Loading...
HomeMy WebLinkAbout01-04590 ROLAND WILLIAMS, III and IN THE COURT OF COMMON PLEAS his wife, LI5A M. WILLIAM5, ~ CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs 01-4590 2001 v. CIVSL ACTION -LAW AMY M. WILSON, NRY TRIAL DEMANDED Defendant 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 LAWYER REFERRAL. SERVICE Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presenter una apariencia escrita o en persona o por abogado y archivar en la Corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado gue si usted no se defiende, la torte tomara medidas y puede entrar una order contra usted sin previo aviso o notification y por cualquier hueja o alivio gue es pedido en la petition de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes pars usted. LLEVE ESTA DEMANDA A UN ABODAGO ININIEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME FOR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717)240-6200 By. , ~1 seph J. Dixon, Esquire Attorney ID No. 28290 126 State Street Harrisburg, PA 17101 (717)236-8515 Attorney for Plaintiffs ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROLAND WILLIAMS, III and his wife, LISA M. WILLL4MS, Plaintiffs v. AMY M. WILSON, Defendant CIVIL ACTION -LAW NO. 01-4590 2001 JURY TRIAL DEMANDED COMPLAINT AND NOW this ~~ day of ~~001 comes the Plaintiff, Roland Williams, III, by and through his Attorney Joseph J. Dixon, Esquire who respectfully avers as follows. The Plaintiffs are Roland Williams, III, and his wife, Lisa M. Williams, adult individuals who reside at 2440 Beech Street, Harrisburg, Dauphin County, Pennsylvania 17110. 2. The Defendant is Amy M. Wilson, an adult individual who resides at RD 1, Box 101, Kittanning, Pennsylvania 16201. 3. On or about the facts or occurrences herein took place on the third day of August 1999 at approximately 1:20 p.m. on the Carlisle Pike in Silver Springs Township Cumberland County, Pennsylvania. 4. At aforesaid time and place, the Plaintiff, Roland Williams was driving a 1994 Nissan Sentra Sedan owned by his wife, southbound in the left-hand lane on the Carlisle Pike in Silver Springs Township, Cumberland County, Pennsylvania. 5. At aforesaid time and place the Defendant, Amy M. Wilson was driving a 1997 Ford Explorer southbound in the right-hand lane on the Carlisle Pike in Silver Springs Township, Cumberland County, Pennsylvania. ~. Fl 6. At aforesaid time and place, the Defendant attempted to make a left hand turn from the right-hand lane and onto Locust Point Road. 7. At said time and place, the Defendant, while making alert-hand turn from the right-hand lane drove her motor vehicle into the Plaintiff's motor vehicle causing the damages described herein. 8. Said collision was due to the negligence and carelessness of the Defendant which includes but is not limited to the following: (a) failure to make alert-hand taro from the proper lane. (b) failure to wait for traffic to clear before making alert-hand turn. (c) failure to make a turn from the proper lane. (d) operating a motor vehicle at an excessive speed under the circumstances. (e) failure to keep a motor vehicle under control. (f) failure to keep proper watch for traffic on the highway. (g) failure to keep alert for the presence of other motor vehicles on the highway. (h) driving a motor vehicle upon a highway in a manner endangering persons and property in a reckless manner with careless disregard to the rights and safety of others violating the Motor Vehicle Code of the Commonwealth of Pennsylvania. 9. Said collision was in no way caused by the actions or conduct of the Plaintiff. 10. As a sole and proximate cause of the accident, the Plaintiff has sustained painful and severe injuries which include but are not limited to: lumbosacral strain sprain, cervical strain sprain, left wrist strain sprain, right ankle strain sprain, thoracic strain sprain, aggravation of low back condition which was previously operated upon, left shoulder sprain, headaches, impairment syndrome of the cervical spine and permanent residual pain pattern symptoms of the cervical spme. 11. By reason of aforesaid injuries sustained by the Plaintiff, Rolland Williams, he has been forced to incur liability For medical treatments, medications and similar expenses in an effort to restore himself to health. The total amount of these expenses are unascertained at this time. 12. The Plaintiff has been advised and therefore avers that he will need additional medical care and incur future additional medical expenses. The total nature and amount of these expenses are unascertained at this time. 13. As a result of aforesaid injuries, the Plaintiff has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out daily activities and a loss of life's pleasures and enjoyments. 14. As a result of aforesaid injuries, the Plaintiff continues to be plagued by persistent pain and limitations and therefore avers that his injuries. are permanent in nature causing residual problems the remainder of his life. 15. As a result of said injuries, the Plaintiff has suffered a substantial inconvenience in his life and a decrease in the quality of his life. WHEREFORE, the Plaintiff prays this Honorable Court enter judgment against the Defendant in the amount of Twenty Five-Thousand Dollars ($25,000.00), which is an amount in excess of the amount requiring compulsory arbitration. COUNTI LISA M. WILLIAMS v. AMY M. WILSON 16. Paragraphs 1 through 15 of the Plaintiff s Complaint are incorporated herein by reference and made a part hereof. 3 r.- 17. As a result of said injuries sustained her husband, Lisa M. Williams, has been and will be deprived of the assistance, companionship, consortium and society of her husband, all of which has been and will be to her great loss and detriment. WHEREFORE, Plaintiffs pray this Honorable Court enters judgement against the Defendant in an amount in excess of Twenty Five-Thousand ($25,000.00) Dollars, which is an amount in excess of the amount requiring compulsory arbitration. Respectfully submitted, By: oseph J. Dixon, Esquire Attorney ID No. 28290 126 State Street Harrisburg, PA 17101 (717)236-8515 Attorney for Plaintiffs Dated: September 25, 2001 4 :~ VERIFICATION I verify that the statements made in this are true and correct. I understand that false statements herein are made subject to the penalty of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. DATED: ~~~~~~ ~/' -. ,,-, CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document by depositing the same in the United States mail, First Class, postage prepaid, at the following address(es): EAGER, REINAKER & SPINELLO ATTENTION: GEORGE H. EAGER, ESQUIRE 1347 FRUITVILLE PIKE LANCASTER, PA 17601 By JOSEPH J. DLY 126 STATE STREET HARRISBURG, PA 17101 (717)236-8515 ATTORNEY FOR PLAINTIFFS Date: September 25, 2001 ,.»~ c;. .. - c- _. R-7 r'~ ?~~ - - ri~- f~~ Y_ ~( x .. _~ _( .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROLAND WILLIAMS, III and his wife, LISA M. WILLIAMS, Plaintiffs NO. 01-4590 2001 v. AMY M. WILSON, JURY TRIAL DEMANDED Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served an original of Interrogatories of Defendant Addressed to Plaintiffs upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 EAGER, REINAKER & SPINELLO DATE: J~~U~I'bl BY: George H~! Ea¢~r, Esquire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 ;..., ~ ~ , ~_ . ~ . , ;; -~ _, ,;;; - ' ~ ~ , -::_ _ ,` ~_.: ~ ~~ ~ .. - ~s, ~ ~=- , .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROLAND WILLIAMS, III and his wife, LISA M. WILLIAMS, Plaintiffs v. AMY M. WILSON, Defendant NO. 01-4590 2001 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of Defendant's Request for Production and Copying of Documents - Set No. 1 Directed to Plaintiffs upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 EAGER, REINAKER & SPINELLO DATE : IU) 0'-~I U 1 BY George Imo. Eager,/Esquire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 .+.y ~) ..3 1 `. `_ ~_ .l . . . __ - ' wJ 1 ' u ~_: J =) - , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROLAND WILLIAMS, III and his wife, LISA M. WILLIAMS, Plaintiffs v. AMY M. WILSON, Defendant NO. 01-4590 2001 JURY TRIAL DEMANDED ANSWER AND NOW COMES DEFENDANT AMY M. WILSON, BY AND THROUGH HER ATTORNEY, GEORGE H. EAGER, AND FILES THE FOLLOWING ANSWER: 1.- 4. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). 5. Admitted. 6. - 15. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). WHEREFORE, Defendant asks that judgment be entered in her favor and against the Plaintiffs' on all claims set forth in Plaintiffs' Complaint. COUNT I LISA M. WILLIAMS v. AMY M. WILSON 16. Paragraphs 1 through 15 inclusive above are incorporated herein by reference and made a part hereof. 17. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). Defendant asks that judgment be entered in her favor and against the Plaintiffs' on all claims set forth in Plaintiffs' Complaint. EAGER, REINAKER & SPINELLO BY: George H. age Esquire Attorney for efendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 I, AMY M. WILSON, hereby verify that I am the Defendant in the foregoing action, and that the averments of the foregoing Answers to Plaintiff's Complaint are true and correct to the best of my knowledge, information and belief. To the extent that any of the averments of the Answers to the Complaint are based upon an understanding or application of law, I have relied upon counsel in making this Verification. I understand that I am subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities for any false statements made herein. Dated: 30 ~~./n~~'~i~ Y M. WILSON 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Answer upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 DATE: ~Ol ~N1~1 EAGER, REINAKER & SPINELLO BY: George Eage squire Attorney for efendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 c? - c__ -- = 7 -~ = t-,:; -~ .., ='~ ~"~ ;. ~ f , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROLAND WILLIAMS, III, and His Wife, LISA M. WILLIAMS, Plaintiffs v. AMY M. WILSON, Defendant NO. 01-4590-2001 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certify that: (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE : ~D I ~ ~Z~ George H. Eager, Esquire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROLAND WILLIAMS, III, and His Wife, LISA M. WILLIAMS, Plaintiff vs. AMY M. WILSON, Defendant N0. 01-4590-2001 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT AMY M. WILSON intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. DATE : ~' (j ~ pZ GEO. EAGE ESQUIRE ATTORNEY FOR DEFENDANT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAi~1D ROLAND WILLIAMS, III, and his wife, LISA M. WILLIAMS, Plaintiff vs. AMY M. WILSON, Defendant . FSIe No. 01-4590-2001 SUBPOENA TO PRODUCE DOCUIVIEIVTS OR THL~iGS FOR DLSCOVERY PURSUANT TO RULE 4009.22 Erie Insurance Group, P.O. Box 2013, Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the follovvnng doc~unents or things; first party records concerning Plaintiff Roland Williams, III (DOB: 10/3/54) (SSN: 20 - 2-6999 Policy No. Q at 1347 Fruitville Pike Lancaster, Pennsylvania, 17601. (Address) . You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party malting this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within tcveuty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. TIiIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: George H. Eager, Esquire NAME; Eager, Reinaker & Spinello ADDRESS: 1347 Fruitville Pike Lancaster, PA 17601 TELEP$ONE: (717) 290-7971 SiTPREMI/ COURT ID # ~~~4n ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of tlxe Court Prothonotary/Clerk, Civil Division Deputy CONii ION~VEAL7'H OF PIIYVSYLVANIA COUNTY OF CUMBERLAND ROLAND WILLIAM.S, III, and his wife, LISA M. WILLIAMS, Plaintiff vs. AMY M. WILSON, Defendant P"de No. 01-4590-2001 SUBPOENA TO PRODUCE DOCUMIIVTS OR THINGS FOR DISCDVERY PURSUANT TO RULE 4009.22 TO:. ABP Freight System, P.O. Box 1925, New Kingston, PA 17013 Withia twenty {20) days after service of this subpoena, you are ordered by the court to produce the followitlg documents or things: Any and all emnlovment records or reports, etc. & any other .information pertaining to Plaintiff Roland Williams, III (nnx• in/3/..,54_) (SAN: 208-42-6999) at 1347 Fruitville Pike Lancaster Pennsylvania 17601. {Address) ' You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party maiilug this request at the address listed above. You have the right to seek in advance the reasonable cost of prepazing the copies or producing the things sought Tf you Fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compellu-g you to comply with it. THIS SUBPOENA WAS ISSUED AT TIME REQUEST OF THE FOLLOWING PERSON: George H. Eager, Esquire NAME: Eager, Reinaker & Spinello ADDgCi$$; 1347 Fruitville Pike Lancaster. PA 1 TF:7.Ti.PHQNE: (777) 290-7971 SUPREME COURT ID # 27740 ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division DATE: Seat of the Court Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAi~TD ROLAND WILLIAMS, LISA M. WILLIAMS, Plaintiff AMP M. WILSON, Defendant III, and his wife., vs. FSie No. 01-4590-2001 SUBPOENA TO PRODUCE DOCi7Ng:NTS OR THINGS FOR DLSCOVERY PURSUANT TO RULE 4009.22 Robert C. Zabinski, D.C., 3028 Market Street, Camp Hi11, PA 17011 Within twenrty (20) days after service of this subpoena, you are ordered by the court to produce the foIIovring documents or things: Any and. all first consultation reports, office notes, MRI, CT and x-r-ay films repor s, es resu s, p ys ca erapy (Address) SSN: You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party malting this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena wi#hin twenty (20) days after its service, the party serving this snbpoeua may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQITEST OF THE FOLLOWING PERSON: George H. Eager, Esquire NAME: Earner. Reinaker & Sninello ~DgLiSS; 1347 Fruitville Pike Lancaster, PA 17601 TELEPHONE: (~i~1 z9o-797] SUPREME COURT ID /< 27740 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAi~iD ROLAND WILLIAPSS, III, and his wife, . LISA M. WILLLAMS, , Plaintiff F51e No. 01-4590-2001 vs. AMY M. WILSON, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To:. Edmundowicz, Watkin & Freshman Associates, P.C., 2645 North Third Street, Waite 200, Harrisburg', PA 17110 Within twenty (20) days after service of this subpoena, you aze ordered by the court to DroduCe the follovi'I~g dOCUm~D,tS Or things: ~Y ~ all .first consultation reports, office nurses' no6esTan~ docto~s iom~eisra~onQS'wit~isanvean allpo~lieiame icalp~eco~~s axld reports concerning Plaintiff Roland M. Williams, III (DOB: 10/3/54) (SSN: 208-42-699' at 1347 Fruitville Pike, Lancaster, Pennsylvania, 17601. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: George H. Eager, Esquire NAME: Eagar~ Rainakar R RninP11~ ADDRESS: 1347 F i vill Pike Lancaster, PA 17601 TDiLD,pgQNEi; (717) 290=7971 SUPREME COURT ID # 27740 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy ~.,P~ . COlVTtii fONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROLAND WILLIAMS, III, and his wife, LISA M. WILLIAMS, Plaintiff _ vs. AMY M. WILSON, Defendant File No. 01-4590-2001 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To• Neurological Surgery, Ltd., 920 Century Drive, Mechanicsburg, PA 17055-8404 Within twenty (20) days after service of this subpoena, you are ordered by the court to e the follov/ing docmnents or things•~y and all first consultation reports, office .MRI. CT and _x-rav films & reports. s resu s, p ysica erapv repor s. reports concerning.Plaintiff Roland M. Williams. III (DOB: 10/3L54) (SSN: 208-42-6999) at 1347 Fruitville Pike, Lancaster, Pennsylvania, 17601. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT .THE REQUEST OF THE FOLLOWING PERSON: George H. Eager, Esquire NAME: Eager, Reinaker & Spinello ADDRESS: 1347 Prattville Pike Lancaster, PA 17601 TIi,LEpFjONli; (717) 290-7971 SUPREME COURT ID # 27740 ATTORNEY FOR: Def en ant BY THE COURT: Prothonotary/Clerk, Civil Division DATE: Seal of the Court Deputy COMMONWEALTH OF PENNSYLVANIA. COUNTY OF CUMBERLAAID ROLAND WILLIAMS, III, and his wife, LISA M. WILLIAMS, Plaintiff vs. AMY M.. WILSON ,. Defendant File No. 01-4590-2001 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO. Zabinski Chiropractic Office, 3025 Market Street, Camp Hill, PA 17011 Within twenty (20) days after service of this subpoeua, you aze ordered by the court to ~roduCQ,~lje fOp~lowdoc e~ts O~ thin~s• Any and, all first consultation reports office _otes„ --a-- -a~ ~_=r?Y~ ~___TeP_?'t ~,a .._.- -- ..~~ ,. .._ _,. _ .... ...... .. ..tea cavorts concernine Plaintiff Roland M. Williams. III IDOB: 10/3/54) (SSN: 2Utf-4l-bN9: at 1347 Fruitville Pike, Lancaster, Pennsylvania, 17601. (Address) ' You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party malting this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: George H. Eager, Esquire rjAMEi; Eager, Reinaker & Spinello ADDRESS: I'~L7 Fr.,ir,.illeyilra Lancaster} PA 17601 TELEPHONE: (717) 290-7971 SUPREME COURT ID # 27740 ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division DATE: Seal of the Comt Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROLAND WILLIAMS, III, and his wife, LISA M. WILLIAMS, Plaintiff , File No. 01-4590-2001 vs. ' AMY M. WILSON, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO' Edwin A. Aquino, M.D., P.C., 845 Sir Thomas Court, Suite 10, Harrisburg, PA 17109 Within twenty (20) days after service of this subpoena, you are ordered by the court to e the fnRnwin¢ docnments nr thinQS: Anv and .all first consultation reports, office reports concerning Plaintiff Roland M. Williams, III (DOB: 10/3/54) (SSN: 208-42-6999) gt 1347 Fruitville Pike, Lancaster, Pennsylvania, 17601. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party malting this request at the address listed above. Yoa have the right to seek in advance the reasonable cost of preparing'the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: George 11. Eager, Esquire NAME: Eager, Reinaker & Spinello ADDRESS: t~fi7 F'rni will a-Pikes Lancaster. PA 17601 TELEPHONE: 0717) 290-7971 SUPREME COURT ID 1f 27740 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAi~iD ROLAND WILLIAMS, III, and his wife, LISA M. WILLIAMS, Plaintiff F'de No. 01-4590-2001 vs. AMY M. WILSON, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To:_Anesthesia Assocaites of Pennsylvania, Ltd., 207 House Avenue, Suite 102, Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to nrnduce the following documents or thins: Anv and all first consultation reports, office reports concerning Plaintiff Roland M. Williams, III (DOB: 10/3/54) (SSN: 208-42-6999) at 1347 Frnitoilla vihP, Lancaster, Pennsylvania, 17601. (Address) You may. deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party malting this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THLS SUBPOENA WAS ISSUED AT .THE REQUEST OF THE FOLLOWING PERSON: George H. Eager, Esquire Tj~i'; Eager, Reinaker & Sninello ADDRESS: 1347 Fruitville Pike Lancaster, PA 17601 TELEPHONE: (717) 290-7971 SUPREME COURT ID # z7i4o ATTORNEY FOR: Defendant BY TILE COURT: Prothonotary/Clerk, Civil Division DATE: Seal of the Court Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROLAND WILLIAMS, III, and his wife, LISA M. WILLIAMS, Plaintiff File No. 01-4590-2001 vs. AMY M. WILSON, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Tp;. Pinnacle Health-Polyclinic Hospital, 2601 North Third Street. Harrisburg, PA 17110 Within tweuty (20) days after service of this subpoena, you are ordered by the court to produce the Following documents or things: An abstract of anv and all medical records and films pertaining to Plaintiff Roland Williams, III (DOB: 10/3/54) ASSN: 208-42-6999) at 1347 Frui_tville Pike, Lancaster, Pennsylvania, 17601. (Address) You may deliver or mail legible copies of the documents or produce things requested by this snbpcena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: George H. Eager, Esquire jv~yjUi; Eager, Reinaker & Spinello ADDRESS' 1347 Fruitville Pike Lancaster, P TELEPHONE: _ (717) 290-7971 SUPREME COURT ID # 27740 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROLAND WILLIAMS, III, and his wife, LISA M. WILLLAMS, Plaintiff ,n'le Np, 01-4590-2001 vs. AMY M. WILSON, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Magnetic Imaging Center, 4665 Trindle Road, Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to :e the following documents or things: Anv and. all films and reports on Plaintiff 10/3/54) (SSN: 208-42-6999) at ]347 Fn+i vitt Fik , an a , Pennsylvania 17601 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. if you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: George H. Eager, Esquire NAME: Eager. Reinaker & Spinello ADDRESS: 1347 Fruitville Pike Lancaster. PA 17601 TELEPIiONE: (7t 71 990-7977 SUPREME COURT ID # 27740 ATTORNEY FOR: Defendant DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROLAND WILLIAMS, III, and his wife, LISA M. WII.LIAMS, Plaintiff vs. AMY M. WILSON, Defendant File No. 01-4590-2001 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 'I'p; QuanGUm Imaging & Therapeutic Associates, Inc.. 3508 Trindle Road CamF Hill_ PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following-documents or things: Any and all films and reports on Plaintiff (DOB: 10/3/54) (SSN: 208-42-5999) at 1347 1!ruitville Pike. Lancaster. Pennsylvania. 17601. (Address) ' You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. Tf you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: George H. Eager, Esquire NAME: Ewer, Reinaker & Spinello ADDRESS: 1347 Fruitville Pike Lancaster, PA 17601 TELEPHONE: (717) 290-7971 SUPREME COURT ID # 27740 ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division DATE: Seal of the Court Deputy CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Notice of Intent to Serve A Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 EAGER, REINAKER & SPINELLO BY: Georg H. Eage Esquire Attorney for fendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 Dated: ~ ~ CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 (Attorney for Plaintiff) EAGER, REINAKER & SPINELLO DATE : ~ ` ~ 1 f d Z- BY George H. Ea er, Esquire Attorney f Defendant I.D. No. 7740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 c> c' C' ~ ~`~ .~ :,. ~ ._~ ~U G3 CY , ~_, r ~ a r~ ~ `- -~ }~•-l `~ ~ 1. ~ c1= - '.~ C~1 ° " ~ <_- + ~ ~(_- ,, <., ~.~) ~ ~~ . k • r ~ w ROLAND WII,LIAMS, III, and His wife, LISA M. WILLIAMS, Plaintiff vs. AMY M. WILSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, NO.O1-4590 2001 CIVIL ACTION-LAW JURY TRIAL DEMANDED PETTTION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE JUDGES OF SAID COURT: Joseph J. Dixon, Esquire -, ;counselfgr the plaintiff in the above action, respectfully represents that: 1. The above-captoned action is at<issue. 2. The claim of the plaintiff in the action is 00.00. f ~S, Ood, The counterclaim of the defendant in the action is $0.00. The following attorneys, ar'~ intereStgd in the case as counsel or are otherwise disqualified to sit as azbitrators: George H. Eaeer;.Esquire 6TEsetbr,~Reinaker & Suinello WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) azbitrators to whom the case shall be submitted. Respectfully Submitted, Dated: Mav 11.2004 Joseph J. Di~en;'Esquire Attorney for Plaintiffs PA Id No. 28290 126 State Street Harrisburg, PA 17101 (717)236-8515 ORDER OF COURT NOW, ~`7~j otr_ l4~ ~20 DTf ~, in`con~ide •ation of the foregoing petition, ~i _ Esq. ,Gt000~~~ /~u;~zk ,Esq., and ~ssQ, _ Esa.. aze appointed arbitrators ' e above captioned action as prayed for. By the Court, P.J. r A ~ -., ~, C a ~ R-J ~ d f ...\~~~ ,~ Xi~'d,IC~f~iOi~~lrJct~~ ~Hi ~~ :1~~a.'~:kf.'tll~' ' N i^' ~~ -rl < _ ..,.. ~ -! ~ .;- r- ; ?; . -~ ~„ ~A`~"sT-0IYW~.RI.i ~~~~ .. ~~' ,~.+F2-E• e t'°_-_'<Mi ma¢3~`#if ~WM €3t{3X:`3 "P1`+=14Ei'dlXftL r~ ,. _._ .. ~, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANLA ~-r~ No. dl_tj59U 2001 Cl,~r~.Q JR~-., Civil Actiou - (X) Law ( )Equity ROLAND WILLIAMS, III and his wife, LISA M. WILLIAMS 2440 BEECH STREET HARRISBURG, PA 17110, Plaintiffs AMY M. WILSON RD 1 BOX 101 IGTTANNING, PA 16201, Defendant vs. JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. X Writ of Summons shall be issued and forwarded to ( )Attorney (X )Sheriff JOSEPH J DD{ON, ESQUIRE 126 STATE STREET RRISBURG PA 17101 (7171236-8515 __ Names/Address/Telephone No. Of Attorney Signature of ey Supreme Court ID No. 28290 Date August 1.2001 WRIT OF SUMMONS TO THE ABOVE-NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. Prothonot~y Date: August 1, 2001 by ~~~,~ 1 Ob1J ~ ,. D ( )Check here if reverse is issued for additional information. ::, ~ ~ `=~ 7 ~C. c' i ~..y~--i 6 . h ,~ r;_ 7 am ~ ,~` ~ y =D -C L d U ~1 O ~ VI 4 L~ t O ~i G C Mtg2"C~ _ ~6"~, icy.. s s~~vnLai riX4kPnRe~~# Sa~dm~~d~T..., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROLAND WILLIAMS, III and his wife, LISA M. WILLIAMS, Plaintiffs v. AMY M. WILSON, Defendant NO. 01-4590 2001 JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO: Curtis R. Long, Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387 Please enter a Rule upon the Plaintiffs to file a Complaint in the above captioned matter within twenty (20) days of the Rule or suffer a judgment of non pros. DATE: oglo~~~l EAGER, REINAKER & SPINELLO BY: ~ ~-~f George H.l E~agc~~; Esquire Attorney fo efendant I.D. No. 2 40 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 AND NOW, this s`~day of JF~'T~_ey1,~{Z_ 2001, a Rule has been entered upon the Plaintiff as above directed. Prothonota CERTIFICATE OF SERVICE - , I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for a Rule to File a Complaint upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 EAGER, REINAKER & SPINELLO DATE:O°l~~~1~0) BY: George H. ager quire Attorney for endant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 ., ., ~~ _ ~n a,~ n`, ~~,' <~ ~~ ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROLAND WILLIAMS, III and his wife, LISA M. WILLIAMS, Plaintiffs NO. 01-4590 2001 v. AMY M. WILSON, JURY TRIAL DEMANDED Defendant PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of George H. Eager of the Law Firm of Eager, Reinaker & Spinello as attorney of record on behalf of Defendant in the above captioned action. EAGER, REINAKER & SPINELLO BY: George H! r, Esqui Attorney o Defendant I.D. No 740 1347 F tville Pike Lancaster, PA 17601 (717) 290-7971 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for Entry of Appearance upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 DATE: Qq~o~~~pl EAGER, REINAKER & SPINELLO BY: George H. E Esquire Attorney f efendants I.D. No. 2 40 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 ~ C~: cTa ~ .~ ,. s: [n --~ ~l ~ ~~~~~ Ui ()"5 _ . i -~rn ~~ .. ~i ~ -G ..i ~ r ROLAND WILLIAMS III, and : IN THE COURT OF COMMON PLEAS OF His wife, LISA M. WILLIAMS : CUPvEBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.01-4590 CIVIL TERM v. AMY M. WILSON IN RE: ARBITRATION PANEL ORDER OF COURT AND NOW, June 7, 2004, the Court having been informed that Richard Mislitsky, Esquire, is unavailable for the above-captioned arbitration hearing, Michael Scherer, Esquire, is appointed in his stead. By the Court, Ge rg r, P.J. Bradley L. GrifFie, Esquire 200 North Hanover Street ~~~ L, ~&.oy Carlisle, PA 17013 ~Y Court Administrator i j fJ ~~ ~~,~~ ~~~:fi,3 n~.i~~~ I '„~ Opt ~£ }.~r~ d - Gufli' ~~O~Z ~+ ,~~?~11'a~ r ~i~i1{j r~lls,'~.~iJiJ ll ~~1Li!%~~1~ ~ '', ;~ .~ :~~~rR e. _ _ - - _ ..1111 .-..,_ ~ `~#^r~axxE'~C4P~R?W'nE~cmes~'~fifi3SRar,:~ an _ _ _. .:. ~ol,A~O ~ILtrisrt+iS, J7~- ~ k~s c.y.~cr Lim m. U+l,l,~ FTmSr / ~. Plaintiff ~~ ~ Y fi . [yl / c-S ~ of Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No.~-, N~ V Civil Action -Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. .8~nd1~5 L_ G„~(i~ Name (C ) Law Firm a oo n~. ~ r,o~sl. ~~ Address ~.. Signahue ~Gt"~ C. \C.~SC~ Name ~p,2~Q,petb'', lei isi A+Ks NV~o-c~Sun e~ o.\ '~ ©~ Law Firm Address ignat ire /17,~huz I /~. S~~trri- Name Law Finn ' J ~ /ry. Jo~~ ,~~~ Address ~G_r1,51~ i ~ft 1 `7Dl '3 ear\.,\~e \A ~ZO ~3 (~'~li S LI I~~ ) ?° 13 City, Zip City, Zip City, Zip ~ 1115~f i0117G3 ala oaf Award We, the undersigned arbitrators, having been u~aly appointed and sworn (or affirmed}, make the followin award: (Note: If damages for delay are awarded, they shall be separately stated.) name Date of Hearing: / ~Zpy Date of Award: ir~.~~-~U4 Notice of Entry of Award 'rk~~~~i;..5~: tG90,ev ,.~ Now, the -~-- day of /Y D~, 20 D~_ , at , ~.M., the above award was entered upon the docket and notice thereof given by mil to~the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ ~~ ~~ ~ By: Prothonotary Deputy 0 ,. b„ ti- F:: ~: . J ..r_ it _y `I C t :: :~ ^ 'C ~ f . . f ~ P _1 ~ (_l ~~ -1 I.L G~ ;']e. . ~,7 t-- ~:~' ii s' t r 1 C7 `'' =~ ,- -- y~~.~-e-~.a, ~y ~~.~,Sj~Y _Cc~ ROLAND WILLIAMS, HI and lus wife, LISA M. WILLIAMS Plaintiffs vs. AMY M. WILSON Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUTNY, PENNSYLVANIA NO.Ol-4590-2001 CIVIL ACTION -LAW PRAECIPE TO SETTLE, DISCONTINUE AND END Please mark the above-captioned case settled, discontinued and ended. Respectfully submitted, Joseph J. Dixon, Esquire Attorney No. 28290 126 State Street Harrisburg, PA 17101 (717)236-8515 Attorney for Plainfiff Date: November 29, 2004 S' ~ ~ T]~: _%~'~~- ~ -i'7 fTV %~j ~7 - t -h ' ~ i , -_; P '~-~~ , . • . ~ ~~ ` ~: .. T> ~~ ~~~ 4~ •i.a~ ~. 'tY~`py^. yyi '~i~'.+`9SF N 5i'v'['vm Faw~'4'MF.h'~ft~ i.,s v.{-e, LtS~ m- ~~u,~~.o.S, Plaintiff Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No.~-~ Civil Action -Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties. of our office with fidelity. ~~----- J~ Name ( irman) lac ~'~c d' !~TSa c i~1C3 Law Firm ~ ~ Address C. Signahue ~Gc~ C. \C.SC~ Name ~R.etpe'~~, let 1St Aa~.s ~'YC~Sun a~- a~ ~ ~~ Law Firm Address Signet e mi~~~, ~. s~~U~- Name Q '~~,'~ , ~r, c t• ~ h ~'Cl Law Firm ~~ W. ~~~-~ S/ Address ('~rl,s)~ P,~ r ~vl ~ CG~~.,~~ ~A ~-~0,3 ~~~l,s ~ ia~ ~ ~° ~ 3 City, i Zip City, Zip Ciry, Zip ~ I115-ii ~ 11`163 d/aoa-i, 'ward We, the undersigned arbitrators, having been duly appointed and sworn (or affumed), make the followin award: r (Note: /If~damages for delay are awarded, they shall be sep~az+ately statLed.) ~n ~.l~nr n'r W~c.Jn'li?TS r..'n.e Cim n.~n? a~ ~cY. CDti®. Lla I.QT~'S 'l )e .Arbitrator, dissents. (insert name if applicable. Date of Hearing: f /~eIZJ(yy Date of Award: tr .z~-~U4 -. - t <9c~.vu ,~'' a go_ury Tom/, 4 ° 90.E ~~Nv ""N~~ once of Entry of Award Now, the -~--- day of //N D, 20~, at , ~.M., the above award w entered upon the docket and notice thereof gven by m~a¢¢I to the parties or their attorneys: GU Arbitrators' compensation to be paid upon appeal: $ ~~ ~~ By: Prothonotary Deputy .,