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Home My WebLink About01-1703 FX . CHONG YI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. CIVIL ACTION - LAW DEBBIE SUE TRAUTMAN and MONIQUE WATSON, Defendants NO. 01- 17~ (1J~L~ JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following 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 TIlE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4th Fl., Cumberland County Courthouse Carlisle, Pennsylvania 17101 (717) 240-6200 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas sugnuientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. COURT ADMINISTRATOR 4th Fl., Cumberland County Courthouse Carlisle, Pennsylvania 17101 (717) 240-6200 OR\G\N~L 228143.1\DLL\LC2 " "'1" '." ~-_o_.c",I( '.__._"" '_"_~~. .=,._ ,'^<' "'_,,~ ""1"__",,,_ < .<.' ,.~_,.~__, __'r ,,'-", ~, <, - .,..." - Ii :1 tll II Ii CHONG YI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. CIVIL ACTION - LAW NO. 0 J - J'103 Cw.<i "'/-Uv>-' DEBBIE SUE TRAUTMAN and MONIQUE WATSON Defendants JURY TRIAL DEMANDED COMPLAINT I. Plaintiff Chong Yi is a citizen of the Commonwealth of Pennsylvania and an adult individual who resides in Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant Debbie Sue Trautman is an adult individual and citizen of the Commonwealth of Pennsylvania who resides at 1485 OITS Bridge Road, Enola, Cumberland County, Pennsylvania. 3. Defendant Monique Watson is an adult individual and citizen of the Commonwealth of Pennsylvania who resides at 53 Village Court, Mechanicsburg, Cumberland County, Pennsylvania. 4. The facts and occurrences hereinafter related took place on or about January 20, 2001, at approximately 6:55 p.m. on Wertzville Road, Cumberland County, Pennsylvania. 5. At that time and place, Mr. Yi was operating his motor vehicle, a 1991 Toyota Previa, in an eastbound direction on Wertzville Road. 6. At that time and place, Mr. Yi was traveling within the lane of travel for eastbound traffic on Wertzville Road, Cumberland County, Pennsylvania. 7. At the same time, Defendant Debbie Sue Trautman was operating a 1997 Ford Explorer in a westbound direction on Wertzville Road and had been traveling in the lane of travel for westbound traffic on Wertzville Road. 228143.1IDLL\LC2 :~ .1, ~. " ~. ..O.=_~, ...~ " .,"", '= .--- -,~, ,. -"- . =-,~" ".~-' . 8. Due to her speed in adverse weather conditions, Defendant Trautman left her lane of travel, entered Mr. Vi's lane of travel, and struck his vehicle. The force of the impact pushed Mr. Vi's vehicle off ofthe roadway onto the south side ofWertzville Road. 9. Mr. Vi's vehicle was stopped on the south side of Wertzville Road when Defendant Monique Watson, operating a 1990 Buick Century in an eastbound direction, lost control of her vehicle and collided into Mr. Vi's vehicle on the berm of the road. 10. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Mr. Yi are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant Trautman operated her motor vehicle as follows: a) failure to stay within her lane oftravel; b) failure to travel at a safe speed; c) failure to drive her vehicle with due regard for the highway and traffic conditions which were existing and of which she was or should have been aware; d) failure to keep proper and adequate control over her vehicle; and e) driving her vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 11. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Mr. Yi are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant Watson operated her motor vehicle as follows: a) failure to stay within her lane of travel; b) failure to travel at a safe speed; c) failure to drive her vehicle with due regard for the highway and traffic conditions which were existing and of which she was or should have been aware; d) failure to keep proper and adequate control over her vehicle; and 228143.11DLLILC2 2 ,."J _ ,_.,."~_"""._,,,?~__,~ ~ 0_" ~ ,. .,.,. .,~, "..'"""",,' = ~~. -. ,....". - '* ."f"-~_-' I' , e) driving her vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. CLAIM I Chong Yi v. Debbie Sue Trautman and Monique Watson 12. Paragraphs 1 through 11 of the Complaint are incorporated herein by reference. 13. Mr. Yi sustained painful injuries that include but are not limited to cervical sprain/strain. 14. By reason of the aforesaid injuries sustained by Mr. Vi, he was forced to incur liability for medical treatment in an effort to restore himself to health, and claim is made therefor. 15. Because of the nature of his injuries, Mr. Yi has been advised and, therefore, avers that he may be forced to incur similar expenses in the future, and claim is made therefor. 16. As a result ofthe aforementioned injuries, Mr. Yi has undergone and in the future may undergo physical and mental suffering, inconvenience in carrying out his daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 17. Mr. Yi continues to be plagued by persistent pain and limitation and, therefore, avers that his injuries may cause residual problems, and claim is made therefor. 18. As a result of the aforesaid accident, Mr. Vi's 1991 Toyota Previa was destroyed and the fair market value of the vehicle was $6,345.00. WHEREFORE, Plaintiff Chong Yi demands judgment against Defendant Debbie Sue Trautman and/or Defendant Monique Watson in an amount in excess of Twenty-Five Thousand 228143.!\DLLILC2 3 ,~ .- - ",--- ,. . ($25,000.00) Dollars, exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. Date: ?7-~d-\-O \ ANGINa & ROVNER, P.C. ~~ I.D. No. 35956 4503 N. Front Street Harrisburg, P A 17110 (717) 238-6791 Attorney for Plaintiff 228143.1\DLLILC2 4 1'" -~"~7.L)o'_'/~ "'_~~ " ,_'" ~'T"'_'" ""'''', _ .' '. _ _ ,~, _., _~_ '1 ,~ -'I ." '", ~_ .v . .. :~,,~, . , I. , , I. <, VERIFICATION I, Chong Yi, Plaintiff, have read the foregoing COMPLAINT and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. WITNESS: ~ -:S//7/{)1 "- / / ~~ Cho gYi // Dated: 228143J\DLL\LCZ '''C'"1",1,"'1r"_;_'f-''!1''.o'',-,_C''_' .",__".""., _'C""',' ~_I'_,',,_ ,--.?,,_,_~__I~",__.._~,,)..,.,~_,__:_. ,..",. I." '-r" ,-, I ---"-'."-> ~ ~d ""'" rt, ~ ,''''L' ,~ 0' rp "'."""'" .,_ 'C.'.'" ~.> _'.'" ,,-, """4,"'-- ".',,0 .. "~, ~,.. ",,"". ,,', .,"~ ___,~"__,,~" ~,~ '__,.__,~,_,;;...;,,__'_'J, '. "f'~'~" .,' '1'-":iiJ~1It~'f' ti~:"'it'rl : -- Q -0 >.> 1;; ~ -lQ 0 ~ .:t c '-< '? .,. -at" ~ C5 WrT '^ . . ~F:' 0-:. ( () (,... (n ;..:. D N rit' , ,V~c~, :v c,., i> ~~ f(~ ~ J f~ .J::: ...} ~ ~ ~ C) () 'I 8 :-1;: ~;'j !"..) ", ('1~t; ~s.~~ 5.) -< CJ ~) .-J ~,!ilI!II!!l'I1~~:I!~W ".~~l~~~,__,o"''''r:'~,'r''''~,', r,i@_ I' .' '. CHONG YI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CNIL ACTION - LAW DEBBIE SUE TRAUTMAN and MONIQUE WATSON, Defendants : NO. 01-1703 : JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE THE PROTHONOTARY: Please enter my appearance on behalf of Defendant, Monique Watson, in the above-captioned action. cGuire, Esquire orney LD. No. 73617 Brett M. Woodburn, Esquire AttorneyLD. No. 81786 3631 North Front Street Harrisburg, P A 17110 (717) 232-7661 Dated: s;J)f y, ., -"'_"'ff""__""'~<"'_~'"_' n,','''' ,,"-~~ -'F~"'" _~ ,__ "0 ,." ",.,._~ ',1-,=' ,'.- ~,-' - , - ,._, ~q '-"I' ","", ~ '. CERTIFICATE OF SERVICE 0''/4'\ ~ AND NOW, this~ day of . 0 ,2001, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Thomas E. Brenner, Esquire GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 E. Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 David L. Lutz, Esquire ANGINO & ROVNER, P.C. 4503 North Front Street Harrisburg, P A 1711 0 CALDWELL & KEARNS By()lJJ J ~~iJ "; ^~,,,- "''';' ~:_~,'o/,~"d ''''''''':"'''_''''1I_.i:__~~_L'''__''~I",_'~_~,,__~,_ ., ",," _~il ,," .., - I ' "".,< ., _. ""'"_'__'_"_c"",""'_' _",_"7"_, ~ " f?'{t I'"", ">^ .c..~~"~, _ ...,..,. r,,,", '""._",",,"_,r. -," .~.. , ,. ."]7 """"",,,.,,,,, '" ".".,'" '"l1UI III (') <:::> c::: ~. "V~ ..,. flirt: .:;;,;; >-'" ---.~ ;;;=t-: : l?lr~:' 'Co ~~ !EE3 c:: :,) 3j ':.v -<: rr, "' ,-, -,.-) ~rl ..-<,_J .....-;,: ~L~_~~ !If~~~IIJl!if{'[il',iUl~_"'I"'''_"~ '!;fl~'f.'!il,,=m''1'!k')~~~ ~~~,. Thomas E. Brenner, Esquire I.D. #32085 GOLDBERG, KATZMAN & SHIPMAN, P.e. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendant CHONG Yl, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. No 01-1703 DEBBIE SUE TRAUTMAN and MONIQUE WATSON, Defendants : Civil Action - Law : JURY TRIAL DEMANDED NOTICE TO PLEAD To: Plaintiff and his counsel, David Lutz, Esquire Angino & Rovner, P.c. 4503 North Front Street Harrisburg, P A 171l 0 Defendant, Monique Watson and her counsel Jeffrey McGuire, Esquire Caldwell & Kearns 3631 North Front Street Harrisburg, P A 171l 0 You are hereby notified to plead to the within New Matter of Defendant, Debbie Susan Trautman, within twenty (20) days of receipt hereof. GOLDBERG, KATZMAN & SHIPMAN, P.e. By CJ::~ Dated: S //vlol Thomas E. Brenner, Esquire LD. No. 32085 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 " :.;>: '"I ' ,-"-~ _ f'f_,";~f"".- ""_'_'''~"' ',<,.' O;,,",W,, , 1'"_..,...,, _~__~_" .~__ ~ ',,>H_' , .-_ Thomas E. Brenner, Esquire !D. #32085 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P. O. Box 1268 fLarrisburg,Pi\ 17108-1268 (717) 234-4161 Counsel for Defendant CHONG VI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 01-1703 DEBBIE SUE TRAUTMAN and MONIQUE WATSON, Defendants : Civil Action - Law : JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEBBIE SUSAN TRAUTMAN AND NOW, comes the Defendant, Debbie Susan Trautman, by her attorneys, Goldberg, Katzman & Shipman, P.C. who states: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted 5. Admitted. 6. Denied. Mr. Yi had lost control of his vehicle and was in the westbound lane at the time of the initial impact. 7. Admitted. ,-." - -. ,- ,~^ ,-." " '7'. "".' .,',', _ ,~ ".' ',"" -. <. >'_ _ _ .., _~'," ~_~, ,_~',~,,_ .~__,. . _ ,~.,~ _, ,~ " f ".__ , -,.^ ~=~" .,~ 8. Denied. Ms. Trautman was operating her vehicle at an appropriate speed and remained within her lane of travel where she was struck as Mr. Yi' s vehicle entered that lane of travel making impact with the front driver's side of her vehicle. 9. Admitted. 10. Denied. It is specifically denied that Defendant Trautman was negligent, careless, wanton, or reckless in the operation of her motor vehicle. The injuries and damages claimed by Mr. Yi did not arise from any action of Defendant Trautman. In further response, the remainder of this paragraph is denied pursuant to PA.RC.P. 1029(e) and proofthereofis demanded. 11. This paragraph is directed to another Defendant and therefore no answer is required by Defendant Trautman. CLAIM I 12. The answers to paragraphs I-II are incorporated herein by reference. 13. Denied. This paragraph is denied pursuant to PaRC.P. 1029(e). 14. Denied. This paragraph is denied pursuant to PaRC.P. 1029(e). 15. Denied. This paragraph is denied pursuant to PaRC.P. 1029(e). 16. Denied. This paragraph is denied pursuant to Pa.RC.P. 1029(e). 17. Denied. This paragraph is denied pursuant to Pa.R.C.P. 1029(e). 18. Denied. This paragraph is denied pursuant to Pa.RC.P. 1029(e). WHEREFORE, Defendant, Debbie Susan Trautman requests that the Claim I ofthe Plaintiff's Complaint be dismissed with prejudice. 2 ';! -~ ] , ~--""-~ "'--<--~'"I-'---'~ -...", -~<-~~ .-~_-"11___"'_"~-'_"--__-"'l-'''';'''','',o ""l'_ <- "'<'1'-"- 1-"" - - . r _ '- - n'_ ','>', _""'^"__""_~_'_ ""_" '<n' ~. '," ,,,,, '''. "' . . NEW MATTER DIRECTED TO PLAINTIFF 19. Plaintiff's injuries and damages arose from his comparative negligence under the circumstances. 20. Plaintiff's injuries and damages arose from his assumption of risk under the circumstances. 21. Plaintiff's injuries and damages arose from the combined negligence ofPlaintiffYi and Defendant Watson. WHEREFORE, Defendant Debbie Susan Trautman requests that Plaintiff's Complaint be dismissed with prejudice. NEW MATTER DIRECTED TO MONIOUE WATSON 22. The averments of paragraphs 1-18 of the Complaint are incorporated herein by reference. 23. Plaintiff's injuries, ifany, arose from the conduct of Defendant Monique Watson. WHEREFORE, Defendant Debbie Susan Trautman requests that Defendant Monique Watson be found solely liable on the claim of the Plaintiff, or liable over to her for indemnity and/or contribution on the Plaintiff's claims. Respectfully submitted, GO By: Date:j Itl/O ( omas E. Brenner, Esquire Attorney I.D. No. 32085 320 Market Street PO. Box 1268 Harrisburg, P A 17108-1268 (717) 234-4161 Attorneys for Defendant, Debbie Susan Trautman \'C , f' ~, "V'" t''!" '1':_'" h_ r-" H ,0'1 ". "'_~-_,.>_-_I --'-~"__ J"",""'_-,~_--:_~I""ff-'__=t_ - i ",,-, ~,1' '"' _"_,^""{ } ":!-, . ~ f __r__~ "'" " __~_'J,_",,," .,-- I _v, '" . ~" . ~ , VERIFICATION I, Debbie Sue Trautman, hereby acknowledge that I am a Defendant in this action and that I have read the foregoing document and that the facts stated therein are true and correct to the best of my knowledge, information and belief I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date 4/30/01 !J,Jlh). ~~~ ,., J Debbie ~Trautman SLLSftn ~i ~. , ~> ;., :'; ;i ~ -I 1 " 'j :..1' 'i'<'1?JIII'I .', ~'''"'' "'cO'" "',,~ "0.<'''''-' ,.. ~,_,," b ~_ "" ~""_~_',, .,~,-~ ,_ I - '_ < ., '. ,.-, . . CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, on the / '{) flt day of ~ ' 2001, addressed as follows: David L. Lutz, Esquire Angino & Rovner, P.C 4503 N. Front Street Harrisburg, P A 1711 0 Jeffrey McGuire, Esquire Caldwell & Kearns 3631 North Front Street Harrisburg, P A 1711 0 GOLDBERG, KATZMAN & SHIPMAN, PC By Thomas E. Brenner, Esquire I.D. No. 32085 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorney for Defendant, Debbie Susan Trautman 62885.1 -_~_'~~_~"" ~,~_ '_".' ",~_. -0'" .___.""""..cJ~__U""_~p_'_.N" ~__ Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CHONG YI, vs. : NO. 01-1703 Civil Term DEBBIE SUE TRAUTMAN and : CNIL ACTION - LAW MONlQUE WATSON, Defendants : JURY TRIAL DEMANDED NOTICE TO PLEAD To: Chong Yi and his attorney, David L. Lutz, Esquire Debbie Sue Trautman and her attorney, Thomas E. Brenner, Esquire YOU ARE HEREBY NOTIFIED to file a written response to the enclosed Answer with New Matter and Crossclaim within twenty (20) days from service hereof or a judgment may be entered against you. Respectfully submitted, CALDWELL & KEARNS Dated: s'/z~/o( By: tJ~ T M. WOODBURN, ESQUlRE orney J.D. # 81786 3631 North Front Street Harrisburg, P A 17110 (717) 232-7661 Attorney for Defendant Watson ;;,.,.,.,. '~-" '''oY''')''Fj-, ,"""",_,'"O""",~'r-',,_-,i-p,--- ~,,'_ ,_~_'~_",_I~"'-<"":"" I, ,r ~ c""' , 1<-'-" " ~- .. - '-~. '" "'-1 Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CHONG YI, vs. : NO. 01-1703 Civil Term DEBBIE SUE TRAUTMAN and CIVIL ACTION - LAW MONIQUE WATSON, Defendants JURY TRIAL DEMANDED ANSWER WITH NEW MATTER AND CROSSCLAIM OF DEFENDANT MONIQUE WATSON AND NOW, comes the Defendant, Monique Watson, by and through her attorneys, Caldwell & Kearns, and Answers Plaintiff's Complaint and avers New Matter as follows. 1. Admitted. 2. Admitted. 3. Denied as stated. To the contrary, Defendant Monique Watson currently resides at 319 Third Street, Apartment 12, West Fairview, Cumberland County, Pennsylvania. 4. Admitted. 5. Denied. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truthfulness ofthe averments of said paragraph and the same are hereby denied. 6. Denied. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truthfulness of the averments of said paragraph and the same are hereby denied. --;""--1' ,_,_",,_,","->;:1_r'w~,_:,~_,_ "', ?~. ',- ,-~__' ,'1'__'_ _'-'CI 'c'-' -"'_' ,. , i,-: ~-" -" ~- ~ . 7. Denied. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truthfulness of the averments of said paragraph and the same are hereby denied. 8. Admitted in part, denied in part. It is admitted that the Trautman and YI vehicles collided. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truthfulness ofthe remaining averments of said paragraph and the same are hereby denied. By way of further answer, it is specifically denied that Mr. Yi's vehicle was off the roadway. 9. Admitted in part, denied in part. It is admitted that the Answering Defendant's vehicle collide with Plaintiff's stopped vehicle. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truthfulness ofthe remaining averments of said paragraph and the same are hereby denied. 10. The averments in said paragraph are directed to a party other than the Answering Defendant and no response is required. By way of further answer, the averments of said paragraph are denied as conclusions of law to which no responsive pleading is deemed necessary and strict proof thereof is demanded at trial. 11. Denied. The averments in said paragraph are conclusions of law to which no responsive pleading is deemed necessary and strict proof thereof is demanded at trial. - ,"-""" - :";:5_<:'!":'o"",,,,-,:~,,_,,,,,,,__","__7\~o',3_ ,', ' _ _~ '--, _'~"'__"I~~'~ I 1,":-- -" ,-,' " ,," " ,- ~, '-I - ' .< CLAIM I Chonl: Vi v. Debbie Sne Trautman and Monique Watson 12. The answers to paragraphs one (1) through eleven (II) are incorporated herein by reference. 13. Denied. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truthfulness ofthe averments of said paragraph and the same are hereby denied. 14. Denied. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truthfulness ofthe averments of said paragraph and the same are hereby denied. 15. Denied. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truthfulness of the averments of said paragraph and the same are hereby denied. 16. Denied. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truthfulness of the averments of said paragraph and the same are hereby denied. 17. Denied. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truthfulness ofthe averments of said paragraph and the same are hereby denied. 18. Denied. After reasonable investigation, the Answering Defendant is without knowledge or information sufficient to form a belief as to the truthfulness of the averments of said paragraph and the same are hereby denied. ~!:#I"I' --,"',~r.,'4""!<,'-"'f" ':"'.~?" /.1"'.', '-,-"'-'-S'0"',.~' '~'1'.,1''''- ~- - " - WHEREFORE, Answering Defendant Monique Watson respectfully requests that the Complaint be dismissed and judgment entered in her favor and against the Plaintiff without cost to her but together with such costs, expenses and attorneys fees as authorized by law and which the Court deems necessary, just and appropriate under the circumstances. NEW MATTER 19. The answers to paragraphs one (1) through eighteen (18) are incorporated herein by reference. 20. Plaintiffs claim is barred in whole or in part by provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 21. Plaintiffs injuries pre-existed the motor vehicle accident which is the subject of Plaintiffs Complaint. 22. In accordance with 91722 of the Pennsylvania Motor Vehicle Financial Responsibility Law, Plaintiff is not entitled to recover any sums paid or payable from any group plan or other arrangement from the Answering Defendant. 23. Plaintiff fails to plead whether he was bound by the limited tort or full tort option on the date of the accident, and iflimited tort applies, Plaintifffailed to plead an exception to the rule prohibiting recovery of non-economic damages in accordance with 75 Pa.C.S.A. 91705. 24. The Answering Defendant specifically preserves those defenses of contributory/ comparative negligence and assumption of risk under Pa. R.C.P. 1030. WHEREFORE, Answering Defendant Monique Watson respectfully requests that the . Complaint be dismissed and judgment entered in her favor and against the Plaintiff without cost '. :-"1"_~,, ~ ".'<'-,C-->',,'," "<,-,!",,,'''~~,"'''-' " .., ,""G":"d'--" .. -'I --"", "- ,-~"- --"," 1-" ~,. ----= -: 1 ("- to her but together with such costs, expenses and attorneys fees as authorized by law and which the Court deems necessary, just and appropriate under the circumstances. CROSS CLAIM PURSUANT TO Pa. R.C-P. 2252(d) DEBBIE SUE TRAUTMAN 25. The answers to paragraphs one (1) through twenty-four (24) are incorporated herein by reference. 26. The injuries and damages, if any, suffered by Plaintiff Chong Yi were caused in whole or in part by the negligence of Defendant Debbie Sue Trautman, as set forth in paragraph ten (10) of Plaintiff's Complaint, which is incorporated herein by reference. 27. If it is determined that Plaintiff Chong Yi is entitled to recover from the Answering Defendant, then Answering Defendant is entitled to contribution and/or indemnification from Defendant Debbie Sue Trautman. 28. This New Matter pursuant to Pa. R.C.P. 2252(d) is filed to protect the rights of contribution and/or indemnity of Answering Defendant in the event that it is determined that Answering Defendant is jointly and/or severally liable to Plaintiff Chong Yi, which liability on the part of the Answering Defendant is hereby denied. WHEREFORE, Answering Defendant Monique Watson respectfully submits that Defendant Debbie Sue Trautman is solely liable to Plaintiff Chong Yi, liable over to Answering ':'"""l - '-~_'-:r:.,'-:~,._:,\'il')>';O',_, ;__'-.0 ' - -' ,~, '''',",' :: ~I ',:"' 1- r _ c' "T"'J-~ ,- r-, ,-.,-.0 Defendant Watson, or jointly and severally liable with Answering Defendant Watson. Respectfully submitted, CALDWELL & KEARNS Dated: 5f~(rJ( By: 3631 North Front Street Harrisburg, P A 17110 (717) 232-7661 Attorney for Defendant Watson 'i'! ..1, ,C -, '" ,"'i-_'~' "":,,-,,-"^'tc'-, ,,--- ,e. """', ,o;~>',-""""--~ ~-'- .,., _I ',.' ',' , _ -. ,- -'--~ -1--: ,-- .' VERIFICATION The undersigned, MONIQUE WATSON, hereby verifies that the facts set forth in the Answer with New Matter and Crossclaim, are true and correct to the best of her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~~~ ONI~WATSON <I "1 , ;:';~'r_ '1"~' """'-'~~-,-!~,'~_""~'.__,_!,,,,~,--~.,._>.,_-_ '---~ ,-,,- -:'""'"?1'I_""'I":"'" - -- -I - -<,".~ " .. " "":' - - ^c ~ CERTIFICATE OF SERVICE AND NOW, this ~ day of ~ , 2001, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, P A 1711 0 Thomas E. Brenner, Esquire GOLDBERG, KATZMAN & SHIPMAN, P.e. 320 E. Market Street P.O. Box 1268 Harrisburg, P A 17108-1268 CALDWELL & KEARNS By: 01-177/24287 , 'j ., -, '",- ',~ ';~,-_- ,_.,____""',,'~<>'I-"',;,"-O' "", --,' _""'_'I~-" 'I' ~, - ~-, -, - ~ I ,,__C_._of. !,1__-1 " ~.... ... , ' ( CHONG Yr, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA vs. : CNIL ACTION - LAW DEBBIE SUE TRAUTMAN and MONIQUE WATSON, Defendants : NO. 01-1703 : JURY TRIAL DEMANDED DEFENDANT MONIOUE WATSON'S ANSWER TO NEW MATTER OF DEFENDANT DEBBIE SUE TRAUTMAN 22. No answer required. 23. The averments of paragraph 23 are conclusions of law to which no answers need be made. B. J T. McGuire, Esquire Attorney LD. No. 73617 Brett M. Woodburn, Esquire Attorney LD. No. 81786 3631 North Front Street Harrisburg, P A 17110 (717) 232-7661 Dated: $~/ --":"1"1 r '_", .< ,_~~ ,''' :_"~, " '," ~_., -'- --I ."'" _'h,' ",' ".-. - , I '_r' ,....". -"'""i .... --... . .\ CERTIFICATE OF SERVICE . Jhfl ~. AND NOW, thls./-IL- day of , 2001, 1 hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Thomas E. Brenner, Esquire GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 E. Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 David L. Lutz, Esquire ANGINO & ROVNER, P.C. 4503 North Front Street Harrisburg, P A 1711 0 CALDWELL & KEARNS By: 'i/Jil- 01-177/24448 __"1 ,_. '"'" ,~_,"f~","',_, ",e '__"'_". ,~ ,-," "7-,7''1, "'_', -'__, "0< _, 0 -1- -, ,1" ,---",- , ~ - --~ , v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW CHONG YI, Plaintiff DEBBIE SUE TRAUTMAN and MONIQUE WATSON, Defendants NO. 01-1703 Civil Term JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO DEFENDANT TRAUTMAN'S NEW MATTER 19. through 21. Defendant Trautman's New Matter, paragraphs 19 through 21, fails to set forth factual allegations that require the Plaintiff to admit and/or deny said allegations. The factual allegations contained in the Plaintiff s Complaint are incorporated herein by reference. WHEREFORE, the Plaintiff respectfully requests that Defendant Trautman's New Matter directed to Plaintiff be dismissed. Date: 'S ~\ \p -0 I ~ROVNERP.C. David 1. Lutz J.D. No. 35956 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiff 231114.1IDLLIMTG ,,""7"..'_'< ."-_", ~_" ^' ~^_, ",,_~~_,_, '_"'" ""'" <'"~'''''"'" ,_,~,,_ ~_I , ,., _' I M' ,~ _~~_~ eo'_." ~_' ~,,,." '" " "'~ - ~- " ;1 Ii <\ II J,." . CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the PLAINTIFF'S REPLY TO DEFENDANT TRAUTMAN'S NEW MATTER upon defense counsel via postage prepaid first class United States mail addressed as follows: Thomas Brenner, Esquire 320 Market Street, Strawberry Square P.O. Box 1268 Harrisburg, P A 17108-1268 Attorney for Defendant Trautman Jeffrey McGuire, Esquire 3631 North Front Street Harrisburg,PA 17110 Attorney for Defendant Watson Dated:S /\~ -\l\ 23 1114.I\DLLIMTG , .~~ , '" ,,~, ,v 'c,''''y_~__ - ~ '. ' ,- ^- <'~_"h_<..~ .'.. I .,,,.. 4_ _O'_,~' ,,- I _ . -,' - -~," ..' -" --.~-- .,.." "'.,.., ~ :,. , ,,- ---~^'- -~ ~.,~~ ,'& -. '0.,_,"" /-:J\p._' . ,-, c;<> . . ":!."'T'j'.y" I: :~'~t""~V::;;~TI"rcr":"I}'r_ - '_"-"""-m . -""'-- ",~, r ~ Q -c::~ ,-- - , 'TJ rT':: ;.<"" rn r',': Z :J , -'" r"": or_'_ Ct) c__. ~,~--j -< ~ u;:1 ..::-'" C~-' ?~ I'-~, '-_J r;,? ~"--" c (~~ 2': r:- ::< ~:D . ..j -< --''''-'-~ ' ..., . . ~ _, ",. ,~,"_",__<<,__,_~,'''ooJl~tl!f~'iH;m~\IIIil~~", '"" ,m!;", ~'_r'ii' V:'.Ot,;0:It'"g;;2,,:.>.,!,,)f;;i;~<;'/:0e<';;::',':;;"fr:r;:",-'i;-f'i;:!," , CHONG YI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. CIVIL ACTION - LAW DEBBIE SUE TRAUTMAN and MONIQUE WATSON, Defendants NO. 01-1703 Civil Tenn JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO DEFENDANT WATSON'S NEW MATTER 19. through 24. The Defendant's New Matter, paragraphs 19 through 24, fails to state factual allegations that require the Plaintiff to admit and/or deny said allegations. The conclusions oflaw in the Defendant's New Matter require no response. WHEREFORE, the Plaintiff respectfully requests that Defendant Watson's New Matter directed to Plaintiff be dismissed. ANGINO & ROVNER, P.C. Date: IQ -') /0 \ Dald L J.D. No.3 5 4503 N. Front Street Harrisburg,PA 17110 (717) 238-6791 Attorney for Plaintiff 231918.1IDLL\MTG ~,~, ~,' ~ ..,~. -- ~'_ ~. ."" dl" .." ..~"".. I, ~'I - I" -- pro - ,,' ~,- - < ~"" --""'" >s-it/~lJ!:R7::'1ZkY,;:;i,!.\:;~Y; Jzt~ ~'~D:t;\:i' _:;"}-\/li CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of the PLAINTIFF'S REPLY TO DEFENDANT WATSON'S NEW MATTER upon defense counsel via postage prepaid first class United States mail addressed as follows: Thomas Brenner, Esquire 320 Market Street, Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-1268 Attorney for Defendant Trautman Jeffrey McGuire, Esquire 3631 North Front Street Harrisburg, PA 17110 Attorney for Defendant Watson ~~~ Dated: ~ /<; /0 \ 231918.1\DLLIMlG . , - ", :"u' n ,,_,"', ,~ " c_, _ """_, ~k~ ,.1--, ',', ,_" .. -~ '-- ~ . "-. " - ~ , .... :;r; I :;~~~- """' .'l!ll ,~""'"" n_ ._m_"".."".~."",... .. o"~ J, K~1!r.l,<wl)'mlJ')llil~~"'~~~~-"'!;\#~~illlj~~'!!.~/lil!!"~~';,j'jlijl'!i:!JIJ'i!:'W;!jl!~~~if' ~~~ -"" " ,,~, ~--,- . '. ,,:0' -]"t';"ITt'!f\'C'-t-~+'\i;~~.1fk'4l~f&1i.~<*~~1i}iitw.u'W;;'Jk~\1f~ (") <:::> 0 c: "~ -r,- -0:$ r_ !!Ern c= Z:o :z ::g CD):': I ,:ntg -<-,- C'. f<O C'S -0 "'I'l..- ~O ::!C f~~ :>0 w c: ~ 0 ;.-;;! (JJ :0 -< ~~ ..' ~ Thomas E. Brenner, Esquire 1.0.#32085 GOLDBERG, KATZMAN & SlllPMAN, P.c. 320 Market Street P. O. Box 1268 Harrisburg, P A 17108- 1268 (717) 234-4161 Counsel for Defendant CHONG YI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 01-1703 DEBBIE SUE TRAUTMAN and MONIQUE WATSON, Defendants : Civil Action - Law : JURY TRIAL DEMANDED REPLY TO NEW MATTER OF DEFENDANT MONIQUE WATSON BY DEFENDANT DEBBIE SUE TRAUTMAN AND NOW, comes Debbie Sue Trautman, by her attorneys, Goldberg, Katzman & Shipman, P.C., and states: 25. Objection. This paragraph violates the Pennsylvania Rules of Civil Procedure by seeking to incorporate twenty-four (24) other paragraphs into a single paragraph. To the extent an answer is required, it is denied. 26. Denied. This paragraph states a legal conclusion to which no reply is necessary. In further response, the answer of Defendant Debbie Sue Trautman in paragraph 10 of Plaintiff's Complaint is incorporated herein by reference. 27. Denied. This paragraph states a legal conclusion to which no reply is necessary. 28. Denied. This paragraph states a legal conclusion to which no reply is necessary. ,~I~li ',<--.,,,-':",,,: - ;Y-,c-~'~_' -f~Y_:"___-I,-_ , 'f!i-~I'-,"r.- """'~~"-_ '--"_;c_,," >', 1<"',. ," '_ "d~_"_ "",f'>~ .. H''',~'" ,''''' <-r.-, ,,_~, ~,_'"_ '_"_~______ "'~~'" _',"'",,,.,.,'-- :~ ~ ; .. WHEREFORE, Defendant Debbie Sue Trautman requests the Crossc1aim of Defendant Monique Watson be dismissed with prejudice. Respectfully submitted, By: Date: C5 -bl Thorn . Brenner, squire Attorney I.D. No. 32085 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Defendant. Debbie Sue Trautman 2 ,-._,,, - '~'~-y',"- "-b', .1'-"" "--",,,_ ,-' VERIFICATION PURSUANT TO PA. RoC.P. No. I024lc) Thomas E. Brenner, Esquire, states that he is the attorney for the party filing the foregoing document; that he makes this verification as an attorney because the party he represents lacks sufficient knowledge or information upon which to make a verification and/or because he has a greater personal knowledge of the information than that of the party for whom he makes this verification; and that he has sufficient knowledge or information and belief based upon his investigation of the matters averred or denied in the foregoing document; and/or because the party for whom he makes this affidavit is outside the jurisdiction of the court, and verification of none of them can be obtained within the time allowed for the filing of the document; and that this statement is made subject to the penalties of 18 Pa. C. S. 94904 relating to unsworn falsification to authorities. Date: ~ ~) 0 I 1~ as E. Brenner, Esquire ""'!"'!"", """~.""'_O "-,"-0""_;__ ""'-~'-~""_1'!~T,,-,'-~_'.,"I_-'n__~ "_,_,_.<~,, n_'_I:""__~'___' "~"I -,o,-,~s,c"__""___,,,,-,,, -7"~~,-~_'_;'~,~,,_ _,."_~_,,_ .,", "',' c''?'- <:"y- CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy ofthe foregoing document upon all counsel of record by depositing the same in the United States Mail, first class, postage prepaid, ./ 6Y~ day of ...d '-' '-'---' , 2001, addressed as at Harrisburg, Pennsylvania, on the follows: David L. Lutz, Esquire Angino & Rovner, P.c. 4503 N. Front Street Harrisburg, P A 1711 0 Brett M. Woodburn, Esquire Caldwell & Kearns 3631 North Front Street Harrisburg, PA 17110 GOLDBERG, KATZMAN & SHIPMAN, P.c. By: Thomas . Brenner, Esquire lD. No. 32085 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorney for Defendant, Debbie Sue Trautman 63992.1 , - ',' ,"~""."."'r,_'""_''f='",,,~,,",,, - ~. '+'_~'C '-~",='''I'_7,,;." 'O"_'"'_,_~' ,_ 1','_" '_,~~'o ,_,',00"1_;,," ""_" .--;"." -.,-~, ,._r., -";'""'-"-f"' -- ,-- , . THE LAW OFFICES OF JOSEPH D. BUCKLEY 1237 HOLLY PIKE CARLISLE, P A 17013 TELEPHONE (717) 249-2448 FAX (717)249-4103 September 20,2001 David L. Lutz, Esquire Angino & Rovner PC 4503 N. Front St. Harrisburg, PA 17110 Thomas E. Brenner, Esquire Goldberg, Katzman & Shipman, PC 320 Market Street Harrisburg,PA 17108 Brett M. Woodburn, Esquire Caldwell & Kearns 3631 North Front Street Harrisburg, P A 1711 0 Re: Chong Yi v. Debbie Sue Trautman and Monique Watson Dear Mr. Lutz, Mr. Brenner & Mr. Woodburn: Enclosed please find a copy of the Notice of Hearing by Board of Arbitrators for the above captioned matter. The September 20, 2001 date was changed due to an out of county trial by an attorney for one of the defendants. There will be no continuance except for good cause. If you have any questions, please call me. Very sincerely yours, Joseph D. Buckley, Esquire JDB/mzf Enclosure '-:;n>!:r ,e . -' I"" I' I ..,..~ _oc'"' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHONG YI Plaintiff v. No.01-1703 CIVIL DEBBIE SUE TRAUTMAN and MONIQUE WATSON, CIVIL ACTION - LAW Defendants NOTICE OF HEARING BY BOARD OF ARBITRATORS YOU ARE HEREBY NOTIFIED that the Board of Arbitrators appointed by the Court has scheduled the Arbitration Hearing in the above-captioned case for Friday, November 16, 2001, at 10 a.m., in the 2nd Floor Hearing Room, Old Cumberland County Courthouse, Carlisle, Pennsylvania. Joseph D. Buckley, Esquire David W. Knauer, Esquire Craig A. Hatch, Esquire Date: -1J 9; 'lA/-Of B~&4 Chairman, Board of Arbitrators 1237 Holly Pike Carlisle, PA 17013 (717) 249-2448 cc: Prothonotary Office of Court Administrator David W. Knauer, Esquire Craig A. Hatch, Esquire David L. Lutz, Esquire Thomas E. Brenner, Esquire Brett M. Woodburn, Esquire 'f"""!_'~" ~ 'I' I" " ., r ~!~ Chong Yi, IN THE COURT OF CmlMON PLEAS OF Cu~IBERLAND COUNTY, PENNSYLVM,IA Plaintiff NO. 01-1703 CIVIL 19 vs. Debbie Sue Trautman and Monique Watson, Defendants RULE 1312~1. The Petition for Appointment of Arbitrators shall be substant~ally in the following form: PETIT.ION FOR APPOINTI1ENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURt: David L. Lutz, Esq. , counsel for the plaintiff/~K~ in the above l. 2. action (or actions), respectfully represents that: The above-captioned action (or actions) is (arej at issue. The claim of the plaintiff in the action is $6.345.00 & unliauj<iated The counterclaim of the defendant in the action is bodily injury c;laim The following attorneys are wise disqualified to sit as interested in the case(s) as counselor are other- arbitra!:ors: Dflvin T.. T.llT7. Rsqllire! Thomas Brenner, Esquire: Bret Woodburn. Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. cc Thomas Brenner, Esquire Brett Woodburn, Esquire Respectfully submitted, ORDER OF COURT ~ESq. AND NOW, y~ /~, , '!.9;Jv-o:J, in considerati~n of the . . foregoing petition, ~~~__ Esq., pjJ(f~ ~/ Esq., and t1L~ ~, ,(Sq., are appointed arbitrators in the above-captioned atrion (or actions) as prayed for. By the P. J. . .'- <:;', ~,- " ~ - -~ '., t-, . fI, . .. \fl\'" '\'" "\ 1'""'\ . . ,-.', ' ( ~"\\p ~~..~,. r,f flQRlIWlI~ ~.~" ~ ~,~ - ~~: ~~ ~~ ~ \11~'!~l(\~~ti~~~!n8 ),INriG,) ,y..' '. 01:'1" ! n ~. ) .7 !I,.: 9 I i" I " (.e,.. ',-, ..\~- IW\/IU;(,'. r,w.., llll\u\!~ar,,;(~""f'0''''l''~-'''-'''''i'''il'-i,"",~q:;-''''-V~R!',~,'\')" "llf'li'=_"1' .~~ ~ ~~ ~.~,~,- (') C g -0 eo rn [T: 2::,=,j tJ;S: -<' <:C:-: '!> "''''. zt.,~ $~) L Z =< .>> o t.... !:~ ~~o.... G; ~ __ -~ t , ~nL~! '~~?'C) '.." L..:!'~ ::jf~; .-; -1> IJ -< ~ :..n t>' ~ '..'.;m,""\'l,Gr'~~~ijil'Jil~r:'. ~- '"" il- '-'~''''d';~ol'i'~"",,;r;?'''''l'''''r''l'_'~>G1-1!I''' ~ . . f' '-- l CASE NO: 2001-01703 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND YI CHONG VS TRAUTMAN DEBBIE SUE ET AL DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon TRAUTMAN DEBBIE SUE the DEFENDANT , at 0018:21 HOURS, on the 29th day of March , 2001 at 1485 ORRS BRIDGE ROAD ENOLA, PA 17025 by handing to DEBBIE TRAUTMAN a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 8.68 .00 10.00 .00 36.68 So Answers: r~rt~t;~~ R. Thomas Kline 03/30/2001 ANGINO & ROVNER Sworn and Subscribed to before By: SJClll~~' W Deputy Sheriff me this II & day of ()r,:J 20,) ( A.D. ~L2 ~ -- P othonotary . ~ ;'"_:_~ _, ~ t ~u 1-'" I', I', , 'I ~" 'l! SHERIFF'S RETURN - REGULAR ,,~ \,j..~ CASE NO: 2001-01703 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND YI CHONG VS TRAUTMAN DEBBIE SUE ET AL JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WATSON MONIQUE the DEFENDANT , at 0015:00 HOURS, on the 28th day of March , 2001 at 53 VILLAGE COURT MECHANICSBURG, PA 17055 by handing to ROY ETTINGER (FIANCE-CO RESIDENT) a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 6.20 .00 10.00 .00 22.20 so;;~~( R. Thomas Kline 03/30/2001 ANG INO & ROVNER Sworn and Subscribed to before By: CJawn ~ ~ga Deputy Sheriff th' II,! Ib me lS 1,- day of ~ :JfJ.oj A.D. g a ~/~ Pr t~-;:;otary 1 :,;;r~,rlll4."",~ , " I -1<' .""," 'Y,FiJ~i:' r;:r:?,';';;;t-\~Z("~,,,:,t0t1\7 Thomas E. Brenner, Esquire LD. #32085 GOLDBERG, KATZMAN & SIDPMAN, P.c. 320 Market Street P. O. Box 1268 Harrisburg, P A 17108-1268 (717) 234-4161 Counsel for Defendant CHONG VI, Plaintiff v. DEBBIE SUE TRAUTMAN and MONIQUE WATSON, Defendants TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01-1703 : Civil Action - Law : JURY TRIAL DEMANDED PRAECIPE PLEASE ENTER the appearance of the undersigned on behalf of the Defendant, Debbie Sue Trautman, in the above-captioned matter. ~~EE: Lf~ \'<lvl _~__C",""I"_" "'~_'_-""'____ ""._, 0_ ,"_,~, ~~1'T_"",,"'~.~7__'~__",*_'''~,=~ ._~_ ~'PC Thomas E. Brenner, Esquire 320 Market Street PO. Box 1268 Harrisburg, P A 17108-1268 Attorneys for Defendant, Debbie Sue Trautman "it-;<2;2f,';i :;!Y;,');:1/}:-:,: -~~_~~,'i'l:. CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, on the J erA day of ~ ' 200 I, addressed as follows: David L. Lutz, Esquire Angino & Rovner, P.c. 4503 N. Front Street Harrisburg, P A 1711 0 Monique Watson 53 Village Court Mechanicsburg, PA 17055 By To. renner, Esquire ID. No. 32085 320 Market Street P.O. Box 1268 Harrisburg, P A 17108-1268 (717) 234-4161 Attorney for Defendant, Debbie Sue Trautman 62044.1 2 "~!;o",1_F'" '. '-" -,-__,,~,''''~_>__ ", =,_,'-:<_'_."",.' _,-..,_,'""",,,._ ,,,,,J-,,,,,,~,,,~,,,,',~I ",>. _ ~ ,,__',~,'< .. " ~,'- ~ _ ~" " __ '-'"" ,,_ ~_ 5';ll -, ,-,," -,-'-;-' "-'--.-- - - <--~ ~.,,,, -,. , ,,-,~ =, oW_ - ",-,=" <<-'1 ~"-".'-"-"-'-'2;i;'0Jji;'f%1~~';i~~i:~Ii~i [' =-J ~, ~ ."___ .._"~~~:.A_"^",",,,~e__:<f~~'~"" ~ Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CHONG YI, vs. : NO. 01-1703 Civil Term DEBBIE SUE TRAUTMAN and CNIL ACTION - LAW MONIQUE WATSON, Defendants JURY TRIAL DEMANDED CERTIFICATE PREREOUlSITE 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 Monique Watson certifies that: (I) a notice of intent to serve the subpoenas with copies ofthe subpoenas attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoenas are sought to be served; (2) a copy of the notice of intent, including the proposed subpoenas, is attached to this certificate; (3) no objection to the subpoenas has been received; and (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. Date: 1(1/or '~~1-P---_ '~/-;'_~~~'''~'_C_'_'. ,_,~_,_ ' " c_, -~-~ I. ., 'I ... y Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CHONG YI, vs. : NO. 01-1703 Civil Term DEBBill SUE TRAUTMAN and : CNIL ACTION - LAW MONIQUE WATSON, Defendants : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant Monique Watson intends to serve subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. Ifno objection is made the subpoenas may be served. Date: 7/tJiJ/ ~~ '.~I ~ ,~._ _, ',,_' 0 .-,. I '--' I""' ",.', ,..-- 'r " ,--. . i Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CHONG YI, vs. : NO. 01-1703 Civil Term DEBBIE SUE TRAUTMAN and CNIL ACTION - LAW MONIQUE WATSON, Defendants JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Good Hope Family Physicians Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete medical file of Chong Yi. At CALDWELL & KEARNS, 3631 N. Front Street. Harrisburg, P A17110. 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: Brett M.Woodburn. Esquire Address: 3631 North Front Street Harrisburg. P A 1711 0 Telephone: (717) 232-7661 Supreme Court ID # 81786 Attorney for: Defendant Watson By the Court: Date: Seal of the Court Prothonotary Deputy ~ ,,;;, j "" , >. "'~ rot " ,~ , I' .~ Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CHONG VI, vs. : NO. 01-1703 Civil Term DEBBIE SUE TRAUTMAN and : CNIL ACTION - LAW MONIQUE WATSON, Defendants : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Osram Sylvania Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docmnents or things: Complete employment file of Chong Yi. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburv:. PA17IIO. You may deliver or mail legible copies of the docmnents 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 docmnents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compeJIing you to comply with it. THIS Subpoena was issued at the request of the following person: ;-" Name: Brett M.Woodburn. Esouire Address: 3631 North Front Street Harrisburg. PA 17110 Telephone: (717) 232-7661 Supreme Court ID # 81786 Attorney for: Defendant Watson By the Court: Date: Seal of the Court Prothonotary Deputy "'''''',_T_ ~ ~-',. ~I " , , ,I - '" . . ;"",i,,,- Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CHONG YI, vs. : NO. 01-1703 Civil Term DEBBIE SUE TRAUTMAN and : CIVIL ACTION - LAW MONIQUE WATSON, Defendants : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: State Farm Insurance Companies Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete first party file of Chong Yi. At CALDWELL & KEARNS. 3631 N. Front Street. Harrisburg. PA17110. 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: Brett M.Woodbum. Esquire Address: 3631 North Front Street Harrisburg. PA 17110 Telephone: (7] 7) 232-7661 Supreme Court ID # 81786 Attorney for: Defendant Watson By the Court: Date: Seal of the Court Prothonotary Deputy l;--'-_r . ., - f - ~" '- .-., , I ~ ., " {#r:MIr. VI ( In The Court of Co~on Pleas of ,.~,." ) ) 2 ) ) ) ) Cumberland County, ?ennsy1vania v. ~ eJS;S,/G $"" TIU+<tTH(~ h/IN/tSHIt: wI'rT~'" . ~€~~ ~/"/v I 70 ..3 tt ,4r:.,~',p - ~ J ~o. 01, U OATH will support, obey and defend Constit~tio~ of this Common- four-office ith fidelity. We do solemnly swear (or affirm) the Constitution of the United States wealth and that we will discharge the that we and the duties JlIt/ It"..,- t I%>soc., AWARD We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) -.- J I.(I)&.tIIFNT" 10M ~J~ d~ d~F~tf1~ TA.I9uTntAW. .::J1+I!I"mD./T /1.1 PrlrI'dA- dP ;t1l.;nlVn';;=.;:: y~ wlPT'So"; 01/ ,,Ht:. ~M/T ~ '2, 7 7~.7J i!I I':. A..,.;IJIll,L~,. 6JEF~II?~ ~/IIU ,~ ,,_ T ,,- 1l1U1I,." "~Il V ~ s.:o -,,- ~ ~ I, dOC> -A..... IJJuu_J hll:WI-,e& _ , lIT Dat.e of Award: {(-/~ -01 applicable. ) Dat.e of Hearing: II-II.. - 61 NOTICE OF ENTRY OF AWARD Now, the J(. ~ day of~ , .;1001, at. L}:31, lL.N!., the above award was ent.ered upon the docket and notice thereof given by mail to the parties or their at.t.orneys. Arbitrators' compensation to be paid upon appeal: $ :L 'J o. cro By: f"nr,;, fJ. p~ 1,,-- ~ ~roehonotary ~o.~ Deputy , , 'I 1-'""'l!1.~"~~ ,"~__ ., r, ""f''"''1- lil ~ w.~,01 1(~~~ ~ 'III (I ~ M"";":)+ ~. !?-. ~k~. J:i...tL. . ~ ~ C'f"; -& ~ //_11".0/ ~ ~ c,. /.2.0c..O( () ~ -0 $,~ rt1 0) .",fTl <---:0 Zr G0)> ::< -';.' cf.S j;;: ;::0 ~O ~c: ~ :v "....., c) _. (~. j -'1 ~ <) "'::: '",c" ,-;~ ......: -1-;- ?:!';;? -'~C) ...~,--: ~ r. ~~;? f~; 6.f"il C7\ ~-'< -. -"- "?,,: ::0 ...;; "" ,...,_.,."""~_~"",,"W ~,,_,=~liU!I~~~~!!!iW~~,~m;;~I'ia~Efiry.<'f-:"'-"L':O"",if1;;""''''AI:-',""," >V'F',_":!-,' "'';:;N~;'"'!W'''-;L'~~''''.?,'~~JJf''''P'~;1'_'''''''''f'-'~'-'*'ii<1~'''!'i1i~~mw~;;' [ fl Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CHONG YI, vs. NO. 01-1703 Civil Term DEBBIE SUE TRAUTMAN and MONIQUE WATSON, Defendants CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please mark the above action satisfied and the judgment paid in full. Respectfully submitted, ANGINO & ROVNER, P.C. BY~ David L. L z, Esquire Attorney I.D. # Attorney for Plaintiff 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 Dated:!vJv /-j ~ r- 01-177/32906-1 ~~-,~ .'" '-~:'"_~"1<".-_'J';Tt':_,_?'; ,., >>- "-' _w_~~I'" _'__I_;J__.~,-; - t!J . "-"";1"'00 p. _?J'H""",__<, ,__l ~ _" r~ ~. '"' () c- ~{i7 -' "" ~s: '-- 2: ;:._- );";'~~~ .... :::-i '"'~ r,,_"') CJ r"-J CJ' 1 ~~ !lI[:- ..4S.:S:l(~~i~~~~!'!'!J~~JmIlJ.ml\lj!l~~~~" c'.,,_. ::>~ 1":'::