 01/03/05 - 01/02/06 1 year 6-1/4% $2,126.72 01/03/06 - 01/01/07 1 year 8-1/4% $2,807.27 01/02/07 - 01 /01 /08 1 year 9-1/4% $3,147.55 01/02/08 - 01 /01 /09 1 year 8-1/4% $2,807.27 01/02/09 - 04/14/09 103 days 4-1/4% 408.10 Total $18,092.15 7. The last, and largest, written offer of settlement that Defendant made to Plaintiff, Amy Devins, was on February 2, 1999, in the amount of Six Hundred ($600.00) Dollars. 8. Plaintiff is entitled to a full amount of delay damages set forth in Paragraph 6 above, as the verdict was in excess of 125% of Defendant's written offer of settlement, and the Plaintiff did not cause a delay of the trial. WHEREFORE, Plaintiff, Amy Devins, respectfully request this Honorable Court to award delay damages to her in the amount of Eighteen Thousand Ninety-Two and 15/100 ($18,092.15) Dollars for a total judgment of Fifty-Two Thousand One Hundred and Nineteen and 67/100 ($52,119.67) Dollars. Respectfully submitted, TUCKER ARENSBERG, P.C. JZ-1,04- By: Dennis R. 46eaffe Attorney I. . #39182 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 Dated: April 17, 2009 Attorney for Plaintiff 107035 EXHIBIT "A" SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-08209 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEVINS AMY VS HOCKER KEITH A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: but was unable to locate Him deputized the sheriff of YORK serve the within WRIT OF SUMMONS On December 6th , 2000 this office was in receipt of the attached return from YORK . Sheriff's Costs: So ans s• Docketing 18.00 Out of County 9.00 Surcharge 10.00 It. Thomas-Kline DEP. YORK CO 29.75 Sheriff of Cumberland County 12/06/2000 TUCKER, ARENSBERG & SWARTZ Sworn and subscribed to before me this day of A.D. in his bailiwick. He therefore County, Pennsylvania, to Prothonotary COUNTY OF YORK OFFICE OF THE SHERIFF s(7117)771 9 OIL 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINE 1. THRU 12 DO NOT DETAC14 ANY COPIES 1. PLAINTIFF/S/ 2' GDI1RTl1U F Amy De- i.n s 4. TYPE OF WRIT OR COMPLAINT 3. DEFENDANT/S/ 147R'TT OT SUMMONS Kej tHnr-ker 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. Ke;i.th A. Rocker 8. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT. NO., CITY, BORO, TWP., STATE AND ZIP CODE) AT 704 Ridge Rd, r?ewi.sberrv, PA 17139 7. INDICATE SERVICE: O PERSONAL O ,PERSON IN CHARGE I? DEPUTIZE QEAj. 01S CLASS MAIL fP, „ TED U OTHER 20 I, SHERIFF OF h ?e the sheriff of NOW ..1/22/00 V or. ic COUNTY to ex e t t attdl_mak retur--n thereof according .,, to law. This deputization being made at the request and risk of the plaintiff. SHERIFF OFgR*feoUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Cumberland. Co. OUT OF COUNTY CUMBERLAND ADVANCE FEE PAID BY CUMBERLAND COUNTY SHERIFF NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. TYPP rVO $?yQtg?QRN IGINATOR and SIGNATURE 10. TELEPHONE NUMBER r1j DAED U ? K. r lrr 'C:ki, EST 111 N. FRONT ST., PO BOX 889, HARRISBURG, PA 17108-0889 (717)234-4121 /21/00 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). CUMBERLAND COUNTY SHERIFF In 13. 1 acknowledge receipt of the writ 14. DATE RECEIVED 15. Ex I ation/Hearing Date or complaint as indicated above. J. LUDWIG 11/27/00 12/000 18. HOW SERVED: PERSONAL( ) RESIDENC POSTED( ) POE( ) SHERIFFS OFFICE ( ) OTHER( ) SEE REMARKS BELOW 17. 0 1 hereby i certify and return a NOT FOUND because I am unable to locate the individual, company, etc. named above. (See remarks below.) 1 E AND TITLE OF INDIVIDUAL SER D 1 LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Defendant) 19. Dpto of ervice 20. Time of Service 21. ATTEMPTS Oate Time MMiileess Int. Date Time Miles Int. Date Time Miles Int. Date Time Miles Int Date Time Miles Int Date TInt. v V) 23. Advance Costs 124. Service Costs 25. N/F 28. Mileage 100.00 ,00 9.75 a ? 34. Foreign County Costa 35. Advance Costs 36. Service Ck 28. 37. Notary Cert. 38. 7 (1?415?/DO, 30. Notary 31. Surchg. 32. Tot. Costs 33. Costs Du Retun Check Nc 39. Total Costs 140. Costs Due or Refund 41. of ? to before ZO 0? 43 j Dep?Sh nM 45.0 E p d 42. tlaF "' / NO RY 48 Signature of York 0or 47. TE Notarial Sear Q'p-1-00 James V. Vangreen, Notary Public Coun Sheriff York, York County, PA WILL AM M. HOSE My Commission Expires Jan. 22., 2001 48. Signature of foreign 49. DATE County Sheriff 50. 1 ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE 51, DATE RECEIVED OF AUTHORIZED ISSUING AUTHORITY AND TITLE CERTIFICATE OF SERVICE AND NOW, this _?. day of , 2009, PAU4INA PATTI THOMAS, for the firm of TUCKER ARENSBERG, P.C., attorneys for Plaintiff,' hereby certify that I have this day served the within document by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Casey Shore, Esquire Gover, Perry & Shore 2411 North Front Street Harrisburg, PA 17110 A PATTI THOMAS OF THE P: H(' OTARY 2909 APR 17 PH E2: 15 AMY DEVINS, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KEITH A. HOCKER, DEFENDANT NO. 00-8209 CIVIL VERDICT SLIP 1. Do you find the Defendant, Keith A. Hocker, was negligent? Yes ,X No 2. Was the Defendant's negligent conduct a factual cause in bringing about harm or injury to the Plaintiff? Yes No 3. State the amount of damages sustained by the Plaintiff. Insert a figure, if any, for each category below. A. Economic Damages: B. Non-Economic Damages: TOTAL DAMAGES: f % Date $ ZW 000.00 $ 34,6 z-7, 5 Foreperson A. I ran t /-? m AMY DEVINS ---- V S --- KEITH A. HOCKER UR In the Court of Commons Pleas of Cumberland County, PA., Docket No. 2000-8209 Judge: EBERT Attorney: D e n n+5 S hec,4c, f" PI" Attorney: C a s e y S kor` fur --D a H Date: 13 _ d l ORS No. Juror # NAMES OF JURORS CALLED CAUSE P 'D 1 110INNINIRMEN11 APR13-320 HOSFELT, PAMELA M 2 IN111111I1rIN11?NNN1 x 3 INI?N?INN?N?1NIbI1N APR13-238 WEAVER, GARY L rJ I?NNMNNIINUMNNIMAI APR13-143 MOORE, W Fro--k 6 INNNNNNINNINNI?I?I1N APR13-123 EHRMAN, CRAIG F 7 IN1uINNNNI?N1 APR13-330 RILAND, BETH A 9 IN111NN1?III??INNN1 APR13-317 JURIC, DANSEN 10 INUIIN1ONNMNNINNN APR13-112 SCHAEFFER,JOSEPH J 11 10110#10101111111 APR13-202 ' ,DUMAS, ELLIS R 13 iN1NNN11NNwnIN11NN1 APR13-243 SHELLER, JOSHUA M pI 'Ni _ pZ 1 CARDNER,AIJCRR F 18 INIINNNmNm1NNNoun APR13-165 CHANCE, HENRY L 19 11101NNONN10121IU APR13-339 STAKE, MARTHA K 20 III of uNi1NNUINNINN m APR13-260 CONTINO, JANICE M P? 1122 III1uNNNNUNNNNNNNuNIN1 APR13-130 TRIONE, NICHOLAS AMY DEVINS --- V S -- KEITH A. HOCKER UR In the Court of Commons Pleas of Cumberland County, PA., Docket No. 2000-8209 Judge: EBERT Attorney: Attorney: Date: ORS No. Juror # NAMES OF JURORS CALLED CAUSE P D 23 ImmNNmNNIomn APR13-81 BEAR, JESSICA L 24 immoNNmove APR13-60 SHOOK, KEVIN M 25 INNN80088II111 APR13-234 LEHMAN, KETHA M 26 INNNINNoNNnwon APR13-308 MARTIN, DOLORES J 27 INNNNNNNIN11mmon APR13-18 FRAZIER, ROBYN V 28 i1no mnNNNNlN u APR13-6 WEEDON, TUNISIA MICHELL 29 InNIIinsiminvNN APR13-198 HARTMAN, GAYLE E 30 Im(IMNImmIII mm APR13-273 SMITH, SHARON L 31 imanoNN min APR13-68 YENTZER„ JR WILLIAM F 32 INNNOMMENNNN APR13-264 SWART, PATRICIA A 33 34 35 36 37 38 39 40 41 42 43 44 AMY DEVINS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-8209 CIVIL ACTION - LAW KEITH A. HOCKER, Defendant JURY TRIAL DEMANDED PLAINTIFF'S AMENDED MOTION FOR DELAY DAMAGES AND NOW, comes the Plaintiff, Amy Devins, by and through her attorneys, Tucker Arensberg, P.C., and moves this Honorable Court, pursuant to Pa.R.C.P. 238 for an award of delay damages, and in support thereof alleges as follows: 1. Plaintiffs cause of action accrued as a result of a motor vehicle accident which occurred on November 27, 1998. 2. Plaintiff instituted suit in this matter on November 21, 2000. 3. Plaintiff served original process on Defendant on November 29, 2000. (See attached Affidavit of Return of Service from York County Sheriffs Department marked Exhibit "A" and incorporated herein by reference). 4. This case was tried in front of.the Honorable M. L. Ebert, Jr., on April 13, 2009 and April 14, 2009. 5. On April 14, 2009, Plaintiff received a verdict after trial by jury in the amount of Thirty-Four Thousand and Twenty-Seven and 52/100 ($34,027.52) Dollars. 6. Plaintiff is entitled to damages for delay from one year of the service of original process up to the date of the verdict, which was November 29, 2001, through April 14, 2009. 7. Plaintiff is entitled to delay damages from November 29, 2001, until April 14, 2009, calculated as follows: Date Days/Yes Annual Percentage Delay Rate/ 9-1/4% Damaaes 11/29/01 - 01 /01 /02 138 days 10-1/2% $1,350.84 01/02/02 - 01 /01 /03 1 year 5-3/4% $1,956.58 01/02/03 - 01/01/04 1 year 5-1/4% $1,786.44 01/02/04 - 01/02/05 1 year 5 % $1,701.38 01/03/05 - 01/02/06 1 year 6-1/4% $2,126.72 01/03/06 - 01/01/07 1 year 8-1/4% $2,807.27 01/02/07 - 01 /01 /08 1 year 9-1/4% $3,147.55 01/02/08 - 01 /01 /09 1 year 8-1/4% $2,807.27 01/02/09 - 04114/09 103 days 4-1/4% 408.10 Total: $18,092.15 8. The last, and largest, written offer of settlement that Defendant made to Plaintiff, Amy Devins, was on February 2, 1999, in the amount of Six Hundred ($600.00) Dollars. 9. Plaintiff is entitled to a full amount of delay damages set forth in Paragraph 6 above, as the verdict was in excess of 125% of Defendant's written offer of settlement, and the Plaintiff did not cause a delay of the trial. 10. Counsel for the Defendant has been contacted and concurs in the present Motion. WHEREFORE, Plaintiff, Amy Devins, respectfully request this Honorable Court to award delay damages to her in the amount of Eighteen Thousand Ninety-Two and 151100 ($18,092.15) Dollars for a total judgment of Fifty-Two Thousand One Hundred and Nineteen and 67/100 ($52,119.67) Dollars. Respectfully submitted, TUCKER ARENSBERG, P.C. BY. Dennis R. eaffe Attorney . D. #39182 111 North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 Dated: April 23, 2009 Attorney for Plaintiff 107035 EXHIBIT "A" CA.SS NO: 2000-08209 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEVINS AMY VS HOOKER KEITH A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: ROCKER KEITH A but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within WRIT OF SUMMONS On Dace r 6" , 2000 , this o ice was in receipt o the attached return from YORK Sheriff's Costs: ;So ana s• Docketing 18.00 Out of County 9.00 Surcharge 10.00 DEP. YORK CO T ors twine 29.75 Sheriff of Cumberland County .00 66.75 12/06/2000 TUCKER, ARENSBERG & SWARTZ Sworn and subscribed to before me this day of A.D. Prothonotary COUNTY OFYORK OFFICE OF THE SHERIFF S(R;';;%01 2a EAST MARKET ST., YORK, PA 17401 - IONS SHERIFF SERVICE INSTRUCT PLEASE TYPE ONLY LINE i THRU' 12 PROCESS RECEIPT and AFFIDAVIT OF RETURN DO NOT DETACH ANY COPIES 1. PLAINTIFF/S( 2 ATV 7e•7n3 UPUY i. 7 TYPE Of MY OR C0INUIMY ]. DEFENOANT131 14RTT Or SUMMONS nr SERVE S. NAME OF INDNIDUAL, COMPANY. CORPORATION, ETC. TO SERVE OR DESCRPTON OF PROPERTY TO BE LEVIED. ATTACHED. OR SOLD Keith A. Hooker 6. ADDRESS (STREET OR RFO 1MYH Box NUMBER. APT. NO., CRY. SORO. TVP., STATE AND ZM CODER AT _ 704 Ridge Rd, T.eWi3herrV PA 1'1i9 7. wOICATE SERVICE. O PERSONAL O PERSON IN CHARGE R DEFUnZE O 75 C1A36 AWL ,QeOSTEO Q OTHER - NOW 7 00 , 20! I, SHERIFF OF h 6e the sheriff of vn..k COUNTY to sx aflfl? thereof according to low. This depuftation being made at the request and risk of the plaintiff. sHeRRF oFgRlc S SPECIAL. wi7RUCM7N5 OR OTHER INFORMATION THAT VOL ASNSr w EKPEdTwD SERVICE Cumberland Co. OUT OF Coumff CUMBERTAM ADVANCE FEE PAID BY CUMBERLAND CO(AVTS SHERIFF NOM ONLY APPLICAK4 ON VW OF BIQQRION: LLB- WANG OF WATCHMAN -Any USNlr shp BbuN,q upr wrBd woww • w/OwwL in *AM* dwbppw w bwd in 1q pN PoPwM vupr wSwr.AI mr7lrw urr . Hw.N for OR, Ipr, rMRglp4 RN RwRlwdd per.rl4.'d1N uoYYby pv?ond WY>dbdwwy,aNwABYBNmpw OW d rd, OBppaIlr~wba w pwww rY PBP" xRAN. *Am f4 rb *We& S. TOR WW iiWTUNE 10. raISPINN/E NUANIER 1 t. DATE FKED . 111 N. FROM ST., PO Box 889, HARRISBURG PA 17108-0889 (717) 274121 11/21100 12 SaNO NOTWA OF SERVICE COPY TO NAME AND ADDRESS BELONG (11W n MW be oNnpMbS S n % mm nW W. , . I adoRF.NBB. Nap4 d ft ae a.BABIrN r YlltaNE rota 17. O 1 hrwwawar.sa nr.n. R V 100.00 - - . 3a Fp.q. C.IWY Crb 7S. Adw Crb S•. 3NMpR CaW 57. Ndry C.M1 >•. YI N. A OC bpd YRY 42 rC?. a.. Notarw 3.w SVRmkkft GFFYpt NuPyAPubB` AM M. HOSE .y « Y`Isaion ONB. C, mm? Exoir.s 1. NABTE-WW%AuAaMf 2PINK -ABOm" S. CANARY-ShWft ON= 4. BWE-Slh.W. Olk. SEE REMARKS BELOW `/SAG t9*9x CUNBE tLAlD COUNTY SHERYFF CERTIFICATE OF SERVICE AND NOW, this 23d day of April, 2009, PAULINA PATTI THOMAS, for the firm of TUCKER ARENSBERG, P.C., attorneys for Plaintiff, hereby certify that I have this day served the within document by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Casey Shore, Esquire Gover, Perry & Shore 2411 North Front Street Harrisburg, PA 17110 PAULINA PATTI THOMAS i t 1--r F- 0 r4 r ? ?,,?'A"RY 200 APR 23 PM 1., - 3 2 CU??r _ R APR 2 4 2000 AMY DEVINS, Plaintiff V. KEITH A. ROCKER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-8209 CIVIL ACTION - LAW : JURY TRIAL DEMANDED ORDER AND NOW, upon consideration of the ' this _ day of within Plaintiffs Motion for Delay Damages, it is hereby ORDERED THAT: The jury verdict of April 14, 2009, in the amount of Thirty-Four Thousand and Twenty- Seven and 52/100 ($34,027.52) Dollars is hereby molded so as to add delay damages in the amount of Eighteen Thousand and Ninety-Two and 15/100 ($18,092.15) Dollars for a total judgment of Fifty-Two Thousand One Hundred and Nineteen and 67/100 ($52,119.67) Dollars. BY THE COURT: r J 14 ,.,3vnc5 . -0 ?It-u -IB?trrJ5 - Q- I-t i-u bQ1 L-c1 h 2Z :01 W LZ ?0 60OZ Jrt bduiw _ ?7 'Hi G vg: ??_1-031IJ AMY DEVINS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 00-8209 CIVIL ACTION - LAW KEITH A. ROCKER, : Defendant JURY TRIAL DEMANDED PRAECIPE TO SATISFY AND DISCONTINUE TO THE PROTHONOTARY: Please mark the above-captioned matter satisfied and discontinued. Respectfully submitted, Date: May 21, 2009 TUCKER ARENSBERG, P.C. Y• Dennis R. Sheffer, Attomey I. D. 9182 111 North Front Street P. O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 Attomeys for Plaintiff 107686 FIM-OFFICE OF TMt PROTHONOTARY 2009 JUN -5 PM 3: 55 CUW-P,, i u ,,,DIJNTY tPENNSYLVANLA