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Home My WebLink About01-1711 FX ~',:>__>,-,+,~,-;1',; :~'&?c\", l~ :') -, >'i I':' '] I "~'1'o~ ,~ . , ELAINE M, MOHLER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, CIVIL ACTION - LAW AMANDA LEE MILLER, NO, 6' - /'11/ eUlt/~ Defendant JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF CUMBERLAND COUNTY:: Please issue a Writ of Summons against the Defendant, Amanda Lee Miller, who resides at the following address: Amanda Lee Miller 131 Marbeth Avenue Carlisle, PA 17013 and have the Sheriff of Cumberland County serve the same. Respectfully submitted, HANDLER, HENNING & ROSENBERG By: osenberg, Esquire Supr e Court I.D. # 20569 130 Linglestown Road P. . Box 1177 Harrisburg, PA 17108-1177 (717) 238-2000 DATED: .3 /.0 f /0; / I Attorney for Plaintiff ~~ "" ~.'~~ ""'''''='~''''~"'~ ~".,~, '",^,,^ ,.'= ~~ ~, _ ~.,= ,',....,-,.~r-"''' ""''''''' '", ... ".~"I,~"",'~",~", _, ."", .' _ . ~ , ,'=~ ~""_ -~ ~-;.*~kX;:,,:j(;1i,i," . Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ELAINE M. MOHLER, v. CIVIL ACTION. LAW AMANDA LEE MILLER, NO, Defendant JURY TRIAL DEMANDED SHERIFF'S DIRECTIONS TO THE SHERIFF OF CUMBERLAND COUNTY: Please serve the Writ of Summons upon the Defendant, Amanda Lee Miller, at the address listed below: Amanda Lee Miller 131 Marbeth Avenue Carlisle, PA 17013 Respectfully submitted, HANDLER, HENNING & ROSENBERG By: Dav." H Rosenberg, Esquire Su reme Court I.D. # 20569 1300 Linglestown Road P.O. Box 1177 Harrisburg, PA 17108-1177 (717) 238-2000 DATED: ,~/ d I ) ~! Attorney for Plaintiff , ,-,.""V,",,_ '< ?'~Cj-~_,~,,~, "it*'!r"__"':~''f'__ "'m~,,~r--"_''IT:~',W:''i'',"'P--'I~'''-'''__-_~€''I'_,~O).g,~_ ~""""~''''''~_'~^~'".'~ 17'''I.-R,~'~,~~ _, " ,_,',CF, _""'r"",,,_,, ,~_.~ . ,~'" ,~,~"~= ,,"= ._ ., __, ,.._ ,,__, __ ~~ _, ~ _ _ ""~ ~ .~,,~. ,,~,N ~_ '" i~r'~'- ".,"' ^ "", "'" ,.,-'-,,~ 'v ,'_, :'c":"' '~"x_",,-, >'-~''''''' ~." _'" 0"'""""'" ,~",', _,", _ _~~_ri~ __~. ._"""~.. "~ ,."",_~_~_ t (J ~ ~ 0 C) f~:-i l s: of :,,:,,>- -::t'" ~ utX' :r~ () nl]! ' :;.:1.) ~ ----;7.-,- ~ , z1.':" f'.) ~ 0 Vj (/) ,!::~ t'V "-.... -<:..< ':_)~~ -0 C D ~~~ .v ~ I - ;----:--J 6' ~--~ f') - ??- I/) r:- ,--'-'~ l~;' I t ..::- ~~j -, -' en :::0 .-< ~ --:< - - - ',,--~ "., ' ,-~,~, _ _i~~~r'~",,~~; .-' ",~iI'l!I!!f!!I~~"" 'IT'~ 11~_ ,.' _,,_;~~), .. #-. -,~"'.~ T" ,- Commonwealth 'of Pennsylvania County of Cumberland ElAINE M. MOHLER Court of Common Pleas VI. No. _______QJ.:-J,7);LC.iyj._~_'J:~!1tL_______ 19____ AMANDA LEE MIlLER 131 MARBETH AVENUE CARLISLE, PA 17013 In _ __ __ _ _ _G:j,.yj.J,,-J\.s:.i.:iQ[t__-:_~~_____________ __ Amanda Lee Miller To _____________________________________________ You are hereby notified that ._______~!~_~Q~_~~_~ll~~~_______________________________________________________________________ the Plaintiff haS commenced an action in _________CiYil_Al::.tiO!Lc:_Lrool__________________________ against you which you are required to defend or a default judgment may be entered against you. (SEAL) Curtis R. Long .~----------------------------------------------- Prothonotary Date ______~nm_~.?J__~Q.9L___ __ B~-2~-'2??~ Depu~:tC - I, ~," I > " I ,-, ~~J ~ -. - -~,-~'""~.~" ," -".~,',,~~""~' .,' .. ....m...._ ....ill1lffIJflrr~ '. , ,~ --f .,--"'" I ~ H -..I g: '1j1--' 0 In n~1 t>J . I-' . wlll ,..... P> W ~ O-..l1100~ I~ 11 ~ P> , . I Ii. Of-l- '..... ~ ..... , tv..... ~ 0. I~ ..... ~ 0. ::1 , =#:wC/] t-1 If) tIl P> (Jl 10 COO'x.....p:: lD~~ ,~ tv I ~ ::1. r :;: 'I Otv.E ~~ 'r!" ,~ lllO I-!f-I::O '....' r!" (Jl' '-..I > '" 0- -..I(JlO '0 ;g::>,~ ~ h-" \00 -..ItIltll '::1 ,~ g ;g r!"(Jl :>< . , ~ g. ~~~ ~ ~ 'n j -J CD' f-I (Jl '..... ~ (Jl i O::1(Jl 11 I~ -..I ::<l.E ~~11 ,..... ~ w(I) I~ 0 2 - 5' I co '>-3 I 0.t>J '(Jl ~ tIl !~ ~ ..0 -..I . , -..I ... '" , , , , ~t- );:('J I z~ ;g~jY ~: m: ~' . 0: VI; , -j' 6 ::{~ ~ ,m~j ~ 0 ~ . ~ ~J "I"""" ""'~ mJSII'jl!I~I_~L~'i'#1~"~"'''"",.~IlRlJii~'l'ff\-0'-\<''"''';!\l!l-'t'N1"I!i'P-~'~__'''';^\4'tli"'~h1""(!I~~r,1i'I!"'llW'illnr>-jJli111!ffl''''j''P4-,)r",'(;nl'2f'-li''_~'<IP""'~!\'~!"~J!\~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-01711 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MOHLER ELAINE M VS MILLER AMANDA LEE . R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT MILLER AMANDA LEE but was unable to locate Her in his bailiwick, He therefore returns the WRIT OF SUMMONS , NOT FOUND , as to the within named DEFENDANT , MILLER AMANDA LEE DEFENDANT NO LONGER AT THIS ADDRESS Sheriff's Costs: Docketing Service Affidavit Surcharge not found 18.00 3.10 .00 10,00 5,00 36,10 ~~~~ R, Thomas Kline Sheriff of Cumberland County HANDLER HENNING & ROSENBERG 05/11/2001 Sworn and subscribed to before me this I p~ day of 7k Aj .2tw ( A.D, () Q ~ A~d7} ~otary I "'-- 1'<;- - - 1 r 'I' - " < ~}" ~'- . . Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ELAINE M. MOHLER, v. CIVIL ACTION - LAW AMANDA LEE MILLER, NO, 01-1711 Defendant JURY TRIAL DEMANDED PRAECIPE TO REINSTATE WRIT OF SUMMONS TO THE PROTHONOTARY OF CUMBERLAND COUNTY:: Please reinstate the Writ of Summons against Defendant, Amanda Lee Miller, who resides at the following address: Amanda Lee Miller 1019 Redwood Drive Waynesboro, PA 17268 and have the Sheriff of Cumberland County serve the same. Respectfully submitted, HANDLER, HENNING & ROSENBERG By: DATED: & j(p / CJ / r , Attorney for Plaintiff ;:'" ,,"~ ^.. "":'-~r>~"a""''''''"_'_~_''-'~:-~"_''',~,<,''~_'' ,-""",,,~~_'""~_I~_"', ~ ,-,_',,,",1["=.."",.0< -c,_, ~,-,-,,"".'r_"" -" -"-, ~ &.~~__ "'''~~''=, _,_,~,,~ H_~ ",.. ,,__~ Leslie B. Handler, Retired W. Scott Henning David H RosenDerg jPA, FLJ Carolyn M. Anner (PA. NY. RNI Matthew S, Crosby {PA. NJ) Gregory M. Feather jPA. NJ) Stephen G. Herd Samuel Handler 11922-70) HARRISBURG OFFICE 1300 Linglestown Road Harrisburg. PA 171 JO 717-238-2000 1-800-422-2224 717-233-30291Iax) LANCASTER OFFICE 140A E King Street Lancaster, PA 17602 717-431-4000 ATTORNEYS AT LAW June 6, 2001 DIRECT MAIL TO: P,O. Box 1177 Harrisburg, PA 171 08 www.HHRlaw.com Rosenberg@HHRLaw.com Sheriff of Cumberland County CUMBERLAND COUNTY COURTHOUSE 1 Courthouse Square Carlisle, PA 17013-3387 Sheriff of Franklin County FRANKLIN COUNTY COURTHOUSE 157 Lincoln Way East Chambersburg, PA 17201 Re: Elaine M. Mohler v. Amanda Lee Miller Cumberland County No, 01-1711 INSTRUCTIONS TO THE SHERIFF Dear Sheriff Kline and Sheriff Wollyung: Please serve the Writ of Summons upon Amanda Lee Miller at 1019 Redwood Drive, Waynesboro, PA 17268. Should you encounter any problems in connection with the service of the Writ of Summons, please contact me immediately. Thank you for your cooperation in this matter. Very truly yours, HANDLER, HENNING & ROSENBERG By: DHR:nlb Enclosures ~ , ~ " ' \-, ~". - \ 'r, ,0 , ' . ~ ~(p n1'n__ _Q_," '"'l "='-" ~~ ~ ;."..... ; 0 0 0 C -T' s: '- .-\ -Pro c: f1~p rnlT. :;:;: Z::D I --.m zc "6 ~z -' ;_:~ r:;:c; -0 ~~-Ti 'i> 3: f5 ::a zQ -"?o -,CJ f':? ~-rT1 ;P'C S ~ 'J1 ~ (.> ;...;: ~~~1~ "!!oon~~~~_~_,"llP,,%~,,?",iF),,:'W,,'R"'-' '."'~"'W""f_"'EQ;'llW?;,W!W,""II-m~f"~f!r>'Pj~"'r-'"'''_'''f'~''~''!ff~j~~\o/'l\j:~:;I~!ti! m:\homelbqallitigatlstatefrmIMILLERlentryofappearance.wpd Draft#l June 28, 200-" Jeffrey E. Piccola, Esquire Supreme Courtl.D. #18018 Brigid Q. Alford, Esquire Supreme Court LD. #38590 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Amanda Lee Miller . ELAINE M, MOHLER, Plaintiff v. AMANDA LEE MILLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 01-1711 Civil Term : JURY TRIAL DEMANDED : CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE Kindly enter the appearances ofBrigid Q. Alford, Esquire, Jeffrey E. Piccola, Esquire and Boswell, Tintner, Piccola & Wickersham on behalf of Defendant Amanda Lee Miller. Respectfully submitted, By: Date: 1-1 J 9/0! , { Brigld Q Iford, quir Supreme Court LD. #38 0 Jeffrey E. Piccola, Esquire Supreme Court LD. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Amanda Lee Miller "~., .-,~ """-,~ "~~C'",:'--',",~7,,),'~;;'^".--_ ."'?-~~1tl?''i'_-i>_-'"__'''I'~' -'7-.,I"-""",--~,~",~',;,,-,,,^, "c<I'-I-"o,' '<fl __'-;,0" I__'-<_""_,_,,,~_ ,,,,,,-~,_ "_,.,_","",.,.~",, ,__" .~, ~~," .0" ,_=, ~_,,~ .- < , .. CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Praecipe for Entry of Appearance by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: David H. Rosenberg, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Post office Box 1177 Harrisburg, P A 17108-1177 Attorney for Plaintiff By: Brigi~d~Sq*^- Date: &b~k) ( I ' i'" ,,"' '-,' '. - '" ,- ~~~""",~",''J!':'';i'''''~''''~~-',',,'''"'q; "",~,;,-"",.",,-'I7~~'!,~I~-l ~;:,I!"'_, >)_:rl"",~'1'_t '~"_~" .,. ~_, 0' ~ ,,_ VN-T' ,~_~:=c -",,~ ',' .~, -r..' y~,-;_~,_,,"^" _ ,__ ~e ,'>''"1-'-'" ,'-," .,- '"- . "", "1" """" ,~~, ,,,,,.~,r- i!!IJ ~ I ''!'"~- "~- '-',"","^-- "_r,,,. ,_~, -", ~ ~, , --<,,~' ~ ~ ,,'= '.j"I'I-111 'I I ~I,lnmi ~r.~'!fjjiii"'nlr --'"" "",',,,"~"-''''''' "~,, -"'""""- ~lIn_lIlIIl_ I I ,. - () G ~~':" c, - (.: ;:~- c__ / --'i -,~~ " , '..- '"--,:; I C-~, , .. (J,"; m'lIMit~l~'~!jI~m^_,__,_,_,_"c~ ~ ,",:",",.l!!l*~ _~!KjJ;l~Ii!!-~!t1"" ," _,~,~~~~ .' , . . - - T~-<?""""~" - f ... SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-01711 P l COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MOHLER ELAINE M VS MILLER AMANDA LEE 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: MILLER AMANDA LEE but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of FRANKLIN County, Pennsylvania, to serve the within WRIT OF SUMMONS On July 30th , 2001 , this office was in receipt of the attached return from FRANKLIN Sheriff's Costs: Docketing Out of County Surcharge Dep Franklin Co 18,00 9.00 10,00 35.40 ,00 72,40 07/30/2001 HANDLER HENNING S.o a~d R~mas Klj(ne Sheriff of Cumberland County & ROSENBERG Sworn and subscribed to before me this (, <E::" day of 0 "j'ulr- ;L"." I A . D . G'(. O,~~oii... u"r.r U Prothonotaty "'t f-, U I ~ II ,', 'I "~ ~ ~-~'I""\' ... SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-00099 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN ELAINE M MOHLER VS AMANDA LEE MILLER ROBERT WOLLYUNG Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: MILLER AMANDA LEE but was unable to locate Her in his bailiwick. He therefore returns the SUMMONS , NOT FOUND , as to the within named DEFENDANT , MILLER AMANDA LEE Sheriff's Costs: Docketing Service AffidaVit Surcharge Mileage So answers: 9.00 5,00 4,00 ,00 16.82 35.40 CUMBERLAND COUNTY SHERIFF 07/18/2001 Sworn and subscribed to before me this day of M;-- '-' NOlanal Seal Patricia A, Stnne, Notary Public Chambarsburg 80ra, Franklin County My Commissior. t:xpires Nov. 4, 2004 ~, _J , '-'" r ~ ~ "~ " I, ~ T ~" f I '-I , . In The Court of Common Pleas of Cumberland County, Pennsylvania \ Elaine M. Mohler VS. Amanda Lee Miller No. 2001 1711 civil Now, 6/7/01 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Franklin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ,~~~ Sheriff of Cumberland County, P A Affidavit of Service Now, Julv 18 ,20~,at o'clock did not serve M. llltlntll:lli the within WRIT OF SUMMONS upon AMANDA LEE MILLER at 1019 REDWOOD DRIVE, WAYNESBORO, PA 17268 by handing to a copy of the original and made mown to the contents thereof. <<' -~-'-'-' .. .... .,..,,- ,-"""'~' (<,:::,1.,,(=:::' \-r""~ I ' , ! ~ ':, ~ J"' .~., So answers, ~L~PA COSTS SERVICE 14.00 $ MILEAGE 17.40 AFFIDAVIT 4.00 $ 35.40 Notarial Seal tricia A. Strine. Notary Public C mbersburg Boro, Franklin County My Commission Expires Nov, 4, 2004 '-'~1l!l~ "," 1"- .'1.....- 'II I , ' !""'1 ~." , ~ ~ ~~ ~~ .,~~,w "_- ,_~_ - 'f ... " TRUE COPY FROM RECORD kl rllltlmony whereof. I hereunto'. my hancI .. tile _ of said Court at CarIiskI. Pa. TMI ~ .~<-' '- /. ~/!J_ ;~ Commonwealth of Pennsylvania County of Cumberland ELAINE M. MOHLER Court of Common Pleas YlI. No, __nmQl-~J,7.nnG.!yj.).n'!'~mnhh__ 19____ AMANDA LEE MILLER 131 MARBErH AVENUE CARLISLE, PA 17013 In ________G!yj._l_~P~!QD__~_~~_______________ Amanda Lee Miller leo _____________________________________________ You are hereby notified that ._______~!~_~Q~_~~_~lll~r______________________.________________________________________________ the Plaintiff has commenced an action in __h__n.CiviLAc:.tiorL"_LaYi_hnn___nnnh____n__ against you which you are required to defend or a default judgment may be entered against you. \: "':.:;::':~:;-l '; } (SEAL) 1 ~ ! Curtis R. Long ----------------p~th~~~t;;y------------------- Date ______~r~IUl..L~Qgl.____ B~-2.-~ Depu~-'tC -... .:.,,-","-- -~",!~~ II] 1'- r -:~ ! I ~. I '" ~ -I~ 'T . - - --m--,n'r"" -, T~ lml rlilliiel""ll'~'llI't.li1l1il.lv' ''IIlr'if'--il l' rTTIii:l'il1\l1~(' rt'" .. ':' , I Z , H--']~'dl-'S? In nl-'f t<J , P I . I-' . LV ,f-'- P> W I-' , 0--.] OO~ .< I-! I-' P> , , . 111. 0- . 'f-" I-' f-'. . I IV f-" & p. II-' f-'. W 0, .... , , *WUl t-l (Jl P> ro 10 I 15' I 00 0' X f-'. 0:: I-'I-! .1-' , IV I ~ ::>. (l>0'f; ;s: " I o IV~ I-'<Q L-r r - (I> '1-' I U10 I-!l---l:;tl 'f-'- rt(l> '-J , 0'10... --..j(t), 0 '0 ;;;!::>"~ ~ II-' >' "'0 --.](Jl(Jl l::> ,I-' S: ;;;! rt(l> I I-'~r--: , ~g. 'I ~ I-' 'n 8: , ~ --.](1)1-' (I> 'f-'. I-' (I> li 0::>(1) I-! 1< ~i --.] ~~ I-'~I-! ,f-'- , I-' W(I> II-' , 0 o - I .. , , 00 ~t<J , Cl '8 I I I '(j) I I-' (Jl I ig I I , I-' ..0 , I --.] I , , --.] I - I I '" I I . , I , , I , I I , L Nil[' ~~ !iifiI CG !iifiI = ~ !iifiI ~--:,~IJ c. c ~ 'ftIN\tc17J" ::/";, 1_: .,)NN]d " ., '-{r. i t/ IOj Nd Oil e Alii"". 44/1I3HS' ...-, '1"1',' "J-, r- -. .~.;~nfiO ~!l ";l1~;JO ;i~~ o _~ ~ ~ ~,~ II , ,.IIl!ltlft~,_~" ''NpmH,~~~n~,~~_:!\'Ml~~Hml~'!l'~~'1,.~'$i'f'&;i-c'~C:'''-'-- - '; ,~. m:\home\bqa\litigat\statefrm\MILLERlrule to file complaint.wpd Draft #1 December 17, 2001 Jeffrey E. Piccola, Esquire Supreme Court J.D. #18018 Brigid Q. Alford, Esquire Supreme Court ID. #38590 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Amanda Lee Miller ELAINE M. MOHLER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 01-1711 Civil Term AMANDA LEE MILLER, Defendant : JURY TRIAL DEMANDED : CIVIL ACTION - LAW DEFENDANT AMANDA LEE MILLER'S PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Enter a rule upon the Plaintiffto file a Complaint within twenty (20) days after service of the Rule, or Judgment of Non Pros will be entered. Respectfully submitted, By: ~~.~ Brigid Q. ~lford, Esquir Supreme Court I.D, #38590 Jeffrey E. Piccola, Esquire Supreme Court I.D. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Amanda Miller Date: It' 1'1/0 1 -,~ , "~,~ ','--""'",~--~,,"-'~' """--'''''1-- '",:'c,._"" I " ,,'" " , , . "-. I-,_h ,0' ,; ~- . , " --,~ ,~ , ,';' " l .".",.., , Jeffrey E. Piccola, Esquire Supreme CourtI.D. #18018 Brigid Q. Alford, Esquire Supreme Court lD. #38590 BOSWEll, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Amanda Lee Miller ELAINE M. MOHLER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. : NO. 01-1711 Civil Term AMANDA LEE MILLER, Defendant : JURY TRIAL DEMANDED : CIVIL ACTION - LAW RULE TO THE PLAINTIFFS: You are ruled to file a Complaint upon Defendant Amanda Lee Miller within twenty (20) days after service hereof. Date: D(.~ l-g, ~oa I g~~'1 ..^ ,,,,,,,,,,,-_~',,,,q-;:,_T~M'i".:\",,_, ' , ,..,. "" ""'~ -I"?" ,- '-1--:-0,,- _'- -"~.._,,",,, "-' -'1 :-1' . ,< -, " "J ' ""~'" r ~<. " I" . , CERTIFICATE OF SERVICE I do hereby certify that I have served on this date a true and correct copy of the foregoing Defendant Amanda Lee Miller's Rule to File Complaint on the following by first-class mail, postage prepaid and addressed as follows: David H. Rosenberg, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Post office Box 1177 Harrisburg, PAIn 08-1177 Attorney for Plaintiffs Bri~~~~ Date: 'd-{ro(ul - ._n, "",_,~'_-o" ;'::" -d ,_~'-'''' "=~'''' ~'.~ 'I c . - . '-" _I -,.. o'n~'" _ _ '-,"~'~-': " '.' '<- """-1->">' '_.,-~", ~', ~ "t-" -T'_ , .' ".,-,- . 1""'-"""', ~ .,~ """'!>_"_'~=lr",., 0'"""_'_"""i:>'''~~''''~'''' ""~"_,,,,. ~'" aE -~'-I (i~ ',- , , < J,"~_~ ,I. ~',4,MJ_~~I!!!t C) ':~; C:"; ('~; 0) ,~~,) ~ ~::. ,~m!'l!!~,!Il!~ "~I''"-~'~-'''''r . ",Ill'-! -I!I'! \ . ELAINE M. MOHLER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 01-1711 Civil Term AMANDA LEE MILLER, Defendant : JURY TRIAL DEMANDED : CIVIL ACTION - LAW CERTIFICATE OF NOTIFICATION , I, I, Brigid Q. Alford, Esquire, do hereby certify that I served the Plaintiff Elaine M, Mohler with the Notice of Intent to Take Default Judgment, sending same by first-class mail, postage prepaid to it, at the following address: Elaine M. Mohler, Plaintiff C/O David H. Rosenberg, Esquire 1300 Ling1estown Road Post Office Box 1177 Harrisburg, P A 17108-1177 A copy of said Notice is attached hereto. BOSWELL, TINTNER, PICCOLA & WICKERSHAM By: ~2~' Brigid . A1ford,'Esqu' e Date: .z{13!o:L /] - . -' ,_,7~"~,_: _"r"~-~'~~'" ,,-_'_" .t'~"F","~,,__",~,'_I~"':--1 =,,", , . ~" "'>1'_'1' ,,'" n,'- - "..'- ',~ ' _,",C,_,_ .". -'--, ,"-,'-",",""'", ''8 , BTigid Q. Alford. Esquire Sllpreme Court 1.0. #38590 Jeffrey E. Piccola, Esquire SlIpreme Cowt lD. #18018 BOSWEll, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street p()st Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Amanda Lee Miller ELAINE M. MOHLER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v, . : NO. 01-1711 Civil Term AMANDA LEE MILLER, Defendant : JURY TRIAL DEMANDED : CIVIL ACTION - LAW IMPORTANT NOTICE TO: Elaine M. Mohler, Plaintiff CIO David H. Rosenberg, Esquire 1300 Linglestown Road Post Office Box 1177 Harrisburg, PA 17108-1177 DATE OF NOTICE: February 12,2002 You are in default because you have failed to file a complaint in this case. Unless you act within ten days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your right to sue the Defendant and thereby lose property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to fmd out where you can get legal help. Cumberland County Lawyer Referral Service 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 Date: .z1lljb"}" Respectfully submitted By: ~J ~ BrigId . Alford, Esqu' Supreme Court I.D. #38590 Boswell, Tintner, Piccola & Wickersham 315 N. Front Street Harrisburg, PA 17108-0741 (717) 236-9377 Attorneys for Defendant Millet .' "", "<;?'IT'it'ffl:"r-;""",,",,,,-,, ,,' ~__,e,_~_,"~ ,_ \< 'o~",,__ ,.0",' ,',,,~,' ,,,y," _, "_";"__' . - ,- 1 l' '!,:" _ --, '__"""':'~_',_r. _'''f '''.' ~_< , c'"'C""''','''' ___"~po ,,''^ _ ""~ "e ''''~''''~~'P,''''''''''~'..,".~ ."'.'- I Jeffrey E. Piccola. Esquire Supreme Court J.D. #18018 Brigid Q. Alford, Esquire Supreme Court lD. #38590 BOSWEll, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 74J Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Amanda Lee Miller ELAINE M. MOHLER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. . : NO. 01-1711 Civil Term AMANDA LEE MILLER, Defendant . : JURY TRIAL DEMANDED : CIVIL ACTION -LAW A: Elaine M. Mohler, PLAINTIFF FECHA DE NOTICIA: February 12, 2002 NOTICIA IMPORTANTE USTED NO HA COMPLIDO CON EL A VISO ANTERIOR PORQUE HA F AL TAD 0 EN TOMAR MEDIDAS REQUERIDAS RESPECTO A ESTE CASO. SI USTED NO ACTUA DENTRO DE DIEZ (10) DIAS DESDE LA FECHA DE ESTA NOTICIA, ES POSffiLE QUE UN F ALLO SERIA REGISTRADO CONTRA USTED SIN UNA AUDIENCIA Y USTED PODRIAPERDER SUPROPIEDAD 0 OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTA NOTICIA A SU ABOGADO EN SEGUIDA. SI USTED NO TIENE ABOGADO 0 NO TIENE CON QUE PAGAR LOS SERVICIOS DE UN ABOGADO, VA Y A o LLAME A LA OFICINA ESCRITA ABAJO PARA AVERIGUAR A DONDE USTED PUEDE OBTERNER LA A Y ADU LEGAL. Cumberland County Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 - ""0" "~":""''''''"'''''' ," "-,-"O',',,_~,_,^,~_ - '_ ,,~-'!"I "',__','~_!- .-', ,I ""._' _ ,~" __" J,_,,~, '- ,~" ~ " I~'" --,. ,~"'- _.~-- ,H,e,,', I: 0" _-, ,~'" _""",_-"N_ ", _1',_'" , ~-~ ,~.' , ,. '. ,,, "'C"'_'" - - ~ ~ 1lI ~, ~" " l'^~~W'''h,,- - '. <'''"~. '" ,.>^" ""--' ',-,' ,~.., ."; '''' a;;". ,.. ,--,0'~(~fJT:~f~l~_~'1i-"I'''.''! '~'''';'''-2~i;~V''<ti':',]t''~ ~, ciS L- ;:;:..- (" ~}_: ~ ~~; -( _(J~1l"!J,.w.\1Jl"~~I~ I <._H. ".-' r-.:, ',~! ~''1 ~-::J c,..) c- -' ~ ,> :q ~ tylj ~~~~,l 'F ,_1m ~r ",i5!. " , . ELAINE M. MOHLER, and her Minor daughters, MIRIAM and HANNAH MOHLER, by and through their natural parent guardian, ELAINE M. MOHLER, Individually Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 01-1711 v. CIVIL ACTION - LAW AMANDA LEE MILLER, Defendant JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint 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 Telephone (717) 249-6166 HANDLER, HENNING & ROSENBERG By: avid H R enberg, Esquire Counsel f, r Plaintiff I.D. # 2 69 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Date: ~~kO:t- '. , "-"'""'~'~~~'<"'~~""""7' ,~", ,,~"' '~_""_ _ "--",~ '<" ,,_ ".~,"~ ,"~ ",.__ ,~, __,1'__, .,_, _~_ ",~,_ '_~""" ,.' -- n_ , ", , \"'=' -1-' -",'.", <'-,- r,'. ~ ---~ ,", -~'~ .",,-~--- " " jjwlcomplaintslmvalmohler ELAINE M, MOHLER, and her Minor daughters, MIRIAM and HANNAH MOHLER, by and through their natural parent guardian, ELAINE M. MOHLER, Individually Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO, 01-1711 v, CIVIL ACTION - LAW AMANDA LEE MILLER, Defendant JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, Elaine M. Mohler, by and through her attorneys, -,1 ~ I :1 HANDLER, HENNING, & ROSENBERG, by David H. Rosenberg, Esquire, and makes this Complaint against the Defendant, Amanda Lee Miller, as follows: 1. Plaintiff, Elaine M. Mohler, is an adult individual currently residing at RR#1 Box 598, Sugar Run Road, Millerstown, Perry County, Pennsylvania 17062. Elaine M. Mohler brings this suit as a Plaintiff in her own right and also brings this action as natural parent and guardian on behalf of minor Plaintiffs Miriam Mohler and Hannah Mohler. 2. Plaintiff, Miriam Mohler was born on May 10, 1987, and is therefore a fourteen year old minor. She resides with her mother at R.R#1 Box 598, Sugar Run Road, Millerstown, Perry County, Pennsylvania 17062, 3. Plaintiff, Hannah Mohler was born on October 12, 1988, and is therefore a thirteen year old minor. She resides with her mother at RR.#1 Box 598, Sugar Run Road, Millerstown, Perry County, Pennsylvania 17062. 4. Defendant, Amanda Lee Miller, is an adult individual currently residing at1019 - . ., ~ -c' ~ ._ "~<'J",'_ ",~c, >~ ,., "':-'_'~,',"', Oy "-""'!'\'')-''',.__?'I!?'''",,",>,! ,~'"__'_,I",,"""__~_ >" ,'.> ' . ~ -_' .r_ "'~ 'I cvj '1 __", - . ,'1 'C', __r",_~ ~ .",,"^, ~,",-" ,,_._ c, ,P.-,C" ..-",+~",:"~",,,W^~d Redwood Drive, Waynesboro, Cumberland County, Pennsylvania 17268. 5. At all times material hereto, Plaintiff, Elaine M. Mohler, was the owner and operator of a 1987 Ford Taurus sedan bearing the license plate number PA JTA 400, that was insured by Erie Insurance Group, under which motor vehicle insurance policy Plaintiff was covered by the Full Tort Option, which was in effect on June 19, 1998. 6. At all times material hereto, Defendant, Amanda Lee Miller, was the operator of a 1990 Chevrolet Cavalier owned and insured by her father, Stephen E. Miller, bearing the license plate number PA BSM 0100, that was insured by State Farm Insurance Company. 7. On or about, April 3, 1999, at approximately 11 :24 am, Defendant's vehicle was immediately behind Plaintiff's vehicle heading north on State Road 35 exit ramp. Plaintiff's vehicle, in which Miriam and Hannah Mohlerwere passengers, was stopped and waiting to turn onto Market Street, State Road 2017. 8. At approximately that same time and place, Defendant failed to observe Plaintiff's vehicle and suddenly and without warning, the Defendant's vehicle violently slammed into the rear-end of Plaintiff's vehicle. 9. The aforementioned collision caused extensive property damage and was so severe that Plaintiffs, Elaine M. Mohler, Miriam Mohler and Hannah Mohler, required immediate and continuing medical attention. 10. As a direct and proximate result ofthe negligence ofthe Defendant, Amanda Lee Miller, Plaintiffs, Elaine M. Mohler, Miriam Mohler and Hannah Mohler sustained extensive injuries as set forth more specifically below. 2 :-ft ~, "!" '"_.'"" '_.".~~","=~',_."_..__~__,",_, __"-<_",."'~~~,~,~,,,___~<_~ ~'_~~"',_""'_,~ __'_'Of, _ _ ._~,"_,,~_" ^-._oC,"_,,'"~_" _~",.,._,",',,__ . ~- H _" . . -~ - COUNT I ELAINE M, MOHLER v. AMANDA LEE MILLER NEGLIGENCE 11. Paragraphs 1-10 are incorporated herein as if set forth at length. 12. The occurrence of the aforementioned collision and all the resultant injuries to Plaintiff, Elaine M. Mohler, are the direct and proximate result of the negligence, carelessness, and/or recklessness of the Defendant, Amanda Lee Miller, generally and more specifically as set forth below: (a) In failing to be reasonably vigilant to observe the roadway and the position of Plaintiff's vehicle; (b) In failing to operate her vehicle in such a manner that would allow her to apply the brakes and stop before slamming into Plaintiff's vehicle; (c) In failing to operate her vehicle under proper and adequate control so that she could have avoided striking Plaintiff's vehicle; (d) In failing to regulate the speed of her vehicle so as to prevent a rear-end collision; (e) In failing to operate her vehicle at a speed at which she could stop within the assured clear distance ahead; (f) In failing to maintain proper and adequate observation of the existing traffic conditions; (g) In failing to keep a proper lookout for vehicles lawfully on State Road 35 exit ramp; 3 iT", " > _~ .' ,. .."" '_"'_'''"__'''' ",<,,_" '" ',,,,,. " ", ,,0-':,_','1 ","_'''~_' _'~"",_"I',',_~",_ ,,,"" _-. ,_",,".,, '" r.r~,"'-- "..,' _ r,-" "I'",_",_"~,,' _ ''__'"^_,'. r-, _~___, ~">v .,-"" ." ,~", T_~",_",""""I"',",,_'=,~,,,,_'_" , ,] '1 "'1 1 '--j '::1 ;i (h) In failing to exercise reasonable care in the operation and control of her vehicle, in violation of 75 Pa.C.SA ~ 3714; (i) In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have her vehicle under such control that injury to persons or property could be avoided; and U) In driving her vehicle upon a State roadway in a manner endangering persons and property and in a manner with careless disregard to the rights and safety of others in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 13. As a direct and proximate result of the negligence of the Defendant, Amanda Lee Miller, the Plaintiff, Elaine M. Mohler, has suffered extensive and serious personal injuries, including, but not limited to, her neck, upper back, left hand and arm. Since being taken from the scene via ambulance to the emergency room at Sunbury Hospital, the Plaintiff, Elaine M. Mohler has been diagnosed with injuries including, but not limited to, a cervical strain/sprain, left somatic dysfunction, dorsal strain/sprain, and contusion of the left hand; a neck strain, cervicalgia, dislocations of cervical vertebrae, and constant and severe headaches. 14. As a result of the negligence of Defendant, Amanda Lee Miller, the Plaintiff, Elaine M. Mohler, has suffered lost wageslincome and will in the future continue to suffer a loss of income and/or loss of earning capacity. 15. As a result of the negligence of Defendant, Amanda Lee Miller, the Plaintiff, Elaine M. Mohler, has suffered great physical pain, discomfort, and mental anguish, and she will continue to endure the same for an indefinite period of time in the future, to her 4 ~ . ~> ".~._"~ ,.~_ " ~ .".~ __" ~ "'=_ ~~. _.".~_____,,_O,_._, '-ow <.<_. . ~ ,0''- '.~ _ ~~ _ - , ". great physical, emotional, and financial detriment and loss. 16, As a result of the negligence of Defendant, Amanda Lee Miller, the Plaintiff, Elaine M. Mohler, has been compelled, in order to effect a cure for aforesaid injuries, to expend large sums of money for medicine and/or medical attention, and will be required to expend money for the same purposes in the future, to her great detriment and loss. 17. As a result of the negligence of Defendant, Amanda Lee Miller, the Plaintiff, Elaine M. Mohler, has suffered a loss of life's pleasures, and she will continue to suffer the same in the future, to her great detriment and loss. 18. As a result of the negligence of Defendant, Amanda Lee Miller, the Plaintiff, Elaine M. Mohler, has been, and probably will in the future be, hindered from attending to her daily duties, to her great detriment, loss, humiliation, and embarrassment. 19. Plaintiff, Elaine M. Mohler, believes and, therefore, avers that her injuries are permanent in nature. WHEREFORE, Plaintiff, Elaine M. Mohler, seeks damages from Defendant, Amanda Lee Miller, in an amount in excess of twenty-five thousand dollars ($25,000.00) exclusive of interest and costs, and demands a trial by jury. COUNT \I MIRIAM MOHLER. bv and throuah her natural parent and leaal auardian. ELAINE M, MOHLER v, AMANDA LEE MILLER NEGLIGENCE 20. Paragraphs 1-19 are incorporated herein as if set forth at length. 5 , ,~,..op~ ____"..,,'"', <=-?,,_',_,_^ ,.;, ,_ "',~.., ,~ , ",,~, ,..,,- ,~<, ',' 1"<"_"',,\' "'~"""_ "'"~_, "'_'''',,,"," -," ,--f 'or.,', '_',." ,_"", , _. ,",0 H,,_L__ ~__~ ,"" . 21. The occurrence of the aforementioned collision and all the resultant injuries to Plaintiff, Miriam Mohler, are the direct and proximate result of the negligence, carelessness, and/or recklessness of the Defendant, Amanda Lee Miller, generally and more specifically as set forth below: (a) In failing to be reasonably vigilant to observe the roadway and the position of Plaintiffs vehicle; (b) In failing to operate her vehicle in such a manner that would allow her to apply the brakes and stop before slamming into Plaintiff's vehicle; (c) In failing to operate her vehicle under proper and adequate control so that she could have avoided striking Plaintiff's vehicle; (d) In failing to regulate the speed of her vehicle so as to prevent a rear-end collision; (e) In failing to operate her vehicle at a speed at which she could stop within the assured clear distance ahead; (f) In failing to maintain proper and adequate observation of the existing traffic conditions; (g) In failing to keep a proper lookout for vehicles lawfully on State Road 35 exit ramp; (h) In failing to exercise reasonable care in the operation and control of her vehicle, in violation of 75 Pa.C.SA S 3714; (i) In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have her vehicle under such control that injury to persons or property could be avoided; and 6 " -,-C'!~"'-__""~'_"""o__"^'/"~, ";.~,o,~''7''. __",,-,.' ,'I"''''"^'',~ ,__"..,,, I' _ '.. """.":"1J',--'6", ,'11_-"'_ ,-;_"~,r~'1 -'-""-~'''',' , - ^1' ,'-0" --. ,,, ,~.~" "" Y,.. ,~<"" -- ' "' '.., '_',"F.~.. "'0> U) In driving her vehicle upon a State roadway in a manner endangering persons and property and in a manner with careless disregard to the rights and safety of others in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 22. As a direct and proximate result of the negligence of the Defendant, Amanda Lee Miller, the Plaintiff, Miriam Mohler, has suffered extensive and serious personal injuries, including, but not limited to, her neck and back. Since being taken from the scene via ambulance to the emergency room at Sunbury Hospital, the Plaintiff, Miriam Mohler has been diagnosed with injuries including, but not limited to, dislocations in the first cervical vertebra, misalignment of the C3 and C1 vertebrae, neck strain, headaches and cervicalgia. 23. As a result of the negligence of Defendant, Amanda Lee Miller, the Plaintiff, Miriam Mohler, has suffered great physical pain, discomfort, and mental anguish, and she will continue to endure the same for an indefinite period of time in the future, to her great physical, emotional, and financial detriment and loss. 24, As a result of the negligence of Defendant, Amanda Lee Miller, the Plaintiff, Miriam Mohler, by and through her natural parent and legal guardian Elaine M. Mohler, has been compelled, in order to effect a cure for aforesaid injuries, to expend large sums of money for medicine and/or medical attention, and will be required to expend money for the same purposes in the future, to her great detriment and loss. 25. As a result of the negligence of Defendant, Amanda Lee Miller, the Plaintiff, Miriam Mohler, has not been able to act as a normal teenager and has suffered a loss of life's pleasures, and she will continue to suffer the same in the future, to her great 7 ,'," '-1 ','~'- ''''",,~_~!.,~_~~_~::,__'.r """"",~,_~-",>-"",,,,,,___,-, :,,'-":!"-f'''I'c~~'-'''<'-';' ;._'~,I,"'e'~',_,,", < :,P"'..'- ,," _ ~- I" t ' 'I! ':"~, -, <"."'. "'1" -, ~~,.-~_ ___', '~.'., < - ,. "_"',," ,,,- ,"- ,.' \~,,, '",_'" '_~" '"", '.r~__",", ',0" ." '-. V,_"_ detriment and loss. 26. As a result of the negligence of Defendant, Amanda Lee Miller, the Plaintiff, Miriam Mohler, has been, and probably will in the future be, hindered from attending to her daily duties, to her great detriment, loss, humiliation, and embarrassment. 27. Plaintiff, Miriam Mohler, believes and, therefore, avers that her injuries are permanent in nature. WHEREFORE, Plaintiff, Miriam Mohler, seeks damages from Defendant, Amanda Lee Miller, in an amount in excess of twenty-five thousand dollars ($25,000.00) exclusive of interest and costs, and demands a trial by jury, COUNT 11/ HANNAH MOHLER. by and throuah her natural parent and leaal auardian. ELAINE M. MOHLER v. AMANDA LEE MILLER NEGLIGENCE 28. Paragraphs 1-27 are incorporated herein as if set forth at length. 29. The occurrence of the aforementioned collision and all the resultant injuries to Plaintiff, Hannah Mohler, are the direct and proximate result of the negligence, carelessness, and/or recklessness of the Defendant, Amanda Lee Miller, generally and more specifically as set forth below: (a) In failing to be reasonably vigilant to observe the roadway and the position of Plaintiff's vehicle; (b) In failing to operate her vehicle in such a manner that would allow her to 8 -', c , -~_ " ,. ~^_ _ ~ ~'",'" '__,~" ,,-,~ __,,, ,_, "",~"'1c~~'" ,,~.-__", ,,,"_"-' "".. ~, ~ _. 'I" _<, ~ ,'" I~' ___ " '_,"" ->'","-'_'0 '_' "" ..._~,...,,- _<., ^' 'r_'." ,~ "'::>r"" ''''-'''<~'.-".", ,",_"~ ..,,"~ ~- ,., ,,__""', -,,,.,.- <, ,," ,-p-<< apply the brakes and stop before slamming into Plaintiff's vehicle; (c) In failing to operate her vehicle under proper and adequate control so that she could have avoided striking Plaintiff's vehicle; (d) In failing to regulate the speed of her vehicle so as to prevent a rear-end collision; (e) In failing to operate her vehicle at a speed at which she could stop within the assured clear distance ahead; (f) In failing to maintain proper and adequate observation of the existing traffic conditions; (g) In failing to keep a proper lookout for vehicles lawfully on State Road 35 exit ramp; (h) In failing to exercise reasonable care in the operation and control of her vehicle, in violation of 75 Pa.C.SA !:; 3714; (i) In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have her vehicle under such control that injury to persons or property could be avoided; and U) In driving her vehicle upon a State roadway in a manner endangering persons and property and in a manner with careless disregard to the rights and safety of others in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 30. As a direct and proximate result of the negligence of the Defendant, Amanda Lee Miller, the Plaintiff, Hannah Mohler, has suffered extensive and serious personal injuries, including, but not limited to, her neck, back, hip and chest. Since being taken from 9 ,- 1,; ~I -.[, -"'" "',_ '''',''''''-'0'-''''''', ~ '-"''''''',,' _p ,.-.>1'>"'_ '_~~~~~"'_ 'I,.. -''x',,,, ,,",,,,,,, "_""~ ,-' 1',"--' " - _ "-'-, '-"7' '_'-"1_" ,-, _",',<_""._,.",,",'_c '" -_c, _""'" _,_,,, '" v '_'.,,_~~,' _ ~ ,"" ,~-'" -,,__, .,~~ <__ ',~" ~~, , ~ "" '" ' the scene via ambulance to the emergency room at Sunbury Hospital, the Plaintiff, Hannah Mohler has been diagnosed with injuries including, but not limited to, dislocations in the cervical vertebra, cervical radiculitis, misalignments of the C1, T1, T8 and T12 vertebrae, misalignments of the right hip, headaches and neck strain. 31. As a result of the negligence of Defendant, Amanda Lee Miller, the Plaintiff, Hannah Mohler, has suffered great physical pain, discomfort, and mental anguish, and she will continue to endure the same for an indefinite period of time in the future, to her great physical, emotional, and financial detriment and loss. 32. As a result of the negligence of Defendant, Amanda Lee Miller, the Plaintiff, Hannah Mohler, by and through her natural parent and legal guardian Elaine M. Mohler, has been compelled, in order to effect a cure for aforesaid injuries, to expend large sums of money for medicine and/or medical attention, and will be required to expend money for the same purposes in the future, to her great detriment and loss. 33. As a result of the negligence of Defendant, Amanda Lee Miller, the Plaintiff, Hannah Mohler, has not been able to act as a normal child of her age and has suffered a loss of life's pleasures, and she will continue to suffer the same in the future, to her great detriment and loss. 34. As a result of the negligence of Defendant, Amanda Lee Miller, the Plaintiff, Hannah Mohler, has been, and probably will in the future be, hindered from attending to her daily duties, to her great detriment, loss, humiliation, and embarrassment. 35. Plaintiff, Hannah Mohler, believes and, therefore, avers that her injuries are permanent in nature. WHEREFORE, Plaintiff, Hannah Mohler, seeks damages from Defendant, Amanda 10 ~ ~,' -, ,^~."____~,~,>~~,~ "~""."'~',~,,~I ~.,.~,_ot =, *~, ~,_...""",e_." . < "",_",,""'_~__""," _~.,",,__~'"_'_~~ ,__~ '^"'__,',~ ~~u, _~~_ _ Lee Miller, in an amount in excess of twenty-five thousand dollars ($25,000.00) exclusive of interest and costs, and demands a trial by jury. Respectfully Submitted, HANDLER, HENNING & ROSENBERG Date: j-J.-I ~j)- By avid H. Rosenberg ID # 20569 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiff ..< 11 ,1 ;'1 f --,~ ,;., '-- -,~, 7'~"'_~"".',, '''''___v~ .0;...."'"","". __ ".--1 "_,,, ,', 'Tr~"5'r', ,. n,,,",_ ,,~.~ .~" 1"_'"1 "_"__.,'1"".. -''''',~ - -_ ".-->I'-"-~ ."" ~,,," ' ^""' ,___~, '-<<:'. ,,__,,=__ - " .'" .'. --~,"',,' "',>,-., ,,--. , VERI FICA TION The undersigned hereby verifies that the statements in the foregoing document are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the document is of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the document are that of counsel, I have relied upon my counsel in making this Verification. The undersigned also understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: b2~)-/-O~ By:~>n M~ I Elaine M, Mohler '~'- " ,~ ,~-"..=, ,._,,,~.-~ ,- -",.-=.::;>--, ,c,~~, ",I-"'-<"~,"7~"'n",.....,'" ,,"'~'.., -,_ .'-1-'-1_, '_-N. " ',_"'__,_-, <_ ^" , ,~." ., ~,_, _ ..,,,_0 _.,~" ' - ~'~",-- ._~ -- . ' . c ! CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the Defendant, Amanda Lee Miller, by sending a copy of the same to his counsel of record, Brigid Q. Alford, Esq. , BOSWELL, TINTNER, PICCOLA, & WICKERSHAM, 315 North Front Street, Harrisburg, PA 17108, by United States Mail, regular service, in Harrisburg, Pennsylvania on February 21,2002. Respectfully submitted, HANDLER, HENNING & ROSENBERG By: David osenberg, Esquire Cou el for Plaintiff I.D. # 20569 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Date: ).-:JI- ():r- 'Ii 'i :'), 'I y :i~ .;', ~C_ '7 _%.. _',', _~ ~ ,_,~"""~"~_~ '" '"~ _,__ ,~,,~ ,__~ "_"~~",~ o_~ '_" _ ","",,,~,_ "_' ,",.1.-"" ",-', , ,,~,"""'~"" ,_ 4,~ "" I~_I' " ~.,",v' ,'" "' _""",'" '"<, _,' '," __ '" _ "'_.. _~ _~,~ ~"~ _ ~._ _.. ""--~'---,." -. --~=< -. .. ,~"' , iI<I z.{; f_'" >.,,- c'~ _;<C"'~,.-' '~__", ,-""".""",-",;.",'-' ,., I "7". Il" - -- -'<"lnrrmm'flii''i'" "l"-''1i " ... , ,,/ )> ~-~. S! ~ (", ,~-- " " t,.) ::::1 -< ~il"J,<~~, IIIII! '~~"-~'?~ ' !>1(\O!,~~Ifl'"_,,o ~~~-" ~"d .1_"" ELAINE M, MOHLER, and her Minor daughters, MIRIAM and HANNAH MOHLER, by and through their natural parent guardian, ELAINE M. MOHLER, Individually Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO, 01-1711 v. CIVIL ACTION - LAW AMANDA LEE MILLER, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE On the 21 st day of February, 2002, I hereby certify that a true and correct copy of Plaintiff's First Request for Production of Documents and Plaintiff's First Set ofInterrogatories were served upon the following by United State mail, postage prepaid, addressed as follows: Brigid Q. Alford, Esquire 315 North Front Street POBox 741 Harrisburg PA 17108-0741 HANDLER, HENNING & ROSENBERG By ~.~ ;-~---: _M ___" . ~ -,'~~,~ .~~= Oi!'j "" c, ~. "'<'~d>' p ""''',~''"'LlllhrUr] ,< rll[iIllIIiI!lrl'''''im"''lI(''"~; -n []J, >-:'1- ,~; .' ~ ~: ;;-, :tJ %r " " ..."" ',~,,,,,-~$~~",, !,?_~mi'!l!l~~,""~","",I'l~,~,, Brigid Q. Alford, Esquire Supreme Court LD. #38590 Jeffrey E. Piccola, Esquire Supreme CourtLD. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Amanda Lee Miller ELAINE M. MOHLER, Plaintiff v. AMANDA LEE MILLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 01-1711 Civil Term : JURY TRIAL DEMANDED : CIVIL ACTION - LAW NOTICE TO PLEAD TO: Elaine M. Mohler C/O David H. Rosenberg, Esquire 1300 Linglestown Road Post Office Box 1177 Harrisburg, PA 17108-1177 You are hereby notified to file a written response to the enclosed Answer of Defendant Miller to Plaintiff s Complaint with New Matter, within twenty (20) days from service hereof or a judgment may be entered against you. Date :3(11I{0).- '~-" ,~,- - ,.~~^~--,-~," .~, ," ~ "'~~""-' ,,",.~"",,"" BOSWELL, TINfNER, PICCOLA & WICKERSHAM ~2~ Brigid Q. ~d, Esqui By: _, ", .__ _, "~_ '0',' _, ", ' " ", ._,,'~ ~,' ,,, -1'-."_ ',_ "e m:\home\bqa\litigat\statefrmIMILLERIANSWER NMT.wpd Draft #2 March 14, 2002 Brigid Q. Alford, Esquire Supreme Court lD. #38590 Jeffrey E. Piccola, Esquire Supreme CourtLD. #18018 BOSWEu., TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg. Pennsylvania 17108-0741 Attorneys for Defendant Amanda lee Miller ELAINE M. MOHLER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. : NO, 01-1711 Civil Term AMANDA LEE MILLER, Defendant : JURY TRIAL DEMANDED : CIVIL ACTION - LAW DEFENDANT MILLER'S ANSWER TO COMPLAINT WITH NEW MATTER Defendant Amanda Lee MilleT, by her attorneys, Brigid Q. Alford, Esquire, and Boswell, Tintner, Piccola & Wickersham, answers Plaintiffs' Complaint, as follows: 1. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 1; proof thereof is demanded. 2. Defendant is without knowledge or information sufficient to form a belief as to the truth ofthe allegations set forth in Paragraph 2; proof thereof is demanded. 3. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 3; proof thereof is demanded. !,~, r' _ -" ";,-~~~::"",,_,,,_,>< ,'""',,, ",,'~ -"C' ---,",,~_~'(_':"',I"__"" . "~~I'r,'",,:", "-"---,,,':',,,c"?-~,:-'j--=-, "P.' 7'- =1-',""" """, ,_",., _," ., ,~ '-',' "','1""""" 4. Denied as stated; Defendant Amanda Lee Miller is now married and uses the name Amanda Lee Lombardo, and currently resides at 3032 Cook Road, Fayetteville, P A 17222. 5. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 5; proof thereof is demanded. 6. Admitted. 7. Admitted. 8. Denied as stated; Defendant did not fail to observe the Plaintiff's vehicle, nor did she "violently" slam into its rear end. 9. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 9; proof thereof is demanded. 10. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 10; proof thereof is demanded. ANSWER TO COUNT I Elaine M. Mohler v. Miller Nel!lil!ence II. Defendant incorporates herein by reference her answers to Paragraphs 1 - 10, above. 12. Paragraph 12 sets forth a conclusion oflaw to which no response is required. Should a response be deemed required, Defendant Miller: (a) Denies that she failed to be reasonably diligent to observe the roadway and the position of Plaintiffs vehicle; -2- '",.,,-'': ,.^.~ _~'.",,~~".~.0 y_,~.~_:<; "~' ,~",_";>7'k;""'':'''':-''''1'''~'~I'f_h'':',, '.-': '''":_ J ?:""'-'-""lc' c .' ,,- ---_,.''? ,,' ", 'C 1__ I """I,' ,,,, 1 - '":T:" _ "-._", "~., F '", . 1 (b) Denies that she failed to operate her vehicle in such a manner that would allow her to apply the brakes and stop before slamming into Plaintiff s vehicle, and denies that she "slammed" into Plaintiffs vehicle; ( c) Denies that he failed to operate her vehicle under proper and adequate control so that she could have avoided striking Plaintiff s vehicle; (d) Denies that she failed to regulate the speed of her vehicle so as to prevent a rear-end collision; (e) Denies that she failed to operate her vehicle at a speed at which she could stop within the assured clear distance ahead; (f) Denies that she failed to maintain proper and adequate observation of the existing traffic conditions; (g) Denies that she failed to keep a proper lookout for vehicles lawfully on State Road 35 exit ramp; (h) Denies that she failed to exercise reasonable care in the operation and control fo her vehicle, in violation of 75 Pa.C,S.A. 3714; (i) Denies that she failed to be continuously alert, failed to perceive any warning of danger that was reasonable likely to exist, and failed to have her vehicle under such control that injury to persons or property could be avoided; and G) Denies that she drove her vehicle upon a State roadway in a manner endangering persons and property and in a manner with careless disregard to the rights and safety of others in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. -3- .'-01 ^ "-"'-,>:'~:,::7'.,?'~"-';";';". ""f_-,'-: '"' "", , '- . "..I-~' -,'.- "'" '91:1,_. -""""-~'" .:-~" '-"-"-';,,'r '-" "''''1" -1- -' -,'" ' ,'- ---, "' I" '^' ," '_ "-':;2 -'C' o'---''',,!--_ ,'-'~' -'.'",,~ ~,"'" ~'" <", ~- -, "'I' '-" 13. The allegations as to negligence set forth conclusions oflaw to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 14. The allegations as to negligence set forth conclusions of law to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 15. The allegations as to negligence set forth conclusions oflaw to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 16. The allegations as to negligence set forth conclusions oflaw to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 17. The allegations as to negligence set forth conclusions of law to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 18. The allegations as to negligence set forth conclusions oflaw to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 19. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 19 as to what Plaintiff "believes;" the same are therefore denies and proof thereof is demanded. -4- 1.'",_ " ,< -~- -''''''''~''''''_~',~'''fh''''_'__-,-~?,,, - -,,,,,,,,~,,_,,:,, _"-c_' " , I" ' "" '~~~I, <-_~"'~~_~"~_C=~T'i''''~ "' ~'f-:- ," '" """",,"u__ "__~O I-__~_~,,"'_,'""__~ ,,,, ,,_ ',""" ," ,~_ -' __"'" > "TH ~" , ?" ,',--" ~' - ",_'1< " , WHEREFORE, Defendant Miller requests that judgment be entered in favor of the Defendant. ANSWER TO COUNT II Miriam Mohler. bv and throul!h her natural Darent and lel!all!uardian. Elaine M. Mohler v. Amanda Lee Miller N el!lil!ence 20. Defendant Miller incorporates herein be reference her answers to Paragraphs 1 - 19, above. 21. Paragraph 21 sets forth a conclusion oflaw to which no response is required. Should a response be deemed required, Defendant Miller: (a) Denies that she failed to be reasonably diligent to observe the roadway and the position of Plaintiffs vehicle; (b) Denies that she failed to operate her vehicle in such a marmer that would allow her to apply the brakes and stop before slamming into Plaintiff's vehicle, and denies that she "slammed" into Plaintiffs vehicle; (c) Denies that she failed to operate her vehicle under proper and adequate control so that she could have avoided striking Plaintiffs vehicle; (d) Denies that she failed to regulate the speed of her vehicle so as to prevent a rear-end collision; ( e) Denies that she failed to operate her vehicle at a speed at which she could stop within the assured clear distance ahead; (f) Denies that she failed to maintain proper and adequate observation ofthe existing traffic conditions: -5- ":1 ,_, ^, "-":'<'"''''c''-'''~'''''',Y''' ?,">.- '1,'".','.' ,~ "-, '''"1-;:;:: ",,,-c_,, "oc,'=I",h ."- ,,-,- ,"_,~" ,', ~ "'I, -,.. ,,-- ,-,,:~, -+ ' __c__' . y_" ,_ ~.,' ,~,_\ ~,. ',1 ," , . (g) Denies that she failed to keep a proper lookout for vehicles lawfully on State Road 35 exit ramp; (h) Denies that she failed to exercise reasonable care in the operation and control of her vehicle, in violation of 75 Pa.C.S.A. 93714; (i) Denies that she failed to be continuously alert, failed to perceive any warning of danger that was reasonable likely to exist, and failed to have her vehicle under such control that injury to persons or property could be avoided; and G) Denies that she drove her vehicle upon a State roadway in a manner endangering persons and property and in a manner with careless disregard to the rights and safety of others in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 22. The allegations as to negligence set forth conclusions of law to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 23. The allegations as to negligence set forth conclusions of law to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 24. The allegations as to negligence set forth conclusions of law to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 25. The allegations as to negligence set forth conclusions oflaw to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. -6- , ~"" ~-:"'-'-~,_'Wt'"'''!_''_''' 0'_ ,,<,,'-..,"",' ,_, ,'''''~'~ ",~'''',~Il'"ro~~,.."", I' ~,__.."._">.'.,',o ."",,,' ,N~ _ '<',I ,_, _ .,W__" >, '-'1_=__ <. "'. ,,_8 '-'-'''"''''':'', ,'.. ._~, , 'I 26. The allegations as to negligence set forth conclusions oflaw to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 27. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 27 as to what Plaintiff "believes;" the same are therefore denies and proof thereof is demanded. WHEREFORE, Defendant Miller requests that judgment be entered in favor of the Defendant. ANSWER TO COUNT III Hannah Mohler. bv and throul!h her natural narent and lel!all!uardian. Elaine M. Mohler v. Amanda Lee Miller Nel!lil!ence 28. Defendant Miller incorporates herein by reference her answers to Paragraphs I - 27, above. 29. Paragraph 29 sets forth a conclusion of law to which no response is required. Should a response be deemed required, Defendant Miller: (a) Denies that she failed to be reasonably diligent to observe the roadway and the position of Plaintiffs vehicle; (b) Denies that she failed to operate her vehicle in such a manner that would allow her to apply the brakes and stop before slamming into Plaintiffs vehicle, and denies that she "slammed" into Plaintiffs vehicle; (c) Denies that she failed to operate her vehicle under proper and adequate control so that she could have avoided striking Plaintiff s vehicle; -7- ., ':'~~-,5""i-0'~;:''''''0,-,'' _ ", ~ ",,,;,, ""0'" ,~- -' ,-",", '~_~i"~":' ;l:I'~_:" 'u~W,t-l?-'" V~~-'3, ',>?_P"'c, -,.,.".~_ - ~ :'I-~', ";--.1-';'1-" ,':- ,,',' '"", "-',,'1' ',-~ '_~~"","~""?__"_"- ,."','Yc__~'--' ." ,"'" ,e' H'_ ~", ,'=__ ~'''' """ ~ _ I ' "'" (d) Denies that she failed to regulate the speed of her vehicle so as to prevent a rear-end collision; (e) Denies that she failed to operate her vehicle at a speed at which she could stop within the assured clear distance ahead; (f) Denies that she failed to maintain proper and adequate observation of the existing traffic conditions: (g) Denies that she failed to keep a proper lookout for vehicles lawfully on State Road 35 exit ramp; (h) Denies that she failed to exercise reasonable care in the operation and control fo her vehicle, in violation of 75 Pa.C.S.A. 3714; (i) Denies that she failed to be continuously alert, failed to perceive any warning of danger that was reasonable likely to exist, and failed to have her vehicle under such control that injury to persons or property could be avoided; and G) Denies that she drove her vehicle upon a State roadway in a manner endangering persons and property and in a manner with careless disregard to the rights and safety of others in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 30. The allegations as to negligence set forth conclusions oflaw to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 31. The allegations as to negligence set forth conclusions of law to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. -8- , -~ :- '(-';:"'-~ ""~'".t,~c,,',~~"c.Hl--S"-" ~"";'-'(!H",",,., c, ','" I:','; "'V1';:~_"~'I"',o _, -~"'"'1' 'y"," }e ,,^,_, ,",,'- I, '1'_-."'"__,,,__ ,~1" ,', _'." c' c_~-I'"_'_' "-. ,,-<C<, ,c _,,",~ ," ':'-~ "",. ,-,", ".., ,.. ~",- ,_ _ ',_" I . 'l' ' . 32. The allegations as to negligence set forth conclusions oflaw to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 33. The allegations as to negligence set forth conclusions oflaw to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 34. The allegations as to negligence set forth conclusions of law to which no response is required. As to the remaining allegations, Defendant Miller is without knowledge or information sufficient to form a belief as to the truth of those allegations; proof thereof is demanded. 35. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in Paragraph 35 as to what Plaintiff "believes;" the same are therefore denies and proofthereofis demanded. WHEREFORE, Defendant Miller requests that judgment be entered in favor of the Defendant. NEW MATTER 36. To the extent that Plaintiffs have sustained any of the injuries alleged in the Complaint, Defendant avers that, in whole or in part, such injuries were not causally related to the motor vehicle accident at issue. 37. Pennsylvania's Comparative Negligence Statute bars Plaintiff Elaine M. Mohler's claims. -9- "-~ '-' ~? - "''",'c__'"__",!","",, ~'.' ___'-~""i~-i-l'" ,'Co_ '-""."",'1'""',) ,,-7 ,I,' 'C.. _ --",-">H~',,'- _"','.,ti, ',-"" ,,~, '_~ r__,' ,-wr-I~~"~'~,""'-' -, <"'_ .., <I ."" ,<"; "'c," ',"",,>,, L^", ~,.."'~,~",,, ,,,,.,,,, '\ '. ' .",.. Tl . WHEREFORE, Defendant Miller respectfully requests that judgment be entered in favor of the Defendant. Respectfully submitted, By: Brigid . Alford, Es ire Supreme Court ill 8590 Jeffrey E. Piccola, Esquire Supreme Court ill #18018 Boswell, Tintner, Piccola & Wickersham 315 North Front Street, Post Office Box 741 Harrisburg, PA 17108-0741 Attorneys for Defendant Amanda Lee Miller Date: '(14/01- ( " ; , -.! '" !,_ -,,~,',,"'y;7_' ,-'~;.,-,7.c, .. _.',"" 1>", "~', ,~ -, 'f!),'~ -,"'I r,- ",,,,,,_,,,-_,,.,,,1.,,,,.- ",." cc,-~' '_,r,,__; >:-_, ,__I', r -;" ~ v -"',, ,.., 'h___ -,,,0, -'. ~"!'>"'"''''' _, -". ,~__ ~"~ ",_":;-, ' " ---< I' 1'" . VERIFICATION Brigid Q. Alford, Esquire, being duly sworn according to law, deposes and says that she is the attorney for Defendant Amanda Lee Miller, that said Defendant cannot make the verification to the foregoing Answer with New Matter to Plaintiffs Complaint because Defendant Miller's verification cannot be obtained within the time allowed for filing, and that the facts set forth in the foregoing are true and correct upon her personal knowledge, information and belief. ~:z~ B gid ,Alford Date: :J/10;L :)~"",J;.-_" -~,. ";>~,>'-,-_. -,,,~ -"-'~-"'~,~,.",.,.<_ ""~-_'" - -~~~,~ ,,," _, _^".~~,I,_", .-, ~""~,!, I ",",_""" "'_"'""?''''''''_O;';c~,"-_,,-~,'I'''1,' ,'v"-, ~"" ,-, ~ ", ,I"",,,',~, ~,--;-' F' ,_'_""'''''.. ,~,,,, ",_, ,'" ',__,____ '-'_.,' ',". _, _,_, C -r," ~ _ , ,~w. -~, ____ . . CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Defendant Miller's Answer to Complaint with New Matter by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: , 1\ David H. Rosenberg, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Post Office Box 1177 Harrisburg, P A 171 08-1177 Attorney for Plaintiff J" By: Bri~(/;ro. ~ , \'1 Date: '7{'1D?- ii I " < -, -" ,- "',- . >'(-"~,1'C<n-m_'~_,_^j-."""",~~",'""':i_,_,,~ ~ ""_~',,,"_'~',!'I' _ ..~",~~~I -, ~~ c- ;=;w,,~ , -c_, ,,-~~r, , ''1-<--1 ," _",:_ ~"'''_' ~"_'\_~I"-io-"'-1~"_,.. ,. '-'-'_,_ " :.' '~"f,,'~'- 0;:-,\ 'J,"_~_ 'T/ -'c" _. ".,. ,,,, -.- --c, I - ,- ~ -,_,'._ ,-~< ' . - ',"""" ill ~ -,,-" ,-" .":" , -" ,.~~" ~,,'~ '-"'" '~,'.."~a_ >,,,,.~,,,< >~~ 1iIllI-~1",~I~~_, ~i~~~,'!\f~, " '" , " .' "ilf:itOirlFt "O>'^]'jilUillTJI i [11.:" , . C~;i"l; Ch '--- r:::tj ~\~ ':'j -< c' C.--: :~:-. ~-::1 '---, , . ;':,-. ()" :::::1 c'.;.~ =< ::J Iv ....1ll!i~l("""'T',~,_~." '~P"'-, Jt~-'j , ELAINE M, MOHLER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO, 01-1711 CIVIL AMANDA L. MILLER, CIVIL ACTION - LAW I', ~j ~, ,: ;,I; Defendant JURY TRIAL DEMANDED it, ~: PLAINTIFF'S REPLY TO NEW MATTER ~,j . .: " AND NOW, comes the Plaintiff, Elaine M. Mohler, by and through her attorneys, J iL HANDLER, HENNING & ROSENBERG, LLP by David H Rosenberg, Esquire, and responds as l" ~j " )' ;J follows: . ,,:, I,' 36. Denied. This is a legal conclusion which requires no answer; however, if an answer was required then this averment is specifically denied. 37. Denied. This is a legal conclusion which requires no answer; however, if an answer ([:: was required then this averment is specifically denied. WHEREFORE, Plaintiff respectfully requests that judgment be entered in favor of :i ~ .. the Plaintiff.. Respectfully Submitted, Date: 3!ulw HAND~, HENNING & ROSENBERG, LLP By: (; R- David H Rose erg, Esquire J.D. No. 205 9 P.O. Box 60337 Harrisburg, P A 17106 (717) 238-2000 Attorneys for Plaintiff ,,^-., '" ,"-- _o~, ,On ,_? ,,_ ."._",~.c, ,""i." ,." <*- "_'" ,''j'~c._I_,,,..__,,,,.._,.,!;J''>_I_, .. ,"_~"'''~~~~- ~ ;""'" __ .._~,' t_n,I""" 'e,' '_" ~<~"__"'"",I~' "'.. '? __,_~_,_.~,_" _~. . _ ___, _" _.,.,_, ~_"_ ,..,' , __, ,~_;-< C->"-'_>" ~=, ~___ . ~ ~,~_ .,,,., "" , -,' ~ ::0' , ,~ ."" -, "'''''''c. &:,,"--,' .~, '~"'<4;"'>'W'""-lllU'-~ ~,,~, n:rr-l"rrifr>'-~'c 'i~'t~if~';f., ~ -I'" .:: C{:__.' L (;~ - r- -.-'- " -. ,~,-. ,-~" T" .1~~~~!illf!l~~~~1MJiI'JI!;IIl,JIIl:l""""'~fJ,t'; ~. ',,:-:1 c,) ,"..) ::J ',' ;'.) :,) _to 01- I~II Ciu~l't-~ CERTIFICATE OF SERVICE I hereby certifY that a true and correct copy of the foregoing document was served on the Defendant, AMANDA L. MILLER, by sending a copy of the same to her counsel of record, Brigid Q. Alford, Esq., BOSWELL, TITNER, PICCOLA & WICKERS, 3]5 North Front Street, P.O. Box 74], Harrisburg, P A ] 7] 08-074], by United States Mai], regular service, in Harrisburg, Peunsylvania on March 2], 2002 Respectfully submitted, HANDLER, HENNING & ROSENBERG Date: 312.110 L---" By: David H osenberg, Esq. J.D. # 2 569 1300 Ling]estown Road P.O. Box 60337 Harrisburg, PA ] 7]06 (7] 7) 238-2000 Attorneys for Plaintiff - ''\i; ',_ ,- _'-, '/ -;'1~"_''t':',,,,,,~~~_,,,,!C-,,____,_,_,,~,", ..,.. '".r,.~","---'~~- ,__,,~, I~ ,_~,~" ,.~'"~~,;t"~'''.~,, ,,~_V''''''~,.,' ~____,"_';I' "I, ' .' ,'-,~ _, '.' ~ ~ ",I,,,L"_'T~' _, ,_". ,,' '~''''_'''''_='_'''~''>'' _~ _ . c_~___, _ , ,'~ ".. _'''~ ='" <ill -1'~ ''''-,-' "& ,~ ,<""~ "'< '-' ,~, "" ,- '4.~''''.''~=~-'"~>'''''''d'*-.'rt1--'-''~"--'~'" [jl '~11Ill ['''''''''''''-''i'ur'':' "'1'",,,-,,,"[-"''' ~'- ,[ ,~~p ~L, ._ r:t:1!l,1.)!11!!~11.~' Tl ,jl~I~' _ ~ " J_4Jl,~~""",,,~,,,,,?,~, w '- ",~'r Brigid Q. Alford, Esquire Supreme Court I.D. #38590 Jeffrey E. Piccola, Esquire Supreme Courtl.D. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Amanda Lee Miller ELAINE M. MOHLER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. : NO. 01-1711 Civil Term AMANDA LEE MILLER, Defendant : JURY TRIAL DEMANDED : CIVIL ACTION - LAW PRAECIPE TO FILE VERIFICATION TO THE PROTHONOTARY: Kindly file the attached original verification and substitute it for the interim attorney's verification attached to Defendant's Answer to New Matter, filed March 14, 2002 in this case. Respectfully submitted, By: Brigld Q. 1\lford, sq Supreme Court J.D. # 590 Jeffrey E. Piccola, Esquire Supreme Court J.D. #18018 BOSWELL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108-0741 Attorneys for Defendant Amanda Lee Miller Date: ~~f}).... :' "<:'c ,,-~--,'~,., _'~"""~""'~"""'.""">O"M ';", ,_, ."-'"""",'_1,.;<",, __"-, ___ ,,_,,~~~ __^~..~__~". ,_, I'~_l~" ~,X,,, ".--_.~,~ ~."",,,,,, ~ -~ " . "~ , VERIFICATION I, Amanda Lee Miller, hereby verify that the facts contained in the foregoing Defendant Miller's Answer to Plaintiffs Complaint with New Matter are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S.A. !l4904 relating to unsworn falsification to authorities. ~~ille~ ~ Date: 3//.1.1/02- :: ) . ",~ - . CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy of the foregoing Praecipe to File Verification by placing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: David H. Rosenberg, Esquire 1300 Linglestown Road Post Office Box 1177 Harrisburg, P A 17108-1177 By: Date: t..€lr{vr ii ,. - P,o~,""~ _ ~ '~~'~".~,~"~-"-. _ "-~,~--,,-,," , ",+-,-.- ,<,"^ ~,,_."-- '-""' " -."' ~ "',', ,~",~ "".",,,~,,,, ~.,,,~ ,"'",,"""","C';',C' """""~"*"c..v,-,,,~<-~ ";"''''''-''''Jll f","~ 'iII~' "1j-Y"""~T""-' "~'T""'lJ'~ "'ff'';'~)-li;t''i'ri:r i 0 a 0 c (0..> ,} ~.: :po :;:1 t:J.OJ ""':J mrYi ;;>::l ;:l13 Z:J::J " zr- , -nm -;t :;')0 lj) '-. u:> -< .,.-:: 1:-) l ,-cD ::,0 )>"..... " ~~:rl 2,...< -'~ -70 ):."C OrT} Z :J"I ~ ~ 0"'\ -< " ~ ,-"""" ,,, " ",. , '. ,'~ c rrWM!fflI~~Ili~~ .",., "~~!ljIlllI:I!.Ig!!"I" :m, ..11f ..,{ll_~~ ... .. . ELAINE M. MOHLER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 01-1711 CIVIL TERM AMANDA LEE MILLER, Defendant : CIVIL ACTION - LAW : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this1?tbaay of May, 2002, I hereby certify that I have, on this date, served the within Plaintiff's Answers to Defendants Interrogatories and Plaintiff's Responses to Defendants Request for Production of Documents, by sending a true and correct copy of same to their attorney of record and including copies to all parties of interest via first class mail, postage prepaid, as follows: ~i Jeffrey E, Piccola, Esquire Brigid Q, Alford, Esquire 315 N, Front Street P.O. Box 741 Harrisburg, PA 171O~-0741 HANDLER, HENNING & ROSENBERG By t' ,^',"' ,"-' , '-, '0"'-" ,r_,"'f'?%",~_,,,_,,..,,,,,,,,,,' ~-,"_,_, 'O'~'" """,or-,,,", """-~~c,,,\ ~I.~_'w, ~_~,__'I"~,__!,"",,,,,,~,'~",,".~,,.o ,_""_~",_n _ _ ~~__, " _< ',' -' _ " 'F"""" _ ,_~",,, ,r--< " ',,' ~,,= = ,'~ ,< ,Rj' r' < _~_, '" _<.~ __ _, < ,__,~,O-," lil L,,~~~ ,." '_c. ~ -'"-. "''-;''-'--- ","c' '^ , ._~,c ^~,' . -, ,~....... . . "'~~_,,~, '-<.l'.wv '" n, ~'._""__"~'=> .,. ~ 'riICU"'lliil'lif .. ... 0 0 0 C "-) " :5: :::I: ,-, 'Ut1J ,.,. f:~~~ n1rll -< Z:r) 21-:- I -Dm (/) ,~::'~ \D ~1JO -<~':' ';~~ t<C~: -0 .c-'~~n "1> ~, ::ll: ~~(~ zC-' ,--0 N r-=:irn PC:: -, Z :.11 ?L; :~ ..... -< jJ~~~~~""'f''''''~ ~~ ~,~,,~ . Brigid Q. Alford, Esquire Supreme Court I.D. #38590 Jeffrey E. Piccola, Esquirf: Supreme CourtI.D. #18018 BOSWElL, TINTNER, PICCOLA & WICKERSHAM 315 North Front Street Post Office Box 741 Harrisburg, Pennsylvania 17108.0741 Attorneys for Defendant Amanda Lee Miller ELAINE M. MOHLER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : NO. 01-1711 Civil Term AMANDA LEE MILLER, Defendant : JURY TRIAL DEMANDED : CML ACTION - LAW CERTIFICATE PREREOUlSITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009 .22, Defendant certifies that: (1) a notice of intent to serve the subpoenas with copies of the subpoenas attached thereto was mailed or delivered to counsel of record, (2) a copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, (3) no objection to the subpoenas has been received, and - ^ ~-" ^ " - ,~,~,,'"'' ''''''f'''h. . ,~--f ~"C:"->~'c' q ",,,,'~"""'I' ,"'L""",,\?1'il,-')',r', '_:":"_O~~,,"_' "'.""1 "I .,"-".,., "'~'- "", - ""'" ':~ _e' ""., --~, .,- -,,^ ,,'-~ 1-' I"!/", (! 1': , ~ : fl , , 'J~P'_'_I"~"'" , (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. Respectfully submitted, By: ={. {} Brigid . Alford, Esq Supreme Court #385 Jeffrey E. Piccola, Esquire Supreme Court #18018 Boswell, Tintner, Piccola & Wickersham 315 North Front Street Hanisburg,PA 17101 (717) 236-9377 Attorneys for Defendant Amanda Lee Miller Date: {p /1'1;'-- ,-,","",<g-"'S"'!'''-'i,f"~,"~'of~e',",,?,^"~~n',,,,,,,,. 'o""'""i_:,_,_,_I_""", """'" '-;<'-':1 ,__,. ," ""',~'\'.e,-", ~~", '-I ~,I ,,'c' . '--<' , ,__ ;~ """'I' - ,_._,-~,,, ~'_'o/' ',_' , '''''.>'''''', L'_ _'.'""'_"_,"'_,'" ",j___;l__,"!3''''''__ . - , " c Brigid Q. Alford. Esquire Supreme Court LD. #38590 Jeffrey E. Piccola. Esquire Supreme Court LD. #18018 BOSWEll. TI7'iTNER. PICCOLA & WICKERSHAlvI ) 15 North Front Street Post Office Box 741 Harrisburg. Pennsylvania 17108-0i..U AUQmeys for Defendant Amanda Lee Miller ELAINE M, MOHLER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v, : NO. 01-1711 Civil Term AMANDA LEE MILLER, Defendant : JURY TRIAL DEMANDED : CIVIL ACTION - LAW " " NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009,21 Defendant Amanda Lee Miller intends to serve subpoenas identical to the ones that are attached to this notice upon the following: Ed S. Violago, M.D. BarryB. Moore, M.D. Arlington Rehab & Sports 1{edicine Center Radiology Associates Steven E. Morganstein, D.O. Timothy A. Mulhollem, D.C. Magnetic Imaging Center David E. Tanner, D.O. Albert W. Heck, M.D. (P A Neurological Associates, Ltd.) Physiotherapy Associates William K. Shaffer, D.C. Robert R. Kaneda, D.O. Thomas E. Becker, II, D.C. (Becker Chiropractic) "--" ,--- ~"'.- ~ "' ,-0>,< ,-" <~, ,>, ,'~',' "" ,__ ',_' ,J',,<~ " '. You have twenty (20) days from the date listed below in which to file ofrecord and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. Respectfully submitted, By: Brigid . Alford, Esq re Supreme Court #38590 Boswell, Tintner, Piccola & Wickersham 315 North Front Street Harrisburg, P A 171 01 (717) 236-9377 Attomeys for Defendant Amanda Lee Mil1er Date: ~ (/t,/DA ( "<C' "'. - _"< ~n."_"_'"~ ,,,,!_. ,_ ,~_ -''-' '-<~--'-'-" .,~. ",,'$~,--,,- "-, , COMMONWEALTH OF PENNSYLV,.l,:,Ht. , , COUNTY OF CUMBERLAND ELAINE M. MOHLER, Plaintiff' v. AMANDA LEE MILLER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009,22 File No. 01-1711 Civil Term ;,0: Thomas E. Becker, II, D.C. (Becker Chiropractic) (Name of Person or ::1t1iy) Nithin twenty (20) cays after service of this su::poena, you are ordered by the court to produce the following tocuments or things: Any and all medical records,. treatment records. correspondence. referrals. etc for Elaine M. Mohler (Social Securitv #169-44-3434). Date-of-birth 07/13/1 from April, 1999 to present. '. =.; 315 North Front Street. Hi'lrr; "hllrg PZI 17101 (Acc:ress) 'IOU :7iay deliver or ~.ail legibie c::pies of the dCC~r7ie!'Hs or produce things ieques~ed by this subpcer.a. together /.'ith the certificate of compliance, to the party making this re~uest at the address listed above. You have the righr ::: seek in advance the ieasonable cost of preoarrnc the c:::ci-as or :::iroduc:na the thincs soucht. . ... ' r ... _ .... ,7 yew fail to produce the doc:.Jments or things required by this subpoeria 'vvithin tvJenty (20) days after its service, ::-.e ;Jarty serving this siJ:::;Joena r7iay seek a c:)u:"'~ order c8l7:;Jelling you t,:) comply with it. ,OilS SUBPOENA WAS ISSUED AT THE REQUEST 0;= TH!:: FOLLOWING P!::RSON: 'Jame Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & W~ckersham ,.l,dcress: 315 North Front street Post Off~ce Box 741 Harrisburg, PA 17108-0741 , ~E:jeprlor'i€;: (717) 236-9377 3u:Jreme Court 10 # 38590 ';t~cri1ey For: Defendant Amanda Lee Miller BY THE COURT: Prothonotary/Clerk, Civil Division '-".=.. -c._. Deputy Seal of the Ccurt (E" -/e7) JI. I - ~- ~,' '- ,'~ --' . <^" ~, ".~' ,~ ,",,'..r '_''''.~" , __ ." COMMONWEALTH OF PENNSYLV:.<:~!~ "COUNTY OF CUMBERLAND ELAINE M. MOHLER, Plaintiff' v. AMANDA LEE, File No. 01-1711 Civil Term MILLER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 ~O: Robert R. Kaneda. D.O. (Name of Person or =:itlty) /Jithin twenty (20) cays after service of this su:::poena, you are ordered by the court to produce the following ::cc~ments or things: Any and all medical records,. treatment records. correspondence. referrals. etc for Elaine M. Mohler (Social Securitv *169-44-3434). Date-of-birth 07/13/1 from April, 1999 to present. '. 315 North Front Street, HMrri"hllrg. PlI 171Ql (Adcress) ',leu may deliver or mail legibie c~pies of the dcc~..H7'lernS or pr:lduce things ieques~ed by this subpceria. together .'.'ith. the certificate of cor7'lpliancel to the party making this request at the address listed above. You have the right :-: seek in advance tr-16 reas::nable cost of preparing the copies or producing the things sought. ~ you fail to praGuee the coc:.Jrnents or things required by this suopoena within tvvent~{(20) days aftar its service, ::-.6 ~ar~ serving ~his sub;Joena may seek a COU:-: oi:::!er c~r7:pe!lin~ ye.u to comply with it. , ;;-1[S SUSPOENA WAS iSSUED AT THE REQUEST 0;= TriE ;::OLLOWING P::RSON: "lame Brigid Q. Alford, Esquire Boswell, Tintner, P~ccola & W~ckersham -,-ccress: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 -=Jepnone: (717) 236-9377 ::Cl:xe17,e Cour: 10 # 38590 ';:~~rlley F:Jr: Defendant Amanda Lee Miller BY THE COURT: ProthonotaryiClerk, Civil Division :Jate: Seal of the Court Deputy (E.. -iC7) IT. I - ',- ." ""',, . - ,~,~ ~~, v,,, ~ -,,~, ,,'~ ",'~ COMMONWEALTH OF PENNSYLV)..:.!1P , COUNTY OF CUM8ERLAND ELAINE M. MOHLER, Plaintiff v. AMANDA LEE,MILLER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 File No. 01-1711 Civil Term ~O: William K. Shaffer, D.C. (Name of Persor', or Entity) /lithin ~I/enty (20) C2.ys 2.TIer service of this su::poen2., you 2.re ordered by the court to produce the following ::ocuments or things: Any and all medical records,. treatment records, correspondence, referrals, etc for Elaine M. Mohler (Social Security #169-44-3434), Date-of-birth 07/13/1 from April, 1999 to present. " 315 North Front Street, Harri"hnrg. P)\ 17101 (Aceress) ,,/~u niay deriver or mail legible c:Jpies of the dcc:":;";1en!s or produce things reques~ed by this sL:opcena.. together :.Iith the certificate of compliance, to the party making this request at the address listed above. You have the righr ::: seek in advance the reasona~Je cost of preparing the copies or producing the things sought. '7 yeu rail to procuce the doc~me;"';ts or things raquired by this suo poena within tvventy (20) days after its ser'/ice, :;-.e ~aity serving i:his sub;Joena may se~k a cour~ or:::er c::~~e![ing YOl..! to comply with it. ,rilS SUBPOENA WAS ISSUEO AT THE REQU::::S, OF,i-iE ;=OLLOWING P::::RSON: \J2.me Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & W~ckersham ~jj~S5: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 -e!ephone: (717) 236-9377 3u::;reme Court 10 #0 38590 ...:., ~:~rlrey F:)r: Defendant Amanda Lee Miller 8Y THE COURT: PrcthcnotaryiClerk, Civil Division 1-....::1. _c:.l..... Deputy Se2.1 of the Court (E" -;07) Ti. I .., ". ,---.~~,.~",-~-".^' ,'"'-, "" -,...- '. ,-, "-"""--- [" ,. COMMONWEALTH OF PENNSYLV.':.>![~ , COUNTY OF CUMSERLAND ELAINE M. MOHLER, Plaihtiff' v. AMANDA LEE'MILLER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 File No. 0]-]711 Civil Term ~O: Physiotherapy Associates (Name of t=ersar. or :::1t1ty) :Jirhin ~tJenty (20) days after service of this subpoena, you are ordered by the court to produce the following tocuments or thinGs: Any and all medical records,. treatment records, correspondence, referrals, etc for Elaine M. Mohler (Social Seourity *169-44-3434), Date-of-birth 07/13/1 from April, 1999 to present. 315 North Front Street. Hi'lrri"hllrg. P)\ 17}91 (Accress) './:;u ~ay deliver or mal! !e;ibfe c:Jpies of the dCc:.H7'len!S or ~r:Jc'uce things ieques~=d by this sL:bpcena. together :-,itn. the certificate of c~mpliance, to the party ma.king this request at the address listed above. You have the right :: seek in advancs the reasonable cost of preparing the c:;pies or producing the things sought. - .f you fail to produce the dcc~ments or things required by this subpoeria within twenty (20) days after its service, ,; :,-;e ~2rt"y serving ~his si.Jb;:Jcena may seek a c:>ur: order c::~~elllng yow to c:)mply with it. ii-lIS SUBPOENA WAS ISSUECl AT THE REQUEST 0;:: T;-.:E FOllOWING PE::\SON: \Jarne Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & W~ckersham ~jdress: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 -~!e~hone: (717) 236-9377 "clorerne Cou;! ID;;, 38590 . - -'~:vrney ;-:)r: Defendant Amanda Lee Miller BY THE COURT: PrcthonotaryiClerk, Civil Division \-~,::l.' _C~_. Deputy (Eft. 7/97) Seal of the Court " "''''lP>~'t'~~,~<''",~"-,'-H-" -- ""'''-"~ - ",'~_ f ", I-~r"',~,~,,, ~ ,,> ~>,' ."'7""""!""y,_ , _ ~_, COMMONWEALTH OF PENNSYLV':.'J!~ . COUNTY OF CUMBERLAND ELAINE M. MOHLER, l?laintiff. v. AMANDA LEE'MILLER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 FileNo. 01-1711 Civil Term -:-0: Albert W. Heck, M.D. (Name of Pers~n or ::1tlty) Nithin twenty (20) cays after service oi this subpoena, you are orderec by the court to produce the iollowing ':cc~riients or things: Any and all medical records,. treatment records, correspondence, referrals, etc for Elaine M. Mohler (Social Security #169-44-3434), Date-of-birth 07/13/1 from April, 1999 to present. 315 North Front Street. Harric;nnrg, Pll 171Q1 (Adcress) " '.low i7lay deliver or rnaillegible c::pies of the dCC~;;1en!S or proc~ce things reques:ed by this subpcer.a. together :.:ith the certificate of compliance: to the party making this request at the address listed above. Yow have the right :: seek ir, advance the reas::nabfe cost of prepaiing the c;:)pies or producIng the things sought. 7 yew fail to produce the dOC~.Hi!eiits or things required by this SUbp06ria within twenty (20) days after its service, :;--;e ;Jaity sen/ing ~~is subpoena i7'iay seek a cou;-,;: cr=er c::r7':;Je!ling you to comply with it. :i-iIS SUBPOENA WAS ISSUE) AT THE REOUEST O~ Ti-iE Fall_OWING PE:=\SON: "'ame Brigid Q. Alford, Esquire Boswell, Tintner, P~ccola & Wickersham ~<jcress: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 -~!=phone: (717) 236-9377 3",::;reme Caur: 10;;, 38590 . - -<:.::rney :-or: Defendant Amanda Lee Miller BY THE: COURT: Prothonotary/Clerk, Civil Division .......,_..::1. _c'l_. Seal oi the Caur. Deputy (Eff. 7/97) -"V':" - < ,~,,~~'"~_~ ..='".,"_~_ ,__',_ _,~c ,. ~,~ _ . ,'" , c_ ~. COMMONWEALTH OF PENNSYLV^,,:OliP 'COUNTY OF CUMBERLAND ELAINE M. MOHLER, Plaihtiff' v. AMANDA LEE,MILLER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 File No. 01-1711 Civil Term ~O: David E. Tanner, D.O. (Name of Person or =~my) '. :/ithin twenty (20) days after service of this su:::poena. you are ordered by the court to produce the following ::c::uments or things: Any and all medical records,. treatment records, correspondence, referrals. etc for Elaine M. Mohler (Social Security ~169-44-3434), Date-of-birth 07/13/1 from April, 1999 to present. 315 North Front Street, HarriRh"rg. pa 171D1 (Accress) " '..':,u iiiay deliver or rr:aille~ible c::)pies of the dcc~ments or ;Jr~duce thiilgS reques:ed by this st,;bpoena. together N!th the certificate of compliance, to the party ma.king this request at the address listed abOVE. You have the right :: seek in advance trle reasonable cost of ;::>re;:aring the c=~ies or produc:ng the things sought. 7 you fail to produce the cocumeiits or things required by this sutJpoena within tvventy (20) days after its service, ::'".e party serving ~his sU:J;;c,ena may seek a cour: oider c:::;r.-:;::;e1lins yew t.:> comply with it. i'-:IS SUBPOENA WAS ISSUED AT THE REQUEST 0;= T:-:E i"OL!...OWING PE:=tSON: \jame Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & W~ckersham ':,;:;dress: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 -;iepnone: (717) 236-9377 3c:::;reme Cour: ID # 38590 ':'::~ri1ey For: Defendant Amanda Lee Miller BY THE COURT: PrcthonotaryiClerk, Civil Division ::ate: Deputy (Eff. 7i97) Seal of the Court -'~--' ' ':>~~,~-, , ,,-' '." '.- , -~, ~ -, -' ~- ^<- -, -' I' ,I', COMMONWEALTH OF PENNSYLV.'\\liA . , COUNTY OF CUMBERLAND ELAINE M. MOHLER, Plaintiff' v. AMANDA LEE,MILLER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 File No. 01-1711 Civil Term '~O: Magnetic Imaging Center (Name of ?ersol'i or ::-:my) /;;thin tv/enty (20) cays after service of this su::;poena, you are ordered by the court to produce the following ~oc:.Jments or things: Any and all medical records,. treatment records, correspondence, referrals. etc for Elaine M. Mohler (Social Securitv #169-44-3434), Date-of-birth 07/13/1 from April, 1999 to present. 315 North Front Street, Hi'lrric:""rg. PZl '710] (Adciess) " \/:U :7'lay deliver or maillegibie c::pies of the d:.c:..:ments or .oroduce trdngs reques:ad by this subpcer1a. together .'lith the certificate of compliance: to the party making this request at the address listed above. You have Hie right. ::: seek in advance the ieasoriable cost of preparing the c;::,pies or producing the things sought. ;7 you fail to produce the coc:Jme-rlts' or things required by this suopoena within tvventy (20) days after its service, :,-.e ;i2ity serving this s;j::-~cer:a t7iZY seek a cour: or::sr c':r7:;Je!ling yeLl !':J comply wirh it. ,:-iIS SU5POENA WAS ISSUEJ AT THE REOUES, 0;= T;-;: FOU_OWING P:::RSON: \Jar;;e Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & W~ckersham ""ceress: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 7"e!e;Jnone: (717) 236-9377 3u:,reme Court ID #0 38590 ';:~::riley F~r: Defendant Amanda Lee Miller BY THE: COURT: Prcthcnotary/Clerk, Civil Division ,-..~- __COl.... Seal of the Court Deputy (E" -/e7) /J. I... ^ , '.'-'~", '-"'" _ 'f". ~," ,,',~"-- COMMONWEALTH OF PENNSYLV.~\J!A . COUNTY OF CUMBERLAND ELAINE M. MOHLER, Plaintiff. v. AMANDA LEE File No. 01-1711 Civil Term MILLER, Defendant SUBPOENA TO PRODUcE DOcUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 -:-0: Timothy A. Mulhollem, D.C. (Name of Person or =:'ltIry) Nithin twenty (20) C2YS 2iter service of this subpoen2, you 2re orderec by the court to produce the following =ocuments or things: Any and all medical records,. treatment records. correspondence, referrals. etc for Elaine M. Mohler (Social Security #169-44-3434). Date-of-birth 07/13/1 from April, 1999 to present. " 315 North Front Street. HAn'i"nllr<]. Oll 171()1 (Adc::ress) i , " jl'./~~ r7iay del!~er or ~aillegi~le copies or the d~C:..I,~enr~.or tJr::Jdu~e th,ings ~eques:ed by this siJbpoe~a. tcge:h~r ~ :.!!ti1 trle certlilca.!s Oi c~mpllancef to the party maKing tnls reques~ at tne acdress lIsted above. You have the ngilt ~I:.:: seek in advance the reasonable cost of prepa:-ing the copi~s or produc:ng the t:,ings sought. :!: ~i'7 you fail to proc:!wce the documerits or things required by this subpoer:a within tvJenty (20) days after its service, 1:::-.e ,:Jarty serving ~his sub;:;oena r.:ay seek a cour~ order c~r7':~efJing yc,u t':l comply wirh it. !-:-;-:IS SUBPOENA WAS ISSUEO ,4.T THE REQUEST 0;:: Ti-:E FOLl.OWING PERSON: ;'j2me Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & W~ckersham ; "",o::ress: 315 North Front street Post Off~ce Box 741 Harrisburg, PA 17108-0741 ~eiephcne: (717) 236-9377 3worer71e Court 10;;' 38590 ':'::Grney r=~r: Defendant Amanda Lee Miller BY THE COURT: Prothonotary/Clerk, Civil Division ':-cte: Seal of the Cour; Deputy (Eft. 7/97) -"_, 1, '~"'" ,,,~,~~~,..,,.,,,,.,,.,,,, ",~ <.,- -.-, . ~,' ,.. ,- , . COMMONWEALTH OF PENNSYLV,~:'.!!A 'COUNTY OF CUMBERLAND ELAINE M. MOHLER, Plaintiff' v. AMANDA LEE'MILLER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 FileNo. 01-1711 Civil Term -0: Steven E. Morganstein, D.O. {Name of Person or :mity) ,:!ithin twenty (20) cays after service of this subpoena, you are ordered by the court to produce the following j :ocuments or things: Any and all medical records"treatment records, correspondence. referrals, etc for Elaine M. Mohler (Social Security #169-44-3434), Date-af-birth 07/13/1 from April, 1999 ta present. ":::, 315 North Front Street. Harr; c;rmrg, P)\ 17101 (Adcress) " /OU i7':ay deliver or mail legible copies of the dcc:,J.'71enrs or pr::J:cuce things reques:ed by this s~bpceIia. together .,>'ith the cer~ificare of compHance, to the part;( making this request at the address listed above. You have the right :,:; seek ir, advance the reasonable cost of ~rsparing the c::pies or producing the things sought. f yew fail to procuce the dac:.Jma;"'its or things required by this subpoeria. within tvventy (20) days after its service, '! -:-,e ~2.rty serving this subpoena ii'iay seek a coun oi'jer c:')r;"';;Jelfing yow to comply with it. ic-iIS SUBPOENA WAS ISSUED AT THE REQUEST OF Ti-'E FOLLOWING P::?,SON: '.lame Brigid Q. Alford, Esquire Boswell, Tintner, P~ccola & W~ckersham "-oeress: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 -e!epnOi,e: (717) 236-9377 3u:Jreme Court 10 # 38590 :"!~::rnEy F'Jr: Defendant Amanda Lee Miller BY THE COURT: Prothonotary/Clerk. Civil Division :;ate: Seal of the Court Deputy (Efr. 7/97) . ',< .,," - - , , .-- ,COMMONWEALTH OF PENNSYLV,-,:'1!~ COUNTY OF CUMBERLAND ELAINE M. MOHLER, Plai'ntiff v. AMANDA LEE MILLER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 File No. 01-1711 Civil Term ',0: Radiology Associates (Name of Person or =:1t1ty) /lithin twenty (20) days after service oi this su::poena, you are ordered by the court to produce the icllowing cocuments or things: Any and all medical records"treatment records. correspondence. referrals. etc for Elaine M. Mohler (Social Security *169-44-3434), Date-of-birth 07/13/1 from April, 1999 to present. " 315 North Front Street. Hard "hllr'J. PlI 17101 (Adcress) :~ 'v':,!j :7iay deliver or rnaillegibie c:::pies or the dcc~men!s or produce things reques~ed by this swbpceGa. together ,:lj ,\'!th the certificate of cO:71pliancsJ to the party making this request at the address listed above. You have the righ! , -, :: seek ir: acva:ice the reasonable cost of preoarinc the c::cies or ::irocuc1na the thincs SOUGht. , ... . r- .... ... ... 'f you fajj to preduce the coc:...rmsilts or things require-d by this subpoena 'yvithin tvYenty (20) days after its service, :,-,e ;;ar~ serving ~his sub~oer:a r;;ay seek 2. cou:-~ order c:;~;:;elling you t.:) comply with it. . .. -:-:-:IS SUBPOENA WAS ISSUED AT THE REOUEST OF Ti-iE FOllOWING PE.4S0N: "!ame Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & W~ckersham ~ddress: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 . ~iepnone: (717) 236-9377 :::'-l,:Jreme Court tD;;, 38590 ":'::criley For: Defendant Amanda Lee Miller BY THE COURT: PrcthonotaryiClerk, Civil Division 1_";::.> ~c:.\..... Deputy Seal of tile Court (Err. 7/97) :~,~[f, ,_ _ ~, A-' "._, , .",0 ,=.,. - J". <_ ,. "~r,,,,_,"::", "~' _" <> "., c. . COMMONWEALTH OF PENNSYLV,.c..\!1:' 'COUNTY OF CUMBERLAND ELAINE M. MOHLER, Plaintiff' v. AMANDA LEE,MILLER, Defendant SUBPOENA TO PRODUCE DOCUMENTS ORTHINGS FOR DISCOVERY PURSUANTTO RULE 4009,22 File No. 01-1711 Civil Term ~o: Arlinqton Rehab & Sports Medicin~ C~nr~r (Name of Fersor, or ::"ltity) :;;thin twenty (20) cays after service oi this su:::poena, you are ordered by the court to produce the iollowing ::ccuments or things: Any and all medical records,. treatment records. correspondence. referrals. etc for Elaine M. Mohler (Social Security #169-44-3434). Date-of-birth 07/13/1 from April, 1999 to present. 315 North Front Street. Hi'lrri,,"nrg. P1I ]7](1] (Adcress) " ''/0'.1 ~ay deliver or mail legible c~pies or the dcc~ments or produce things reques~ed by this st.:bpceria. together .'.'!!h the certificare of compliance, to the party making this request at the address listed above. You have the right :': seek in advar;ce the reasonable cost of preparing the c:::;:ias or producing the things sought. : you fail to produce the docume,~ts or things required by this subpoena within twenty (20) days after its ser'/ice, :,....e part! serving ihis $ub;Joena may seek a c~ur: oi:ier c::;~,::>elling yow to comply wirh it. ,;-':15 SUBPOENA WAS ISSUED AT THE REQUEST 0:= T;-;E FOLLOWING PE:RSON: -';ame Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & W~ckersham .c..ecress: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 -~!ephone: (717) 236-9377 3,,:jreme Court 10;; 38590 .:., ::criley F~r: Defendant Amanda Lee Miller BY THE: COURT: Prothonotary/Clerk, Civil Division '-~Q.' _c,~. Seal oi the Court Deputy (Crr" -leT) "- . I _ ~, - '~"""','H.._,~,,,,, _~~ ._ , ,< L "--'~' "I " ,.' , ' COf';lMONWEALTH OF PENNSYLV;'.>J!~ COUNTY OF CUMBERLAND ELAINE M. MOHLER, , Plaintiff v. AMANDA LEE- MILLER, Defendant SUBPOENA TO PRODUCE DOCUMENTS ORTHINGS FOR DISCOVERY PURSUANTTO RULE 4009,22 File No. 01-1711 Civil Term ,,0: Barry B. Moore, M.D. (Name ot Person or ::mrty) Nithin tv/enty (20) days aher service of this subpoena, you are ordered by the court to produce the following ~ccuments or things: Any and all medical records,. treatment records. correspondence. referrals. etc for Elaine M. Mohler (Social Security *169-44-3434). Date-of-birth 07/13/1 from April, 1999 to present. 315 North Front Street. Harr; "1-"'T/]. P)\ 17101 (Accress) !"i 'f=u may deliver or ma1l1egiois copies of the dcc:..:me:'1!s or produce things requested by this subpoena. together tj .vith the certificate or comptiance, to the party making this request at the address fisted above. You have the right ;1 :: seek Ir. advance the reasonable cost of preparing the copies or producfng the things sought. ': yeu fail to preduce the doc:.Jments or things required by this subpoena within twenty (20) days after its service. :;-.e ,::i2r\j serving \his SiJb~C6na l7'lay seek a court Cider c~~~el1ing you t,:) comply with it. I:-:IS SUBPOENA WAS ISSUEO AT THE REQU::ST OF Tc-i:: FOLLOWING PE.=iSON: 'lame Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & W~ckersham ;dt~ss: 315 North Front Street Post Off~ce Box 741 Harrisburg, PA 17108-0741 7'e:iephone: (717) 236-9377 3,-,::reme Cou;, ID #0 38590 ":',:::r:iey For: Defendant Amanda Lee Miller BYTHE COURT: Prothonotary/Clerk, Civil Division ,_.~. _c::.,_. Seal of the Court Deputy (Err. 7/97) ~, - ~.= ,-","0' .,_ _.,' . ".,. ~, d"1' " ." --" ..-> ,COMMONWEALTH OF PENNSYLV,.c,~!L~ tOUNTY OF CUMBERLAND , ELAINE M. MOHLER, Plaintiff . v. AMANDA LEE MILLER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 File No. 01-1711 Civil Term ro: Ed S. Violago, M.D. (Name of Person or Entity) ~/ithin twenty (20) days after service of this subpoena, you are ordered by the court to produce the following :!cocuments or things: i Any and all medical records,. treatment records, correspondence. referrals, ! etc for Elaine M. Mohler (Social Security #169-44-3434). Date-of-birth 07/13/19' from April, 1999 to present. 'I:;, 315 North Front Street. Harr; ",hllrg. PlI 17101 (Adoress) '. !You may deliver or maillegibie copies of the dccuments or produce things requested by this subpoena. together J,N!th the certificate of compliance, to the party making this request at the address listed above. You have the right j::c seek in advance the reasonable cost of preparing the copies or producing the things sought ':if yeu fail to produce the documents or things required by this subpoena within twenty (20) days after its service, ;;:;;e party serving ~his subpoena may seek a court order c:::;r.-:~el1ing you to comply with it. : THIS SUBPOENA WAS ISSUED AT THE REQUEST OF Ti-iE FOLLOWING PERSON: ,'lame Brigid Q. Alford, Esquire Boswell, Tintner, Piccola & W~ckersham ;adress: 315 North Front Street Post Office Box 741 Harrisburg, PA 17108-0741 7"eJephone: (717) 236-9377 3uoreme Court 10 # 38590 ';~torney For: Defendant Amanda Lee Miller BY THE COURT: Prothonotary/Clerk, Civil Division .Jate: Seal of the Caur, Deputy (Eff. 7/97) , " "', '''1''\ _~"'~~="_; """<"~''','. ,~'-"""",,,,~ -, .," ., , " , . . . - . CERTIFICATE OF SERVICE I do hereby certify that I have served a true and correct copy ofthe foregoing Defendant Miller's Notice of futent to Serve Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 by first-class United States mail upon the following parties at the addresses set forth below: David H. Rosenberg, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Post Office Box 1177 Harrisburg, PA 17108-1177 Attorneys for Plaintiffs " By: ~J~ BrigId Q 'Alforlr, Es ire Date: -5.1(~/i>~ :" ,~ ,,' '_, .J."'_ _ ." ;>, ",,,' <,., ., ,~, _""",~ , 11~.'_" ,,__'r, '_'__ '~". ,I" '1' ~"', - ., . . . , . CERTIFICATE OF SERVICE I do hereby certify that I have served a true and COlTect copy of the foregoing Certificate Prerequisite to Service of a Subpoena on the following by first-class mail, postage prepaid and addressed as follows: David H. Rosenberg, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Post Office Box 1177 Harrisburg, P A 17108-1177 Attorneys for Plaintiffs By: ~...{. ~ ~ Brigi Q. Alford, Efjuire Date: 0/11/02-- '}it . "__'~_ _ ',;'''W __ ",,0 ',. ,Q"". "".,^,,~~~,,?,n~.' ," ,__ ,-' .?li""- ~.--r'~',-,~I- ""' ;'_'_'<," ~ -- _ .. " --I" " ,,_ ,___'" ..'_ "', _ ,. ,,~,~_ ,0 ->e " _p, ", ""'''_"' "" " if SS'{.R '-. - - ~ ", ,~: __~T'"'" . . . ,"'7- ~~"'- e"_,,...!l ,~ -~.~ _,. '4"" . '< '.',~. '-" '^' 'JI.J.;';,N-r :~- : J TlfTIT _'_' - ~'_~_trll"J' "',';{C'-f '~"fIJfi, . . , 0 C') 0 c;-; ~--J " ..-;" .,:::c: -c:r r , 1'-r . -.' ,'-- ~' ,',) ,"ll (/ C) "':::'J [~~: '1;:;... (~ ~ ...,;,.. =t: " '. r " .' 'i- \..,,,,1 -< , ';;:J ,lIiJ~~.I!ffil~~.~~~~~~~ Elaine M, Mohler, IN THE COURT OF COMMON PLEAS Cumberland County, PENNSYLVANIA Plaintiff NO,01-1711-Civil v, Amanda L, Miller, CIVIL ACTION - LAW JURY TRIAL DEMANDED Defendant PRAECIPE TO THE PROTHONOTARY: Please mark the Docket in the above captioned matter as Settled, Discontinued and Satisfied. HANDLER, HENNING & ROSENBERG, LLP BY: vid H osenberg, Esq. 1300 L' glestown Road Harri urg, PA 17110 Tel. No.: 717-238-2000 Supreme Court ID No. 20569 Attorneys for Petitioner DATE: 5f~/&5 ) ~';,'C^ ~--'^ ~~ -, ;~~ ^',~, '"''_!~''' _~h,~~,"",__" ",,-"''>;''''h,O,''" f-' _", ~ __,",01 N,n _ _ -," '1,__,,, '_ _ n_''- ;, - 1'--'1 ' ,,- ,- ,~ k' ~'~"--- . -~ . '"',' '''~ ,'-" --' ~1 " 'H' ~ , H < f~~~1l: Mil!'[Ij;~~; ~~~~~~IIIl!lill\ft!l, "'" ,',"",'-,-"",,,-,, "', ,', ""~''''''''''''.'''~~rn'''''ilmrl"rr' () c: ~~. ?)/~:;' <I en '. -"-:" " Fi/( ,..-:.,,- ~~:-." ;~? '-'--,;. ........ ,':,'-. ~" c ~:0 c- "'~J o ~ri , , -:-1 ~,Q -~