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HomeMy WebLinkAbout01-2467 FX -'-_.._~=~~~. c.~",'_~ . "',j ['I ,. , , > TODD ALAN REED Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-2467 CIVIL TERM RICHARD LEONARD, CECELlA LEONARD and ROSE A. LEONARD, Defendants CIVIL ACTION - LAW :JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint, order 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 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, Pennsylvania 17013 (717) 249-3166 1-800-990-9108 ~ ~ -. ""~ ~ -, ~. 'O'~' -~~,_. ,'~' '''~,~ ~---- -~ "~~'.' . , ~ .. -" ,_'on", . , "":"'~"tj itj ',I " "I I J'i .'1 , " I ;~(~ , I:' Americans with Disabilities ii' 'i;: Act of1990 The Court of Common Pleas of Cumberland County is required by law to comply with the " ,. ;, i; Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable ::: {! accommodations available to disabled individuals having business before the court, please contact our i1 office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. " ;'1 2 ,~_ ,>~~__ ^~ ~ "_ ,~< ~ ~,_"~__<o, '_'~~_~<'_<.~ ,,-~,~'~ '.,_h'__ . "', ''_'__{ ." '" r"} i TODD ALAN REED Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-2467 CIVIL TERM RICHARD LEONARD, CECELIA LEONARD and ROSE A. LEONARD, Defendants CIVIL ACTION -LAW :JURY TRIAL DEMANDED " ,~ COMPLAINT AND NOW, thi40 day of December, 2002 comes the Plaintiff, TODD ALAN REED, by his attorneys, Irwin, McKnight & Hughes, and makes the following Complaint against the defendants, RICHARD LEONARD, CECELlAN LEONARD and ROSE A. LEONARD: i.; 1. The Plaintiff is Todd Alan Reed, an adult individual residing at 75 West Main Street, Newville, Peunsylvania 17241. 2. The Defendants, Richard Leonard, Cecelia Leonard and Rose A. Leonard, are adult individuals residing at 88 Lonesome Road, Newville, Pennsylvania 17241. 3. On May 1, 1999, at approximately 4:30 am., the Plaintiff, Todd Alan Reed, was a passenger in the front seat of a 1989 Chevrolet Cavalier driven by Rose A. Leonard and owned by Cecelia Leonard and Richard Leonard. 3 rt , ,~ , ,,-. . -~ ~"-~- ,,",,' H_ ,,---<. ^'"~- - . -"-~ . ~'_"^. "~."'''''- -',,",--,-, -,,,"",,,,-,,,,_, ",'c'" -_"'_~'''''-V_';.--",~"._C' -..;".q"",,,..,,,h.-~~;,._;_'_'~__';,_;_;'___;-_ .,-. ;;b-~ 4. The single vehicle injury accident occurred on Wolfe Bridge Road approximately 75 feet before Route 34. The vehicle was travelling at a high rate of speed when the Defendant, Rose Leonard, lost control of the vehicle, went off the left side of the roadway and struck a utility pole. 5. The Plaintiff, Todd A. Reed, had multiple contusions and abrasions on his face due to the severe impact which caused his head and face to break through the windshield of the vehicle. 6. The Defendant, Rose A. Leonard, received a hand and leg injuries as result of the impact. 7. Both Plaintiff, Todd A. Reed, and Defendant, Rose A. Leonard, were taken by ambulance to Carlisle Hospital, Carlisle, Pennsylvania, for emergency treatment of their injuries. 8. The Plaintiff, Todd A. Reed, was treated for multiple facial lacerations with multiple shards of glass imbedded into his head and face. The Plaintiff, Todd A. Reed, received numerous sutures to closes the lacerations in his face. 9. The injuries sustained by the Plaintiff was caused by the negligence and careless actions of the Defendant, Rose A. Leonard. 4 -~- -,. . - ~- ,- "~-.-=-",""_< i"'H '":';!i I 10. i I ! :i , i I :1 J I .1 , ] I I \\ I ':1 'I I 'I I 'J I ,I J I 'I I ,I ] , I I ! j 'I 1 ,] I The Defendant, Rose A. Leonard, was negligent and careless as follows: a. She failed to maintain his vehicle under proper control in an effort to avoid a collision; b. She was operating his vehicle at an unsafe speed; c. She was operating the vehicle while under the influence of alcohol; and d. She was not paying attention to the highway. 11. The negligent actions of the Defendant, Rose A. Leonard, were the proximate cause of the injuries to the Plaintiff, Todd A. Reed. 12. The conduct of the Defendant, Rose A. Leonard, in operating the motor vehicle while under the influence of alcohol was outrageous in that it was done with a reckless indifference to the safety of the Plaintiff. 13. At the time of the accident, Defendants, Cecelia Leonard and Richard Leonard, had negligently entrusted the vehicle to their daughter, Defendant, Rose A. Leonard, knowing that she would be drinking and operating their vehicle in a reckless manner. 5 ..'~ '." -, -. .~ -~- 14. The Plaintiff, Todd A. Reed, seeks compensation for the pain and suffering, emotional distress, and loss of life's pleasures since the date of the accident as well as compensation for future losses he will incur in these areas. 15. The Plaintiff, Todd A. Reed, seeks compensation for the medical expenses which he has incurred and may incur in the future to treat his injuries and lost income from his work which occurred as a result of the injuries he sustained in the accident. 16. The Plaintiff, Todd A. Reed, also seeks compensation for the serious and permanent injuries which he has sustained to his face which has caused extensive scarring. WHEREFORE, the Plaintiff, Todd A. Reed, requests compensation and punitive damages from the Defendants in the amount in excess of Twenty-Five Thousand and no/lOO ($25,000.00) Dollars with interest as permitted by law and the costs of this litigation. Respectfully submitted, IRWIN, MC By: Marcu 1\. Mc 60 West Pomfret t Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court I.D. No. 25476 Attorney for plaintiff Date: December 20, 2002 ~ ~ -" '"' - ',-...-'<"-:"~!/! '-1 q ,:~ .. :; '. i: n I,: !~ ,J 6 . . .. .-.~. '~=- < ~~. ."~~~ "'_.~_"c=___ '-",'~ - h~ - --~-., .'., ~ ,,-, " '"'""--,-''' ~ .:-..-~' )--.-;;;',' ;';'i u VERIFICATION ,.;1 The foregoing Complaint is based upon information which has been gathered by ,;. " " counsel and myself in the preparation of thir action. I have head the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. ('"./o.u c..~ TODD A. REED Date: DECEMBER. 20, 2002 11 .' ~ ~~=~ -, ~ - ~, -,~- .- - ~='~-"'-"~~'--~ -~ TODD ALAN REED Plaintiff, v. RICHARD LEONARD, CECELIA LEONARD and ROSE A. LEONARD, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2467 CML TERM CML ACTION - LAW :JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Marcus A. McKnight, 111, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: John A. Statler, Esquire 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 By: Date: December 20, 2002 7 . -/"'-~- "'l; ::i :1 il "-I :-1 ;' j '1 I, " 'I II 1:1 I~ I 1-1 IJ II II 11 I, 1,1 :,1 ij I' n "I ,:1 I., 'i :--1 [;1 'J ,I I 1 I I 'J ~I I I I I I I I 'I :1 I . " c " ~, "-~ , 'M .,,'-,"". " ,,','-"~, c ~" -'-''-,-- -.',;,-, ~ " ->; " , -",', '".-,^""..,_Gc. , .iJ " ~', ~ili " v ;:0. TODD ALAN REED, PLAINTIFF, v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA (JI-~I/~ ? NO. CIVIL TERM RICHARD LEONARD, CECELIA LEONARD and ROSE A. LEONARD, DEFENDANTS CIVIL ACTION - LAW PRAECIPE FOR A WRIT OF SUMMONS TO CURTIS R. LONG, PROTHONOTARY: Please enter my appearance on behalf of the Plaintiff and issue a Writ of Summons against the defendants, Richard Leonard, Cecelia Leonard and Rose A. Leonard. Please direct the Sheriff to serve the defendants as follows: Richard Leonard Cecelia Leonard Rose A. Leonard 88 Lonesome Road Newville, P A 17241 Respectfully submitted, IRWIN, McKNIGHT & HUGHES By: Date: April 27, 2001 To: RICHARD LEONARD, CECELIA LEONARD and ROSE A. LEONARD You are hereby notified that Todd Alan Reed, the plaintiff, has commenced an action against you which you are required to defend or a default judgment may be entered against you. IS/ ~I#.~ PROmO OTARY ~~ ~~~~ DEPUTY By: Date: ~ .;2'7 .2001 .,..; ~ ". .1, '." "L'L ,.;i ,_<,"- ~ -. i L", "'j ,'-~', .-.i.',", , <.. SHERIFF'S RETURN - REGULAR ... CASE NO: 2001-02467 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REED TODD ALAN VS LEONARD RICHARD ET AL RICHARD E. SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon LEONARD RICHARD the DEFENDANT , at 1840:00 HOURS, on the 1st day of May , 2001 at 88 LONESOME ROAD NEWVILLE, PA 17241 by handing to RICHARD LEONARD a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 6.20 .00 10.00 .00 34.20 ~~~~~ , R. Thomas Kline 05/02/2001 IRWIN MCKNIGHT Sworn and Subscribed to before By: me thi s A. 3"^-- day of ~d ~I A.D. ) 915' ~7ud'##., A~ rothonotary' o~ , ... CASE NO: 2001-02467 P SHERIFF'S RETURN - REGULAR .. COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REED TODD ALAN VS LEONARD RICHARD ET AL RICHARD E. SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon LEONARD CECELIA the DEFENDANT at 1840:00 HOURS, on the 1st day of May , 2001 at 88 LONESOME ROAD NEWVILLE, PA 17241 by handing to CECELIA LEONARD a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: ,~~ ~~ ,/!-"//' ~ , :':i ..~dI"L _,4'~' .....:~~':';:~._~~:.::::j~~ ~ ' ?~f - <<;.~ >T" ,". ~' R. Thomas Kline 05/02/2001 IRWIN MCKNIGHT Swo~ and Subscribed to me this J. -J,d day of before By: eriff /'LIA.. .;lbof A.D. q: " <f,-,12 l-M,tlI'j /, '+f Prothonotary .... SHERIFF'S RETURN - REGULAR " CASE NO: 2001-02467 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REED TODD ALAN VS LEONARD RICHARD ET AL RICHARD E. SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon LEONARD ROSE A the DEFENDANT , at 1840:00 HOURS, on the 1st day of May , 2001 at 88 LONESOME ROAD NEWVILLE, PA 17241 by handing to CECELIA ROAS, MOTHER a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: ,~~"":I " , i',vY"~vcji ~r l ...~ _,.-r"""""",~.-J .r "","4c#"",,, 1""~"v~F.,g;Jf R. Thomas Kline 05/02/2001 IRWIN MCKNIGHT Sworn and Subscribed to before By: me this :l,?~1 day of ftt ~ A.D. 0,,( '/vudl,..-;~ P othonotary .~'~ 0' "" _~~._~__~,~",..___.,. "'''''Ci';'_''-;;jl .. . John A. Statler, Esquire AttorneyI.D.~o.43812 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 2344161 Attorney for Defendants TODD ALAN REED, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW RICHARD LEONARD, CECEL1A LEONARD and ROSE A. LEONARD, Defendants : NO. 01-2467 Civil Term : JURY TRlAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter the appearance of John A. Statler, Esquire of Goldberg, Katzman and Shipman, P.C. as counsel for Defendants Richard Leonard, Cecelia Leonard and Rose A Leonard. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. By: ~r- John A. Statler, Esquire Attorney 1. D. No. 43812 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 DATE: l/ / "7 ! 0 2- 87274.1 Attorneys for Defendants ,~ .0" "'" .,-,~ .' '-~,,-, -' ',,-,".-'"~.--<.,-'_:..--, ;'^' --~- ,". ,""""-,'-",""",,,ltil,""i,'\-\'~"":'___" : -~ l' '-"j; ""'{,j . , ~ CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon ail parties or counsel of record by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage prepaid on the 7'"'fV\ day of 1\1 (l\r<-wt \v-v , 2002, addressed to the following: Marcus A. McKnight, III,Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.c. By John A. S atler, Esquire Attorney I. D. No. 43812 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendants .'Ai.~ili-'~'ij";-- . ;...."'- '~ '_'~^'d .;;; ~ ir::L' '. "- '.~:G~- ,k.,--"'~"''-t~~ -, I., "^ . --<> .,' ,','" e. ~. ,- .. ^,- ,"e ,~,~ , ,~,-~ ".. l.ll,',: lTii >~' \,:. C') f~t ',. .~- ~~~ t~::: -"~ --; e_, . o ~;: c:-;: ~'-',J ,- 'f) N I" 11 ~ ij i'i :~ i'l r:~) ;') ()l :3 :~ ::.< 1 .. John A. Statler, Esquire Attorney 1. D. No. 43812 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, P A 17108-1268 Telepbone:(717)234-4161 ~ ' <', M.c F_'~~~_"',.n_~o~._'_,.'___ -~--~--'''-~J.1 ~ .. TODD ALAN REED, Plaintiff Attorney for Defendants v. RICHARD LEONARD, CECELlA LEONARD and ROSE A. LEONARD, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 01-2467 Civil Term : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter a Rule upon the Plaintiff, Todd Alan Reed, to file a Complaint within 20 days or suffer a judgment non Dros sea. reg. DATE: II I 7 / 0 2- 81275.1 Respectfully submitted, By: GOLDBERG, KATZMAN & SHIPMAN, P.c. J~d Attorney I. D. No. 43812 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendants "-'. =~- , ,,- -,' -"-'---'''"'"~'''"--.''''-",>-..r, ~-, -~^-~,-,_< ,-,' ,----~"'- -",; ',;>,,,'3..,i;)*,',,-';'-'j';';~"',,;;.___ ,'- . '--. TL:i . + RULE TO PLAINTIFF TODD ALAN REED: You are hereby directed to file a Complaint in the above-captioned matter within 20 days or judgment non OfOS will be entered against you. DATE: /1- y- OJ.. .&r~~~ .~".= - -".,"'--~-"~-- ."d-----ll"~ . CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage prepaid on the I'J O"ll'.tMA ~ ,2002, addressed to the following: {TV.. day of Marcus A. McKnight, III,Esquire IlWin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. ~ 33;~- Attorney I. D. No. 43812 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendants F"""-"""-~~J~'li~.4'!-: dbJlll ~~- ~~~~~~.""-,;- "_~, "~__ _, ",<" v'",,,' ~= ',," ,-",,, ,- " lJ'~'" -r., " n"'; "":-,' c c:: ., ::c, -~ Ci " I ,""" "..-' " ~~ " ~:1 .,"J (j'''; ''1'~, / ~ ,:J -< , John A. Statler, Esquire Attorney 1. D. No. 43812 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, P A 17108.1268 Telephone: (717) 234-4161 } .. . TODD ALAN REED, Plaintiff Attorney for Defendants v. RICHARD LEONARD, CECELIA LEONARD and ROSE A. LEONARD, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION . LAW : NO. 01-2467 Civil Term : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly file of record the attached Certificate of Service of the Prothonotary's Rule to File a Complaint which was issued on November 8, 2002 and served on the date reflected in the attached Certificate of Service. DATE: II 1/2-10 L 87276.1 GOLDBERG, KATZMAN & SHIPMAN, P.c. ~.~ John A. Statler, . Attorney 1.D. No. 43812 320 Market Street P. O. Box 1268 Harrisburg, PA 17108.1268 Telephone: (717) 234-4161 Attorney for Defendants ~=,:' ... . .. John A. Statler, Esquire Attorney 1. D. No. 43812 GOLDBERG, KATZMAN & SIllPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717)234-4161 Attorney for Defendants TODD ALAN REED, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW RICHARD LEONARD, CECELIA LEONARD and ROSE A. LEONARD, Defendants : NO. 01-2467 Civil Term : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have served a certified copy of the Rule to File Complaint issued by the Prothonotary of Cumberland County on November 8, 2002, upon counsel for Plaintiff, by depositing same in the United States Mail at Harrisburg, Pennsylvania, with first-class "11i\ postage prepaid on the I 2- day of No V-t#1 ~ , 2002, addressed to the following: Marcus A. McKnight, Ill,Esquire Irwin, McKnight & Hughes 60 West Pomftet Street Carlisle, PA 17013 GOLDBERG, KATZMAN & SHIPMAN, P.e. By: ~ Attorney I.D. No. 43812 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney for Defendants ~- ~- -~ ,,-- <,> A~ .>~~ ~~.==~=.,=-,,~~~,~' ,- ~J - CERTIFICATE OF SERVICE I HEREBY CERTIFY that 1 served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage prepaid on the I 2- /1A day of No v-e-wI ~ , 2002, addressed to the following: Marcus A. McKnight, III,Esquire Irwin, McKnight & Hughes 60 West Pomftet Street Carlisle, PA 17013 Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.e. By 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendants ~:'.-..~~,;-'_;;-.t"','I ~" .. ._..~~,~.~~~ --,'"._.-. ~ n' -h eJiiici: Tuj{i,~ll~';""":''''~ - - -, - ,- -~ ",,"'-<., --I_"",~" ." . ~ ~, -~ ","..:..-;.,.--:... - ~. (") ~.o ~;:~ c.! ;.....: ~..~ '''; ~~;;'-.:- ..- (.,:' /,- " c" ::-;.- :::~. \' ,) '..---:"- ~ J:,; c;:) :_) ~-iJ. -~ -\ ."'"" V~ \...J !~ ,--, . ~,~'" "_H,.'_ ~ --~N'~_ ,~" - -~~~~- --~~-- "'-">-.~'- ''-"'[:::1 :! John A. Statler, Esquire Attorney 1. D. No. 43812 GOLDBERG, KATZMAN & SHIPMAN, P.c. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney for Defendants TODD ALAN REED, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW RICHARD LEONARD, CECELIA LEONARD and ROSE A. LEONARD, Defendants : NO. 01-2467 Civil Term : JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendants hereby certifY that: 1.) A Notice oflntent to serve the subpoena, with a copy of the subpoena attached thereto, was mailed or delivered to each party at least twenty days prior to the date on which the subpoena was sought to be served; 2.) A copy of the Notice oflntent, including the proposed subpoena, is attached to this certificate; 3.) No objection to the subpoena has been received; and 4.) The subpoena to be served is i entical to the subpoena attached to the Notice of Intent. By: DATE: I (J /1 3 J 0 3 John A. Statler, Esq . Attorney J.D. No. 43812 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 .~ I ,. . John A. Statler, Esquire Attorney I. D. No. 43812 GOLDIlERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. BOl< 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney for Defendants TODD ALAN REED, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW RICHARD LEONARD, CECELIA LEONARD and ROSE A. LEONARD, Defendants : NO, 01-2467 Civil Term : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: TODD ALAN REED, Plaintiff c/o MARCUS A. MCKNIGHT, ESQUIRE Irwin, McKinight & Hughes 60 West Pomfret Street Carlisle, PA 17013 Attorney for Plaintiff PLEASE TAKE NOTICE that Defendants, Richard Leonard, Cecelia Leonard and Rose A. Leonard intend to serve a subpoena identical to the one attached to this notice. You have 20 days from the date listed below in which to file on record and serve upon the undersigned an objection to the subpoena. Ifno objection is made, the subpoena may be served. GOLDBERG, KATZMAN & SHIPMAN, P.c. By: ~~ Attorney for Defendant Date: 412.; f03 .. . (DoM)NWFALTH OF PmlNSYLV2\NIA <XXlNl'Y OF aJMBmIAND TODD ALAN REED, l'laintiff v. File No. 01-2467 Civil Term RICBAlID LKONAlID, CECELIA LEONARD and ROSE A. LEONAlID, Defendants SUlPOENA TO Pfl()()(XE DOCltENTS OR 11i I NGS FOR 0 I SOOVERY PURSUANT TO RULE 4009.22 TO: Graham Medical Clinic (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the fOllowir\9 docunents or things: Copies of all medical records, medical reports, office notes, physical therapy records, correspondence, x-ray.'reports, MRI reports, nospiral ]records, test reports~any and all uLb~L L~~ULdb pCLta~aiftt ~8 any eare aT ~r8~~4~~ pv~r reBdered te: '001))) ALAI\{ RI11m; noR, 8/17/71: SSN: 210-66-9040. at Goldberp;, Katzman & Shipman, P.C., 320 Market Street, P.O. Box 1268, Harrisburg, l'A 11108-1268 (A,ddress) You may deliver or mail legible copies of the docunents or produce things requested by this subpoena, together with the certificate of CCfIl)liance, to the party making this request at the addr<>ss listed above. You have the right to seek in advance the reasonable cOst of preparing the copies or producing the things sought. I f you fail to proquce the docunents or things required by this subpoen; within twenty (20) days after its service, the party serving this subpoena noay seek a court order oarPelling you to COITIlly with it. nlls SUBPOENA WAS ISSUED AT TIE REGll.eST OF THE FOLLONING PERSON: NAtE: John A. Statler, Esqnire Goldberg, Katzman ana Shtpman, P.C. ADDRESS: _32Jl....l1arket Street P'..O. Box 1268 Han:isbu.rg,--w.- 17108-1268 ~4E: (717) 234-4161 SlJ'REI'E a:urr 10 # 43812 ATTORNEY FOR: Defendants . BY TI-E ~T: Prothonotary/Clerk, Civi I Division OATE:_ Sea 1 of the Ccx.r.t Deputy (Eff. '1/91) -,- ,- , -, ,,"'--,> - ~"-< ' '-'-- -~'-'"'" ,"'"'_H~'_,_,o. ,,_.-'" _~_~~'_" i ";;o;-~;'--~'''''-''-'~'I-''':c1;:'d'"/_',M:'"", ~';">""'""-"ii #- ' ,-""" ... CERTIFICATE OF SERVICE I HEREBY CERTIFY that 1 served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at / 3 """[1A Harrisburg, Pennsylvania, with first-class postage prepaid on the day of ()cJv~ , 2003, addressed to the following: Marcus A. McKnight, I1I,Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.e. By 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendants ~d!"-'->"-~""'r~;j';""=-"" "" _. > -~~-, ,~-- '-"'---~-';~'>~-':':_;-~~!ti~~~il:;->.- "-- ,,,-.1. .'/.= = '_u". ~" ,-- -,- "" "" ~. ''; (~ 1 . .. ... (~-:) c: c,,:- ....1 -'"\ c:> [--,.;;"; :~) -" --j r't ;::-: ; (; , c:-:. f-~ , C) , ;....; """:;) ~~ , - ~~ --;-; '- . .' r~":l ;'>'0-. C .i'v ' '-, in .~"" ,- ~b --! ~ -o- n) -< ~"" ~ "" -~~ -,. _,_" ""'d' '",~?='~:'C-~' _"';~ __ "-'__'._.':: John A. Statler, Esquire Attorney 1 D. No. 43812 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg,PA 17108-1268 Telephone: (717) 234-4161 Attorney for Defendants TODD ALAN REED, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW RICHARD LEONARD, CECELIA LEONARD and ROSE A LEONARD, Defendants : NO. 01-2467 Civil Term : JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service ofa subpoena for documents and things pursuant to Rule 4009.22, Defendants hereby certify that: 1) ANotice ofIntent to serve the subpoena, with a copy of the subpoena attached thereto, was mailed or delivered to each party at least twenty days prior to the date on which the subpoena was sought to be served; 2) certificate; A copy of the Notice of Intent, including the proposed subpoena, is attached to this No objection to the subpo has been rec~iV~?; and :. /:t!i,~\' _-':'. JbP6eA:~ '''')~e, Intent. 3) 4) By: DATEd;., rt< - y, /t7tJ2.- " ,',~ '",-' " _" .1 -. [h~";"T' :~--~,-- ~', -"-''''-'~''lli , - John A. Statler, Esquire Attorney 1. D. No. 43812 GOmBERG, KATZMAN & SHIPMAN, p.e. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Te1ephone:(717)234-4161 (( .' Ii '.", .. ,/ '0 ~; iI:::/ If Attorney for Defendants TODD ALAN REED, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -LAW RICHARD LEONARD, CECELIA LEONARD and ROSE A LEONARD, Defendants : NO. 01-2467 Civil Term : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Marcus A. McKnight, Esquire: PLEASE TAKE NOTICE that Defendants" intend to serve subpoenas identical to the ones attached to this notice. You have twenty (20) days from the date listed below in which to file on record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoenas may be served. GOLDBERG, KATZMAN & SHIPMAN, P.e. Date: r0"1C IJ, J1/2-- By: --J)/ S /sU1C John A. Statler, Esquire Attorney for Defendants . . <XM-UNWEI\LTH OF prnNSYLVANIA <XXlNl'Y OF aJMBEmJ\ND Todd Allen Reed, Plaintiff vs. File No. 01-2467 Richard Leonard, Cecelia Leonard and Rose A. Leonard, Defendants SUBPOENA TO PRClOlk::E DOCl.M:NTS OR TH' NGS FOR 0 I srovERY PURSUANT TO RULE 4009.22 TO: r.Rr1iRle Hospital (N<rne of Person or Entity) within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records pertaining to Todd Allen Reed, DOB 8/9/71, ssH 210-66-9040 at h' P C 320 Market Street, Harrisburg, PA Goldberg, Katzman & S lpman, .., (A.ddress) You may deliver or mail legible cooies of the documents or produce things requested by this subpoena, together with the certificate of carpliance. to the party making this request at the addr,?,ss listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. 'f you fai 1 to produce the docunents or things required by this subpoen'3. within twenty (20) days after its service, the party serving this subpoena IT'ay seek a court order o::.ni)e 11 ing you to carp ly with it. TH I S SUBPOENA WAS I SSUEO AT THE REQUEST OF THE FOLLCYlI NG PERSON: NAME: John A. Statler, Esquire ADORESS:~_~O Market Street, PO Box 1268 Harrisburg ,_ PA 17108-1268 TELEPrKX~E: (717) 234-4161 StJ'REI"E COUIT 10 # 43812 ATTORNEY FOR: Defendants, Rose A. Leonard DATE: ,/!Joe.) /.:l ~, Seal of the &;;:;,.-t Prothonotary/Cler . Oi . Division 44,,_P_~CP/JJ~~ Deputy "--- (Eff. 7/97) - <XJ!.MlNWE2\LTH OF PENNSYLVANIA <XXlNl'Y OF aJMBmLAND Todd Allen Reed, Plaintiff vs. File No. 01-2467 Richard Leonard, Cecelia Leonard and Rose A. Leonard, Defendants SUBPOENA TO PR<X:lLCE [)()CU-ENTS OR TH I NGS FOR OISCOVERY PURSUANT TO RULE 4009.22 TO: Aesthetic Reconstructive Surgery of Central PA (Nane of Person or Entity) Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the fo llowinq documents or things: Any and all records pertaining to Todd Allen Reed, DOB 8/9/71, ssH 210-66-9040 at Goldberg, Katzman & Shipman, P.C., 320 Market Street, Harrisburg, PA 17108-1268 ( t>,ddress ) You may deliver or mail legible cooies of the documents or produce things requested by this subpoena. together with the certificate of carpliance. to the party making this request at the addr~ss 1 isted above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produc:e the documents or things required by this subpoen'3. within twenty (20) days after its service, the party serving this subpoena IT'ay seek a court order o::.ni)e 11 ing you to carp ly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLCYlING PERSON: NAME: John A. Statler, Esquire ADORESS:]~Q Market Street, Box 1268 HRrri R'mrg. 1'1L..l7108 TELEPrKX~E: (717) 234-4161 SU'REJoE O:::UH 10 *' 43812 ATTORNEY FOR: Defendants,Rose A. Leonard Prothonotary/Clerk. Division &~ ~p 7f~j}AC.~- OATE:_ .//JOl\ Sea I of ),3 ;;J rY:>::J.. the' Court. ~ (Eff. 7/97) ,~~~li';lrJMj$!lilffil,~~~' .<,.," ,'~ ,'~O v - ~~1~d;t!k3t~~~~if'~~'-' , """""" , ,,~, ~,-",~~.".-, . < ,-~ "' ~, ,. ~~", ,~, " . 0 <,"- C:, C.t,.' """ -0 IT 'CO," n-\ L;- z. .- z "'--, G') \..() -< .~ - r:' (' ~ '--', ~/-< :PC () Z -I --' '>> ;;C' -< en .D -< ---- , J- 1-. '~_;,_ ,-, >-' ,',." ~ ~. ' _'.i'.""", _" e' . -, -".---1 . f '<,,,-, ,,",~. -- '-I"-'-'.,;~;i.'~;-,:;t.-' "',,". 1';;..:',,< ",- ",~ '~;~l;;-;'i;:-~;.k.:~'(;;.~ j_';~_,- . ~0'-c-;ji > John A. Statler, Esquire Attorney l. O. No. 43812 GOLDBERG, KATZMAN & SlDPMAN, P.C, 320 Market Street P.O. Box 1268 Ranisburg, PA 17108-1268 Telepbone: (717) 234-4161 Attorney for Defendants TODD ALAN REED, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW RICHARD LEONARD, CECELIA LEONARD and ROSE A. LEONARD, Defendants : NO. 01-2467 Civil Term : JURY TRIAL DEMANDED NOTICE TO PLEAD TO: TODD ALAN REED, Plaintiff c/o MARCUS A. McKNIGHT, ill, ESQUIRE Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 Attorney for Plaintiff YOU ARE REQUIRED to plead to the within Answer With New Matter within 20 days of service hereof or a default judgment may be entered against you. GOLDBERG, KATZMAN & SHIPMAN, P.c. DATE: 1/1S-/03 BY~~ John A. Statler, Esqu' Attorney I, D. No. 43812 320 Market Street P,O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney for Defendants .... . _' '-j~", n. _',",~" '.;.0.' '--',,"' "'0.-"" '~i"' _.,~__,,-__,h~'-"" -",":'-';-"':"'.~-~-;;, ' - - -'~j~~j John A Statler, Esquire Attorney I. D. No, 43812 GOLDBERG, KATZMAN & SIDPMAN, P,C, 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney for Defendants TODD ALAN REED, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW RICHARD LEONARD, CECELIA LEONARD and ROSE A LEONARD, Defendants : NO. 01-2467 Civil Term : JURY TRIAL DEMANDED DEFENDANTS' ANSWER TO PLAINTIFF'S COMPLAINT INCLUDING NEW MATTER AND NOW, come the Defendants, Richard Leonard, Cecelia Leonard and Rose A Leonard, by their attorneys, Goldberg, Katzman and Shipman, P.e. who file the following Answer and New Matter in response to the Plaintiff's Complaint: 1, Admitted on information and belief 2. Admitted. 3. It is admitted that on May 1, 1999 at approximately 4:30 a,m., Todd Alan Reed was a passenger in the front seat of a 1989 Chevrolet Cavalier driven by Rose A Leonard. The ~- ,.. , "'- ...-~,,-...,~~ "'.'~ ,.~~" > {-;;;"'n",..'" -'~_ ,.",., ,_-<V~"',..". >".d;,- -,'~' , ~'-'--[;%i vehicle was owned by Rose A Leonard and Cecelia Leonard. The vehicle was not owned by Richard Leonard. 4. It is admitted that a single vehicle accident occurred on Wolfe Bridge Road near the intersection of Route 34. It is denied that the vehicle was traveling at a high rate of speed. It is admitted that the vehicle went off the left side of the roadway and struck a utility pole. 5, It is admitted that the Plaintiff sustained some injuries to his face in this accident 6, Admitted. 7, Admitted. 8, Based upon information and belief, it is admitted that the Plaintiff received treatment to his head and face including sutures, By way of further answer, Defendants are without information sufficient to form a belief as to the truth or falsity of the remaining averments in this paragraph and, therefore, deny the same and demand strict proof at trial if deemed material. 9, The averments in this paragraph constitute conclusions oflaw to which no response is required. In the event a response is deemed to be required, it is denied that any 2 , . ~~~_. ---''''-''' " ' -~. ,-' ,-' -~v...;":;"!i'~1 injuries sustained by the Plaintiff were caused by an negligence or careless actions on the part of Defendant Rose Leonard, 10. The averments in this paragraph constitute conclusions oflaw to which no response is required, In the event a response is deemed to be required, it is denied that Defendant Rose A Leonard was negligent and careless in: a. failing to maintain the vehicle under proper control in an effort to avoid a collision; b, operating the vehicle at an unsafe speed; c, operating the vehicle while under the influence of alcohol; and d, not paying attention to the highway. 11. The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, it is denied that Defendant Rose A Leonard was negligent and further denied that any negligent actions on the part of Defendant Rose A Leonard were the proximate cause of any injuries sustained by the Plaintiff. 12. The averments in this paragraph constitute conclusions oflaw to which no response is required. In the event a response is deemed to be required, it is specifically denied that Defendant Rose A Leonard was operating the motor vehicle while under the influence of 3 . .',-.., . ~.. -~ ~-~' :>1 I I , alcohol. By way of further answer, it is denied that the conduct of Rose A Leonard was outrageous or that it was done with a reckless indifference to the safety of the Plaintiff 13, The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, it is denied that Defendant Rose A Leonard operated the vehicle in a reckless manner and denied that Defendants Cecelia Leonard and Richard Leonard negligently entrusted the yehicle to their daughter knowing that she would be drinking and operating their vehicle in a reckless manner. 14. The averments in this paragraph constitute conclusions oflaw to which no response is required. In the event a response is deemed to be required, Defendants are without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiffs alleged damages and, therefore, deny the same and demand strict proof at time of trial if deemed material. 15. The averments in this paragraph constitute conclusions oflaw to which no response is required, In the event a response is deemed to be required, Defendants are without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiffs alleged damages and, therefore, deny the same and demand strict proof at time of trial if deemed material. 4 ~ .._.,-,' .--, ~~_~,'_O". --- .-'''',_'.,-.-', .'0',,<'--1.' ~.",,~~~_," '"'~';'-_,_',,_"""'-_"',._ -:.0'" '",,'~ _~.,,:_c_~_<__,_. "",,'o'"'Lc,..' - "'" 'CO' -;;21:.;:i 16. The averments in this paragraph constitute conclusions oflaw to which no response is required. In the event a response is deemed to be required, Defendants are without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiff's alleged damages and, therefore, deny the same and demand strict proof at time of trial if deemed material. WHEREFORE, Defendants Richard Leonard, Cecelia Leonard and Rose A Leonard respectfully request that the Plaintiff's Complaint be dismissed and that judgment be entered in favor ofthe Defendants and against the Plaintiff. NEW MATTER By way of additional answer and reply, Defendants raise the following New Matters: 17. Some or all of the Plaintiff's claims are barred in whole or in part by the applicable Statute of Limitations. 18. Some or all of the Plaintiff's claims are barred and/or are limited by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.SA 91701, et seq., and especially by 991705 and 1722 of that law. 5 ~.- .~ ",- _ .'C~'_" ^ ~ _ '~,-."_.~_ - '""_"'~",<_.;"~_ ,-~ <~_"~~"'- --"-'ht~ 19, Some or all of the Plaintiffs claims are barred in whole or in part and/or are limited by the provisions of the Pennsylvania Comparative Negligence Law and/or by the Doctrine of Comparative/Contributory Negligence. 20, Plaintiff Todd A Reed failed to exercise reasonable care for his own safety and was negligent and/or careless in that he: a. insisted that Rose A Leonard drive him home knowing or having reason to know that she was too fatigued or tired to do so; and b, voluntarily rode as a passenger in the vehicle operated by Rose A Leonard knowing or having reason to know that she was fatigued and too tired to drive. 21. The negligence and carelessness of Plaintiff Todd A Reed as aforesaid was a substantial factor in bringing about the Plaintiffs harm. 22. Todd Alan Reed has been paid for some or all of the damages alleged in the Complaint and, therefore, claims for those damages are barred by the defense of payment. 6 . , . ".,~. --; -" ~- ";,.''-',,."',-,. ,0 ~",,"_, -- ~,,~, . =, ". ,,,' "~,;;:'_'~t'_~_ii ~-" "'""''''-,-''{'' ",,",o~~ '~i,"C. -, ~"~":'---;--~i WHEREFORE, Defendants Richard Leonard, Cecelia Leonard and Rose A Leonard respectfully request that the Plaintiff's Complaint be dismissed and that judgment be entered in favor of the Defendants and against the Plaintiff. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.c. By: John A Statler, uir Attorney L D. NO.4 320 Market Street P. 0, Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 DATE: 1//S-/()3 Attorneys for Defendants 89539.1 7 '" ~~ ., 'ff'.- ',"'-"~- ~,~",,,,,,,,,-~- , ,..';._ i ' '"~I I I I I I VERIFICATION I, RICHARD LEONARD, hereby acknowledge that I am a Defendant in this action; that I have read the foregoing Answer With New Matter; and that the facts stated therein are true and correct to the best of my knowledge, information and belief I understand that any false statements herein are made subject to penalties of 18 Pa. C S. Section 4904, relating to unsworn falsification to authorities. DATE:d \3'D?- -, .. - "~ " . ,_.,.,"C._' '=_ ,_ "C..,__.,v~to*~^.;F.'" _~, . _'OJ VERIFICATION I, CECELIA LEONARD, hereby acknowledge that I am a Defendant in this action; that I have read the foregoing Answer With New Matter; and that the facts stated therein are true and correct to the best of my knowledge, information and belief I understand that any false statements herein are made subject to penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. ~ )~ 1 Ok.J Lti 6{J IUI CECELIA LEO ARD -1 DATE: O\'\~'Dd- i = --~,.".,~ "~. ., -~, . ..~~-_."_<~--~_,_,,~__. "_'0,'_"'_''-_' "_;iN"-"'~'--.-< ,-~'-_ .~-" ,_.:' '=-'_';""_"'_~<;,j_' VERIFICATION I, ROSE A. LEONARD, hereby acknowledge that I am a Defendant in this action; that I have read the foregoing Answer With New Matter; and that the facts stated therein are true and correct to the best of my knowledge, information and belief I understand that any false statements herein are made subject to penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities, ~~ . ) ROSE ~. L NARD DATE: 01, I~'()?- I.' , '."'~ . ".,. " ., '...,....,.. "I' '0 '".., " ~-c' .". ~-~~ ,>-> ",) '""""",0-.. ,";'. ci,'~,-'_U<>."_ ~" '~,",,, ,'h"... ',--~/ -,- -" --.,_-j;;'~-"r:;;;i~i~~,'''' :';"-";';'. --.; - ---""..,~ CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at !S~ Harrisburg, Pennsylvania, with first-class postage prepaid on the day of J Pflu;r, , 2003, addressed to the following: Marcus A. McKnight, III,Esquire Irwin, McKnight & Hughes 60 West Potnfret Street Carlisle, PA 17013 Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.e. By 320 Market Street P.O. Box 1268 Harrisburg, P A 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendants ,",,_nJ< ~l_ "-'<1I'r lUI!!i\m;_jj',!-'~-"li"'" ~:t,,,~I,,,,,,~,~,'!J;~-~_,, ,~__ +,WL)!IfL,.,->C', "_"l"-",_,,. "" .;",...;;:;...""<';,;-,-.-, ~~l~ ~~ii-'- - :,~ ,">,',9V'- - <;' , ,-,~-" " - " ""'~- ,," -., ''''.' e- c ~,. ~ ----:>,- () '~7 =3 ~ .r.- '-0 t~ ~ m) ~!-: -~l J< - .. __, w . .'-,-,",-,' .- .,,-.~ ",.,', . f ;.0";> .- -",."..,,_1'_',"'_ ,"'~,_~' ',_ ~, - ",,-; \: . ~ TODD ALAN REED, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-2467 CIVIL TERM RICHARD LEONARD, CECELIA LEONARD and ROSE A. LEONARD, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO SETTLE AND DISCONTINUE To Curtis R. Long, Prothonotary: Please mark the above-captioned case settled and discontinued and issue a Settlement Certificate to Marcus A. McKnight, III, Esquire, at 60 West Pomfret Street, Carlisle, PeIlllsylvania 17013. Respectfully submitted, By: Date: December 22, 2003 _~~ _M_M_ ~~._,~<, ."_ "'~-_~_ ,-,'''',S~,~-_,,,__",_,,,-.,~__"~.,,____,_~ "--'_'0 , ,. , TODD ALAN REED, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-2467 CIVIL TERM RICHARD LEONARD, CECELIA LEONARD and ROSE A. LEONARD, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Praecipe to Settle and Discontinue was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: John A. Statler, Esquire 320 Market Street P,O. Box 1268 Harrisburg, PA 17108-1268 IRWIN & McKNIGHT By: /z!i . 0,25476 Date: December 22, 2003 2 ,",,;~.! ,......~it" ,"'- " "^'~ _, __'",''''__'''',''~_''' """."!it.<<'rr," ,","""" '-~,"__ ,"_"h- -ib1iJjif~:!~~~- :JiiiJ~.,i~~' ,.-. '. ~"-- I,\~_ ,<, ,,",0','_" """,, ,'<"~-~- ,~. ~" -,\. , ~- , , .~"~h"_ => .. C) "" 0 = ~; = "n '--' f',- 0 .-< -r r-H Pi -'.""'f/ C-) n1r= N -ofT'l :DO N ot ,-- -I :J n-,---n -n ~~i-) C) C' (,0 (~3 rn "'f ,I .~ ~,> m_t a :.0- -< -J -< , ~