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(',t,rrnd~~r f~.~- ~- ~t - ~~,~ DSB In The Court of Common Pleas of York County, Pennsylvania 2001/05/17 TINA V ROSSON Case Number 1996 SU 04222 Ol VS Case Type Civil Action HEATHER MC KEITHAN APPEARANCES D 001 MC KEITHAN, HEATHER SCHEIB, MICHAEL B 424 E MAIN ST DALLASTOWN PA 17373 P 001 ROSSON, TINA V MAFFfiTT, RICHARD F JR 6 RUSSIAN OLIVE DRIVE ETTERS PA 17319 DOCKET ENTRIES 1996/09/11 PRAECIPE FOR WRIT OF SUMMONS IN CIVIL ACTION 55.00 0098 0214 1996/09/11 WRIT OF SUMMONS ISSUED 0.00 & RETURNED TO ATTORNEY 0098 0214 1996/10/18 SHERIFF RETURN OF SERVICE 25.58 SERVED SUMMONS UPON DEFT HEATHER MC KEITHAN 0127 9/30/96 SHF OF YORK CO 0122 1996/12/30 APPEARANCE ENTERED 0.00 OF LYNN F REUTELHUBER ESQ FOR DEFT W/CERT OF 0151 SERVICE 0070 1997/02/03 PETITION FOR LEAVE TO WITHDRAW APPEARANCE 0.00 W/CERT OF SERVICE 0012 0547 1997/02/21 PETITION TO WITHDRAW APPEARANCE 0.00 W/CERT OF SVC 0019 0410 1997/02/21 ORDER ALLOWING WITHDRAWAL OF COUNSEL 0.00 LYNN F REUTELHUBER ESQ PERMITTED TO WITHDRAW 0019 HER APPEARANCE FOR DEFT BY CT: J C UHLER P J 0410 1999/02/02 APPEARANCE ENTERED 0.00 OF MICHAEL B SCHEIB ESQ FOR DEFENDANT 0013 W/CERT OF SERVICE 0664 i , I ~ 1 i DSB In The Court of Common Pleas of York County, Pennsylvania 2001/05/17 TINA V ROSSON Case Number 1996 SU 04222 O1 VS Case Type Civil Action HEATHER MC KEITHAN DOCKET ENTRIES 1999/02/16 RULE TO FILE A COMPLAINT 0. 00 UPON PLTF 0020 0163 1999/03/02 AFFIDAVIT OF SERVICE 0. 00 OF RULE TO FILE COMPLAINT 0025 0415 1999/03/06 COMPLAINT 0. 00 WITH CERTIFICATE OF SERVICE 0027 0737 1999/03/11 CERTIFICATE OF SERVICE OF 0. 00 DEFT'S INTERROGATORIES & REQ FOR PRODUCTION 0029 OF DOCUMENTS 0365 1999/03/30 ANSWER WITH NEW MATTER 0 .00 W/CERT SVC 0036 0593 1999/04/21 REPLY TO NEW MATTER 0 .00 W/CERT OF SVC 0049 0582 2001/01/31 CERTIFICATE PREREQUISITE TO SVC OF A SUBPOENA 0 .00 W/CERT OF SVC 0013 0138 2001/02/12 CERTIFICATE PREREQUISITE TO SVC OF A SUBPOENA 0 .00 W/ CERT OF SERVICE 0018 0279 2001/03/26 PRE-TRIAL CONFERENCE LIST 0 .00 0034 0030 2001f04f02 CERTIFICATE OF SERVICE OF 0 .00 NOTICE OF DEPOSITION 0036 0811 2001/04/16 ORDER PRELIMINARY TO PRE-TRIAL CONFERENCE 0 .00 BY THE COURT JOHN W THOMPSON JR JUDGE 0043 0453 DSB In The Court of Common Pleas of York County, Pennsylvania 2001/05/17 TINA V ROSSON Case Number 1996 SU 04222 O1 VS Case Type Civil Action HEATHER MC KEITHAN DOCKET ENTRIES 2001/04/16 NOTICE GIVEN RE: PA R. C. P. 236 0.00 0043 0459 2001/05/07 CERTIFICATE OF SERVICE OF 0.00 NOTICE OF DEPOSITION BY MAIL TO RICHARD 0056 MAFFETT JR ESQ 0013 2001/05/16 ORDER DIRECTING CASE BE TRANSFERRED TO 0.00 CUMBERLAND CO TO BE CONSOLIDATED W/PENDING 0061 CASES BY THE, COURT JOHN W THOMPSON JR JUDGE 0043 ** E N D O F C A S E P R I N T O U T ** (PROTRI0) froxa tLo records o£ tlae Ccurk of C:o~m~~on Fleas of ork Gowity--~~~~Sc ~_. thi&_7:J.~LS~_.dc;9 a£.~_A.D. 2i1 !!L_._. r 6tacia N. Gates, P oma2axg* .~~ :~, ~~ ~` a .~ -~ w ~v ~ ~ ~~ ~ ~d (.:i c __ JG7 ?m ~~~ ' :pry ~~ ~~ ,..~ _ ~. GCS ~~~ _ __,. ~,!_~> ~, ~, • : ~. , .. < : 1` ~> -: t (Y~ IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA d TINA V. ROSSON NO. 96-SU-04222-01 E"` . ~ , Plaintiff ~ . ~ off; _ v. ~ ~; ~ :CIVIL ACT-ON -LAW ~'= . ~;, -~, r „ c: ~ ` ,-~ _.- HEATHER McKEITHAN, i , Defendant :JURY TRIAL DEMANDED ~ ORDER :I/~ AND NOW, to wit, this ~S day of May 2001, the Court having been informed #hat the Honorable Kevin A. Hess has entered an Order pursuant to Pa. R.C. P. 213.1 consolidating the above-captioned matter with cases pending in Cumberland County, Pennsylvania, the Prothonotary is ORDERED and DIRECTED to transfer and forward to the Prothonotary of Cumberland County the file and a copy of the docket in this case FORTHWITH. It is further ORDERED and DIRECTED .that a copy of Judge Hess's Order provided herewith be filed and docketed in this Court's records. Further, the Prothonotary is directed to provide notice of this Order and the transmittal of the file to Richard F. Maffett, Jr., Esquire, counsel for Plaintiff, Michele J. Thorp, Esquire, counsel for Defendant Fegan, James G. Nealon, III, Esquire, counsel for Defendant Buffington and Michael B. Scheib, Esquire, counsel for Defendant McKeithan. So Ordered. BY THE COURT, .~,.~ 1~ ompson,Jr.~ CJ ge ~ t~ rccortts ai ttae Coi:.t ~ 4'r this..-,~~d~Y ~A.D. 24 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, : Civil Action -Law Plaintiff vs. No. 96-SU-04222-01 ~-, ~: . -r - :~ -~~ HEATHER McKEITHAN, : JURY TRIAL DEMANDED ° ~`~ ~ ._.t Defendant ~~~. .~ `~ ~* CERTIFICATE OF SERVICE ''~ - cr! AND NOW, this ~ day of May, 2001, I, Michael B. Scheib, a member oar '- the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served the Notice Of Deposition by United States Mail, addressed to the party or attorney of record as follows: Richard F. Maffett, Jr., Esquire 2201 North Second Street Harrisburg, PA 17110 q Supreme Court ID No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 GRIFFITH, STRICKLER, LER AN L M S ALKI Michael cheib Es uire IN THE COUR COMMON PLEAS OF YORK COUNT NNSYLVANIA TINA V. ROSSON v. HEATHER M~'KEITHAN NO. 96-SU-04222-01 CIVIL ACTION -LAW JURY TRIAL DEMANDED TO: COUNSEL FOR PLAINTIFF: RICHARD F. MAFFETT, JR. , ESQUIRE 'c~'3 COUNSEL FOR DEFENDANT: MICHAEL B. SCHEIB, ESQUIRE °°` ORDER PRELIMINARY TO Pa.R.C.P. 272 PRE-TRIAL CONFERENCE c: ._`. ;~ AND NOW, to wit, this 16th day of April , 2001 ,upon the Court's understanding That the litigants. want and deserve a prompt resolution to the matter, since the pleadings are closed and request for Pre-dial' Cortference~ has been made counsel are directed to take the following steps: ~.~ 1. Within seven (7) days of the date of this Order, counsel for Plaintiff shall notify opposing counsel in~turitirig of the names and addresses of all Plaintiffs witnesses. Within seven (7) days after receiving such, defense counsel shall notify opposing counsel in writing of defense witnesses. See York R.Civ.P. 212. Within twenty (20) days of the date of this Order counsel SHALL CONFER personally: a. schedule any depositions and fixing dates for any written discovery and/or responses; b. disclose and exchange any discoverable written statements of the parties or witnesses or other relevant documents not previously disclosed; c. preparation and filing with the Prothonotary within five (5) days of conferring, a Case Management Plan signed by counsel addressing and setting forth: 1.1 The Judge to whom the case is assigned and the date of this Order. 1.2 The need to join additional parties, if any, what will be done to effect such joinder and when such will be accomplished; any necessary pleading amendments. 1.3 A statement of factual issues agreed to and those disputed including the contentions of each party regarding any disputed fact. 1.4 An agreed discovery schedule. 1.5 An estimated deadline to obtain any relevant medical information including any agreement as to how such information is to be obtained. See Pa.R.C.P. 234.1 and Rules 4009.21 - 4009.27. See also York R.Civ.P. 4009 and 4003.5. 1.6 Where multiple counsel are representing a party, the name, address, telephone number and fax number, if any, of lead or primary counsel who will be the only counsel to receive service of Court Orders, notices, etc. 3. When the Case Management has been concluded, counsel for Plaintiff shall have the primary responsibility of writing to the Court setting forth the full caption of the case, all counsel involved and certifying the matter ready for Pre-Trial Conference. Opposing counsel shall be provided a copy and shall have seven (7) days to communicate to the Court any objection to scheduling aPre-Trial Conference. If counsel for either side fails to comply with this Order or the joint Case Management Plan, opposing counsel may request the Court schedule aPre-Trial Conference certifying that party's readiness for trial and setting forth the opposing party's specific non-compliance. So Ordered. HE OURT, Iri J W. "o pso r. dge ~ ~. n vim. ~, 1 ^~ ~n ~J ~\ r1--} (ry-,], ''C.,i €~!~:3&"~ '~-~" ~.,x~.+;y'mrax~ x~re~,~r-s„~e3?:ar~in. 04/16/0 S. MON 15:32 FAX 87714629 ~ OOJ. ~~ **~ TX REPORT *m~ TRANSMISSION OK TX/RX NO 1089 CONNECTION TEL 87573783 SUBADDRESS CONNECTION ID GRIFFITH STRCRLR ST. TIME 04/16 15:31 USAGE T 00'47 PGS. 2 RESULT OK OFFICE OF THE PROTHONOTARY Ot York G~mty Stac"ra N. Gates Piarkomlazy ~ VICky A. G~erher 191Q - :• C3ief 1kptLLy . `~ - Gregdty & GetNe xose Covlvs'f! COU$T HoiTSt: sOk~ ' 'IS Bast' MAt~T B1RE8! Yatt>ti YAtvrn vaut . ' 'a7-T~soNE - Cn77 771-961 t nATE: ~ ll la (G l . FROM: PROTEONOTARY'S OFFICE LOCATION: CORK CD COIIRT~Y~USE TO: ~l~-~I Ct.e,~ i3 ~I~QC,6 LOCATION: SIN# ~j y CD# CONTE'IVTS: ~.~.~,T...~.~,,,.., 1D21190~3D4D3 rwcF.~crn~Ex:. ~'ICo~ ~~ 0 ~a-~-a-- 0 l NUMBER OF PAGES INCLUD11~tG COVER SHEET: ;~-' :,.~~, C~ O IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKEITHAN, Defendant Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this *~ `~'i_day of March, 2001, I, Michael B. Scheib, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served the Notice Of Deposition by United States Mail, addressed„ ..~. -. to the party or attorney of record as followse - _ o __ GJ t=J +._-A Richard F. Maffett, Jr., Esquire ~:' ~_-_ 2201 North Second Street `" Harrisburg, PA 17110 GRIFFITH, STRICKLER, LER LYMO~AL ~S ~ r Micha B. Scheib, Esquire Supreme Court ID No. 63868 110 South Northern Way York, Pennsylvania 17402 (717- 757-7602 D . IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Civll Aotion -Law Plaintiff vs. a No. 96-SU-04222-01 HEATHER McKEITHAN, o JURY TRIAL DEMANDED Defendant . NOTICE OF TAKINf~ DEPOSITIONS TO: Tina V. Ronson c/o Richard F. Maffett, Jr., Esquire 2201 North Second Street Harrisburg, PA 17110 PLEASE TAKE NOTICE that pursuant to Pennsylvania Rule of Civil Procedure No. 4007.1, the Deposition of Tina V. Ronson will be taken upon oral examination, for the purpose of discovery and/or for use at trial, before a Notary Public or before some other person authorized to render an oath, at 1 10 S. Northern Way, York, PA 17402, on Friday, May 4, 2001, at 10:00 a.m, and at any and all adjournments thereof, on all matters not privileged which are relevant and material to the issues and subject matter involved in the above-captioned action and that the above-named Plaintiff is requested to appear at the aforesaid time and place and submit to examination under oath. J i~'"A q 3 ~ GRIFFITH, STRICKLER, LERMAN, SOLYMOS & ~ALKIJV$/ BY: Michel B: Scheib¢'Esc~uu'e ~ Attorney for Defendant McKeithan Supreme Court I.D. #63868 110 South Northern Way York, Pennsylvania 17402 Telephone: (7171757-7602 j .. IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff Civil Action -Law vs. No. 96-SU-04222-01 • o HEATHER McKEITHAN, JURY TRIAL DEMANDED Defendant _ =; - ~ _ ._ c-. PRAECIPE TO LIST CASE FOR PRE-TRIAL CONFERENCE _ - _ ~ __ -Fv To the Prothonotary: Stacia Gates ~ Please list the above-captioned action for apre-trial conference. Additional comments: I have, by copy of this Praecipe, notified all other counsel of record of this listing. Micha I B. Scheib, Esquire Attorney for Defendant, Supreme Court No. 63868 110 S. Northern Way York, Pennsylvania 17402 Telephone No.: 717-757-7602 Dated: March 26, 2001 nr~Q ~,~,,,1w1.~~ii» , gin.. 4~~~li ~;f~ ~t~ ~~I' ~~~1 ~^ , ~`~~3 ~ ,_ + IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Civil Action -Law Plaintiff vs. No. 96-SU-04222-01 HEATHER McKEITHAN, : JURY TRIAL DEMANDED Defendant CERTIFICATE OF SERVICE AND NOW, this 26th day of March, 2001, 1, Michael B. Scheib, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS &CALKINS, hereby certify that I have this date served a copy of the Praecipe to List Case for Pre-Trial Conference by United States Mail, addressed to the party or attorney of record as 0 follows: - - - „a Richard F. Maffett, Jr., Esquire °' 2201 North Second Street ~ %- Harrisburg, PA 17110 '- c.a GRIFFITH, STRICKLER, LERMAN, SOLYMOS &CALKINS Michael B. Scheib; Esquire Supreme Court ID No. 63868 1 10 South Northern Way York, Pennsylvania 17402 (717) 757-7602 Y V ~ ~t`~~~~ .~ ~ ~:~I~~~ v~ ~~f IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON> : Civil Action -Law c? - Plaintiff . -~ ~ va vs. : No. 96-SU-04222-01 `-=' -= ;~ JURY TRIAL DEMANDED -' ~=' ,,v; ~ HEATHER McKEITHAN, ~_ ~` Defendant ~ ~~~ 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, Heather MclCeithan, certifies that: 11) A notice of intent to serve the subpoenas with copies of the. subpoenas attached thereto was mailed or delivered to each party at least twenty 120) days prior to the date on which the subpoenas are sought to be served, or the twenty (201 day period has been waived by opposing counsel. (2) A copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, d3) No objections to the subpoenas have been received, and (4- The subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. _ Date: Michael B. Scheib, Esquire Attorney for Defendant ~~~~ . ;, IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKE1THAN, Defendant : Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4Q09.22 To: Allstate Insurance Comoanv. 6345 Flank Drive. Harrisburg. PA 17112 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: documents submitted in suooort of or in oavment of orooertv damage claims. and anv other documentation in your files. at 110 South Northern Wav. York. PA 17402 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 seasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Michael B. Scheib. Esquire ADDRESS: GRIFFITH. STRICKLER. LERMAN. SOLYMOS & CALKINS 110 South Northern Wav. York. PA 17402 TELEPHONE: (717) 757-7602 SUPREME COURT ID: 63868 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of Court Prothon~k„Gj~ Division 0444809~g2T9 !' ~a IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKEITHAN, Defendant Civil Action -Law No. 96-SU-U4222-01 JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Stetler Dodae. 1405 Roosevelt Avenue. P.O. Box 1908. York. PA 17405 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: _, Midatlantic Drive: Mt. Laurel. NJ 08054, 1994 Dodae Intrepid, date of estimate is aooroximately September 15. 1994 at 110 South Northern Wav York. PA 17402 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 parry making this request at the address Ilsted above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Michael B. Scheib. Esquire ADDRESS: GRIFFITH. STRICKLER. LERMAN. SOLYMOS &.CALKINS 110 South Northem Wav. York. PA 17402 TELEPHONE: (7171757-7602 SUPREME COURT ID: 63868 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of Court Prothonotary /Clerk, Civil Division 04409 18~?18 ~s~ IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs, HEATHER McKEITHAN, Defendant Civil Action v Law No. 96-SU-04222-01 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE ~- AND NOW, this ~ day of ~~ , 2001, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, Esquires, hereby certify that I have, this date, served a copy of Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 by United States Mail, addressed to the party or attorney of record as follows: Richard F. Maffett, Jr., Esquire 2201 North Second Street Harrisburg, PA 17110 klr/mckeith.cer GRIFFITH, STRICKLER, LERMAN, SOLYMOS &CALKINS i BY MICHAEL B. SCHEIB, ES UIRE Attorney for the Defendant Sup. Ct. I.D. No. 63868 110 South Northern Way York, PA 17402 Telephone: (7170 757-7602 044099 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKE1THAN, Defendant Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 a c.. - - Lo -m ,_ n'~ 0 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant, Heather McKeithan, certifies that: (1) A notice of intent to serve the subpoenas with copies of the subpoenas attached thereto was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoenas are sought to be served, or the twenty 120) day period has been waived by opposing counsel. (2) A copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, (3) No objections to the subpoenas have been received, and 141 The subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. Date: ~ 3 4 . ~~ Mic ael B. cheib, Esquire . Attorney for Defendant IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKE1THAN, Defendant Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Dr Robert Zabinski 3028 Market Street. Camo 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: at 110 South Northern Way. York. PA 17402 You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Michael 8. Scheib. Esquire ADDRESS: GRIFFITH. STRICKLER. LERMAN. SOLYMOS & CALKINS 110 South Northem Wav. York. PA 17402 TELEPHONE: (7171757-7602 SUPREME COURT lD: 63868 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of Court Prothonotary /Clerk, Civil Division 03109 .~~ t I IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKEITHAN, Defendant Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED To: Michael Rvan M D Vallev Green Family Practice 1790 Old Trail Road. Suite A. Etters. PA 17319 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the at 110 South Northem Wav York. PA 17402 You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Michael B. Scheib. Esquire ADDRESS: GRIFFITH. STRICKLER. LERMAN. SOLYMOS 8 CALKINS 110 South Northem Wav. York, PA 17402 TELEPHONE: (717) 757-7602 SUPREME COURT ID: 63868 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of Court P k, Civil Division 031090130138 PA 17319: Social Security No. 192-42663. Date Of Birth: 612150. ':~.~,,~ IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKE1THAN, Defendant Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED To: Central Pennsylvania Oral & Maxillofacial Surgeons 2818 Green Street Harrisburo PA 17110 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: at 110 South Northern Wav York. PA 17402 You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Michael B. Scheib. Esquire ADDRESS: GRIFFITH, STRICKLER, LERMAN. SOLYMOS & CALKINS 110 South Northern Wav, York. PA 17402 TELEPHONE: (7171757-7602 SUPREME COURT ID: 63868 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of Court Prl,~ppBtafy /Clerk, Civil Division 0310901-- 3- 013$` ~~. t ~ ~~ V3 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Civil Action -taw Plaintiff vs. No. S6-SU-04222-01 HEATHER McKEITHAN, JURY TRIAL DEMANDED Defendant SUBPOENA TO PRODUCE DOCUMENTS OR TF FOR DISCOVERY PURSUANT TO RULE 4009 To: Arlington Orthopedics 805 Sir Thomas Court Harrisburg PA 17019 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the fallowing documents or things: at 110 South Northern Wav. York. PA 17402 You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Michael B. Scheib. Esquire ADDRESS: GRIFFITH, STRICKLER. LERMAN. SOLYMOS & CALKINS 110 South Northern Wav. York. PA 17402 TELEPHONE: (7171757-7602 SUPREME COURT ID: 63868 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of Court Prothonota/ C~ I irk Civil Division 031090130138 !N THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKEiTHAN, Defendant Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: South Central Neurolocic Associates 805 Sir Thomas Court Harrisburg. pA 17109 Wifhin twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: at 110 South Northern Wav. York. PA 17402 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 aCourt-Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Michael B. Scheib. Escuire ADDRESS: GRIFFITH. STRICKLER. LERMAN. SOLYMOS $ CALKINS 110 South Northem Wav. York. PA 17402 TELEPHONE: (717) 757-7602 SUPREME COURT ID: 63868 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of Court Prothonotary /Clerk, Civil Division ~~.~ IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Civil Action -Law Plaintiff vs. No. 96-SU-04222-01 HEATHER McKE1THAN, JURY TRIAL DEMANDED Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Occupational Rehabilitation and Research Associates 805 Sir Thomas Court. Harrisburg. PA 17109 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: at 110 South Northern Wav York PA 17402 You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought.' if you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: _Michael B. Scheib. Esquire ADDRESS: GRIFFITH. STRICKLER. LERMAN. SOLYMOS & CALKINS 110 South Northern Wav. York. PA 17402 TELEPHONE: (7171757-7602 SUPREME COURT ID: 63868 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of Court Prot qr~q Civil Division { -~ ~.~~ IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKE1THAN, Defendant To: Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED Within riventy (20) days after service of this Subpoena, you are ordered by the Court to produce the foltowirig documents or things: at 110 South Northem Wav. York PA 17402 You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliarice, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Michael B. Scheib. Escuire ADDRESS: GRIFFITH. STRICKLER. LERMAN. SOLYMOS & CALKINS 11.0 South Northern Wav. York. PA 17402 TELEPHONE: X17) 757-7602 SUPREME COURT ID: 63868 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of Court Prothonota 1 r~ivision ~~~ IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKEITHAN, Defendant Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED To: KDV Orthopedics 8 Rehabilitation Ltd. 908 S. George Street. York PA 17403 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: at 110 South Northern Wav York PA 17402 You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have. the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Michael B. Scheib. Escuire ADDRESS: GRIFFITH. STRICKLER. LERMAN. SOLYMOS & CALKINS 110 South Northern Wav. York. PA 17402 TELEPHONE: 1717) 757-7602 SUPREME GOURT ID: 63868 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of Court Prothononntary /Clerk, Civil Division ~~~OJ "'' IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKE1THAN, Defendant Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Michael Gerhart D.C.. 303 S. 32nd Street. Camp Hill. PA 17011 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: at 110 South Northern Way York. PA 17402 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 cast of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Michael B. Scheib. Esquire ADDRESS: GRIFFITH. STRICKLER. LERMAN. SOLYMOS & CALKINS 110 South Northern Wav, York, PA 17402 TELEPHONE: (7171757-7602 SUPREME COURT ID: 63868 ATTORNEY-FOR: Defendant BY THE COURT: DATE: Seal of Court Prothonotary /Clerk, Civil Division 03109013Q138 ~~~- . IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKEITHAN, Defendant Civil Action -Law No. 96-SU-04222-01 JURY TRtAt DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Dr. Steven Moroanstein. 805 Sir Thomas Court. Harrisburo. PA 17109 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: at 110 South Northern Wav. York. PA 17402 You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliahce, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Michael B. Scheib. Esquire ADDRESS: GRIFFITH. STRICKLER. LERMAN. SOLYMOS & CALKINS 110 South Northern Wav. York. PA 17402 TELEPHONE: (717) 757-7602 SUPREME COURT ID: X868 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of Court ProthoA~ivil Division 03109Q 130138 ~,~ ~v~- IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKEITHAN, Defendant Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR' DISCOVERY PURSUANT TO RULE 4009.22 To: Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: Co~lete first-oartv benefits file oertainina to Tina V Rosson Date of Birth: !?aLrment of orotaerty damage claims and any other documentation in your files. The last known adjuster was B. Kelliehan. at 110 South Northern Wav York PA 17402 You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Michael B. Scheib. Esquire ADDRESS: GRIFFITH, STRICKLER. LERMAN, SOLYMOS & CALKINS 110 South Northern Wav. York PA 17402 TELEPHONE: L17) 757-7602 SUPREME COURT ID: 63868 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of Court ~;~..1~Q..q~,~.,- Q Pr~th'drfo~a'r~o/~I~rk, Civil Division ~:~ IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKEITHAN, Defendant Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: at 110 South Northern Wav York PA 17402 You may deliver or mail legible copies of the documents or produce things requested by this Subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this Subpoena, within twenty (20) days after its service, the party serving this Subpoena may seek a Court Order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Michael B. Scheib. Escuire ADDRESS: GRIFFITH. STRICKLER. LERMAN. SOLYMOS & CALKINS 110 South Northern Wav. York, PA 17402 TELEPHONE: X17) 757-7602 SUPREME COURT ID: 63868 ATTORNEY FOR: Defendant COURT: DATE: C3109413p138 Seal of Court Prothonotary /Clerk, Civil Division cCF43P.p:' notes, documents submitted in suooort of or in oavment of Drooertv damage claims, and anv other documentation in vour files. The-last known adjuster was K. Eaan. r env' IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKEITHAN, Defendant Civil Action -Law No. 96-SU-04222-01 : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, thisJI - day of y ~~~1~ , 2001, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, Esquires, hereby certify that I have, this date, served a copy of Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 by United States Mail, addressed to the party or attorney of record as follows: Richard F. Maffett, Jr., Esquire 2201 North Second Street Harrisburg, PA 17110 GRIFFITH, STRICKLER, LERMAN, SOLYMOS &CALKINS klr/mckeith.cer BY ~ 1~~~~~~~~G%~~"v/V MICHAEL B. SCHEIB, ESQUIRE Attorney for the Defendant Sup. Ct. I.D. No. 63868 1 10 South Northern Way York, PA 17402 Telephone: (717) 757-7602 p J RICHARD F. MAFFETT, JR., ESQUIRE SUPREME CouRT ID# 35539 2ZO1 NORTH SECOND STREET xARRxseURG, PA 17110 717-233-4160 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL DIVISION -- - TINA V. ROSSON, Plaintiff v HEATHER McKEITHAN, Defendant File No. 96-SU-04222-01 PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER AND NOW, this Zo~~ day of April, 1999, comes the Plaintiff, TINA V. ROSSON, by her attorney, Richard F. Maffett, Jr., Esquire, and respectfully represents the following: ~.~ __ 4~ 19. Denied. Plaintiff incorporates the averments of m ~4~ Paragraphs 1 through 18 of her Complaint herein as thoughY:~~11~; set forth at length. -r: ~- -~ ~> ~_, 20. Denied. Plaintiff was not involved in any motor vehicle crr accident prior to September 15, 1994. 21. Denied. Plaintiff had not suffered injuries in a motor vehicle accident before September 15, 1994. 22. Admitted. 23. Admitted. 24. Denied. The injuries alleged by Plaintiff in her Complaint were suffered by Plaintiff as a result of the motor vehicle accident involving Defendant on September 15, 1994, and were not caused by events either before or after said accident. 25. Denied. Plaintiff's injuries were directly and proximately caused by the negligent acts and omissions of Defendant McKeithan and not by the acts or omissions of any third party. 26. Denied. This paragraph is a conclusion of law to which no responsive pleading is required. By way of further .answer, it is denied that Plaintiff was negligent in any way, and/or that any alleged negligence on the part of Plaintiff caused or contributed to her injuries. 27. Denied. This paragraph is a conclusion of law to which no responsive pleading is required. 28. Denied. This paragraph is a conclusion of law to which no responsive pleading is required. 29. Denied. This paragraph is a conclusion of law to which no responsive pleading is required. 30. Admitted. 31. Denied. In Plaintiff's other lawsuits, she has sought recovery for damages from injuries she suffered in other automobile accidents which created the causes of actions which ~. w led to those lawsuits, and not for damages from injuries she suffered in the automobile accident with Defendant McKeithan. Plaintiff demands judgment in her favor and against Defendant, dismissing Defendant's New Matter with prejudice, and denying all relief requested therein. Respectfully submitted, Richard F. Maffett, ., Esquire ~~:,:~ ~~ ~. s 11 ~~a~~~~~,~~~~io~~,~~~.~~~, I, TINA V. ROSSON, have read the foregoing Plaintiff's Reply To Defendant's New Matter and hereby affirm that it is true and correct to the best of my knowledge, or information and belief. This verification and statement is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities; I verify that all statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa. C.S.A. §4904. Dated: y~~y~ggq /) 2 a~a..efi'' . ROSSO , Plaintiff Pv .~ it ~~,:'~~~~~ia~~',ul~ ~~ IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL DIVISION TINA V. ROSSON, Plaintiff File No. 96-SU-04222-01 v HEATHER McKEITHAN, Defendant CERTIFICATE OF SERVICE The undersigned hereby certifies that he served a true and correct copy of the foregoing Plaintiff's Reply To Defendant's New Matter upon counsel of record by depositing same in the United States Mail, postage prepaid, at Harrisburg, PA, addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 Dated: ~~~~~~ //'</L/l d~ /~l~/~~_ Richard F. Maffet ,`Jr., Esq. ` a`"~°,^ 4~ RICHARD F. MAFFETI', JR. Attorney at Law 2201 North Second Street Telephone Harrisburg, Pennsylvania 17110 (717) 233-4160 April 20, 1999 Fax (717) 233.2342 Office of the Prothonotary -- York County Court House `~~~ 28 East Market Street -' York, PA 17401 _, ~: ~> ;_, = ...- RE: Rosson v McKeithan -_ No. 96-SU-04222-01 Dear Sir or Madam: Please find enclosed Plaintiff's Reply To Defendant's New Matter (original and 1 copy) for filing in the above- captioned matter. Kindly return a time-stamped copy to me in the self-addressed, stamped envelope provided. Should you have any questions, or require anything additional, please contact me. Wit best regards, ~' ~ ~~ Richard F. Maffett, J RFM/cs Enclosures cc: Michael B. Scheib, Esquire (w/enc) IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKEITHAN, Defendant : Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Tina V. Rossen c/o Richard F. Maffett, Jr., Esquire 2201 North Second Street Harrisburg, PA 17110 ~. Q„ ~=; N -n p W ~o ~ ` N You are hereby notified to file a written response to the enclosed New Matter within twenty 1201 days from service hereof or a judgment may be entered against you. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS MICHAEL B. SCHEIB, ESQUIRE Attorney for Defendant Supreme Court I.D. No. 63868 110 S. Northern Way York, PA 17402 Telephone: 717-757-7602 c-~ _< G r~ s- .~ r; -~'' 5' u t IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Civil Action -Law Plaintiff vs. : No. 96-SU-04222-07 HEATHER McKEITHAN, JURY TRIAL DEMANDED Defendant ANSWER WITH NEW MATTER COME NOW, Defendant Heather McKeithan by and through her attorneys, Griffith, Strickler, Lerman, Solymos & Calkins, and Michael B. Scheib, Esquire in response to the allegations in Plaintiff's Complaint as follows: 1. Denied. After reasonable investigation Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 1 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 2. Denied. Defendant McKeithan's correct address is 26 Plank Road, Shrewsbury, Pennsylvania. 3. Admitted in part and denied in part. It is admitted that the date time and location is correct. The allegations regarding the vehicle and which lane Plaintiff was traveling in are denied. After reasonable investigation Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 3 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 4. Admitted in part and denied in part. Defendant denies the allegations about the number of vehicles between her can and Plaintiff's car. After reasonable investigation, D O answering Defendant is without knowledge or information sufficient to form a belief as to the teruth or veracity of the allegations contained in paragraph 4 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 5. Denied. After reasonable investigation Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 5 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 6. Admitted in part and denied in part. It is admitted that the Defendant's vehicle came into contact with the Johnson vehicle. The remaining allegations are denied. After reasonable investigation Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 6 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 7. Denied. This paragraph states a legal conclusion to which no response is required. 8. Denied. This paragraph states a legal conclusion to which no response is required. 9. Denied. This paragraph states a legal conclusion to which no response is required. It is specifically denied that the negligence of Defendant McKeithan consisted of: a. failing to keep her vehicle under proper and adequate control; b. failing to keep alert and maintain proper lookout for the presence of other motor vehicles on the streets and highways; c. operating her vehicle in careless disregard for the rights, safety and position of others; d. traveling too fast for conditions; 2 e. following too closely; f. failing to apply her brakes in time to avoid striking another vehicle; g. failing to operate with the skill and care required to safely operate a vehicle and, h. operating her vehicle in violation of the Commonwealth of Pennsylvania. On the contrary, at all times relevant Defendant McKeithan operated her vehicle in a lawful, careful, safe and prudent manner and with due care as required by the circumstances. 10. Denied. After reasonable investigation Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 10 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 11. Denied. After reasonable investigation Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 11 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 12. Denied. After reasonable investigation Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 12 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 13. Denied. After reasonable investigation Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 13 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 14. Denied. After reasonable investigation Answering Defendant is without 3 knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 14 of Plaintiff°s Complaint and same are denied and strict proof thereof is demanded. 15. Denied. After reasonable investigation Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 15 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 16. Denied. After reasonable investigation Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 16 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 17. Denied. After reasonable investigation Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 17 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. 18. Denied. After reasonable investigation Answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 18 of Plaintiff's Complaint and same are denied and strict proof thereof is demanded. WHEREFORE, Defendant McKeithan respectfully requests this Honorable Court to enter judgment in her favor and against Plaintiff together with the costs of this lawsuit. BY WAY OF FURTHER DEFENSE: NEW MATTER OF DEFENDANT McKEITHAN 19. Paragraphs 1 through 18 of Defendant's Answer with New Matter are 4 incorporated herein as though fully set forth at length. 20. Plaintiff was involved in a motor vehicle accident or accidents prior to September 15, 1994. 21. Plaintiff had suffered injuries in the prior motor vehicle accident or accidents. 22. Plaintiff has been involved in motor vehicle accidents since September 15, 1994. 23. Plaintiff has suffered injuries in the accidents since September 15, 1994. 24. Plaintiff's injuries, if any, were caused by the events that either pre-dated or post-dated the motor vehicle accident which is the subject of this lawsuit. 25. Plaintiff's injuries, if any, were caused by the acts and omissions of a third party over whom Defendant McKeithan had no control. 26. Plaintiff's injuries, if any, were caused by Plaintiff°s contributory and/or comparative negligence. 27. Plaintiff fails to state a cause of action upon which relief can be granted. 28. Plaintiff's claim may be barred by the applicable Statute of Limitations. 29. Plaintiff's claim may be barred or limited by the Pennsylvania Motor Vehicle Financial Responsibility Law. 30. Plaintiff has filed other lawsuits. 31 . In these other lawsuits Plaintiff has sought recovery for the same damages as she attempts to recover in this action. WHEREFORE, Defendant McKeithan respectfully requests this Honorable Court to enter judgment in favor of Defendant McKeithan and against Plaintiff Rosson, together with the costs of suit. 5 Respectfully submitted, GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS MIC1iA'EL B. SCHEIB, ESQUIRE Attorney for the Defendant Sup. Ct. I.D. No. 63868 110 South Northern Way York, PA 17402 Telephone: (717) 757-7602 6 VERIFICATI®N I verify that the foregoing facts are true and correct, upon my personal knowledge or information and belief. This verification is made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: 3l a~~ ~ R5 ~.uc.~_h.¢~. 7n `/ce t`~tt uiY. i Heather McKeithan -~; . _. IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKEITHAN, Defendant Civil Action -Law : No. 96-SU-04222-01 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this ~~ of /~1 iL/G ~\ 1999, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS &CALKINS, Esquires, hereby certify that I have, this date, served a copy of Defendant's Answer and New Matter by United States Mail, addressed to the party or attorney of record as follows: Richard F. Maffett, Jr., Esquire 2201 North Second Street Harrisburg, PA 17110 GRIFFITH, STRICKLER, LERMAN, SOLYMOS &CALKINS ark/MBS/mckeith.anm BY ----1~ - /" MICHAEL B. SCHEIB, ESQUIRE Attorney for the Defendant Sup. Ct. I.D. No. 63868 110 South Northern Way York, PA 17402 Telephone: (717) 757-7602 Richard F. Maffett, Jr., Esquire supreme court ID# 35539 2201 North Second Street ATTORNEY FOR PLAINTIFF Harrisburg, PA 17110 717-233-4160 '% L: IN THE COURT OF COMMON PLEAS OF q c~ YORK COUNTY, PENNSYLVANIA ~~^~= ,~ CIVIL DIVISION TINA V. ROSSON, Plaintiff v HEATHER McKEITHAN, Defendant ~~ 2, ` 3 c~ ~ ~ n, ,,,,, ti File No. 96-SU-04222-01 O 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(s). You may lose money or property or other rights important to you. YOU 3HOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DON'T 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. Lawyer Referral Service of The York County Bar Association The York County Bar Center 137 East Market Street York, Pennsylvania 17401 Telephone: 717-854-8755 NOTICIA LE HAN DEMANDADO A USTED EN LA CORRE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogad µ~~y~$ 'YN.V ~~ en la Corte en 7.P i, IR,~J k 6 iv z-, ] ~3~ ~~ forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la torte tomaro medidas y puede entrar una Orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la petition do demanda. Usted puede perder dinero 0 sus propiedades o otros derechos importantes para usted. LLEVE ESTA DSMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGAGO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIER ASISTENCIA LEGAL. Lawyer Referral Service of The York County Bar Association The York County Bar Center 137 East Market Street York, Pennsylvania 17401 Telephone: 717-854-8755 ami~a~~ '~~~ C IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL DIVISION TINA V. ROSSON, Plaintiff File No. 96-SU-04222-01 v HEATHER MoREITHAN, Defendant COMPLAINT AND NOW, this 5th day of March, 1999, comes the Plaintiff, TINA V. ROSSON, by her attorney, Richard F. Maffett, Jr., Esquire, and respectfully represents the following: 1. The Plaintiff, Tina V. Rosson, is an adult individual residing at 6 Russian Olive Drive, Etters, York County, Pennsylvania, 17319. 2. Defendant, Heather McKeithan, is an adult individual residing at 424 East Main Street, Dallastown, Pennsylvania, 17373. 3. On September 15, 1994, at or about 7:40 a.m., the Plaintiff was operating her vehicle North on Interstate Route 83 in the passing lane, approximately .1 mile North of Exit 16 in Fairview Township, York County, Pennsylvania. 4. At that time and place, Defendant was operating her vehicle, headed North on Interstate Route 83 in the passing lane, three (3) cars to the rear of the vehig.l~f~,lintiff. 5. At the aforesaid time and place, traffic ahead of Plaintiff in Plaintiff's lane slowed and came to a complete stop, causing Plaintiff, and the two (2) cars behind Plaintiff, to slow and then come to a complete stop. 6. At that time and place, the Defendant failed to stop her vehicle and the front of Defendant's vehicle struck the rear of an automobile operated by Diane J. Johnson, the force of which caused the front of the Johnson vehicle to strike the rear of an automobile operated by John S. Schultz, which said impact caused the front of the Schultz vehicle to strike the rear of Plaintiff's vehicle, as a result of which Plaintiff suffered severe physical injury. 7. Said collision resulted from the negligence of Defendant and was due in no manner whatsoever to any act or failure to act on the part of Plaintiff. 8. Defendant owed a duty to other lawful users of the roadways in the Commonwealth of Pennsylvania to operate her vehicle in such a way as not to cause harm or damages to said other persons and to the Plaintiff in particular. 9. The negligence of Defendant consisted of the following: (a) failing to keep her vehicle under proper and adequate control; (b) failing to keep alert and maintain a proper lookout for the presence of other motor vehicles o t sgtreets and highways; e .r x.i ~ ~ 2 (c) operating her vehicle in careless disregard for the rights, safety and position of others; (d) traveling too fast for conditions; (e) following too closely; (f) failing to apply her brakes in time to avoid striking another vehicle; (g) failing to operate the vehicle with the skill and care required to safely operate such a vehicle; and, (h) operating her vehicle in violation of the laws of the Commonwealth of Pennsylvania; 10. As a direct and proximate result of the aforesaid collision, Plaintiff suffered injuries including, but not limited to, the following: (a) cervical, thoracic and lumbar sprain/strain; (b) sacroiliac strain; (c) traumatic bursitis in her left shoulder; (d) trapezius strain; (e) costochondritis of the anterior ribs; (f) left shoulder and left arm pain and numbness; (g) chronic headaches; (h) facial and jaw pain; (i) right temporomandibular rjoint inflammation; ,~ t ~, ~ ~ G 3 (j) fibromyalgia; anal (k) chronic myofascial pain. 11. Plaintiff suffered from pre-existing Temporomandibular Joint disease (TMJ), which was aggravated by the aforesaid collision, and the resulting injuries and treatment therefrom. 12. As a direct and proximate result of the aforesaid collision, Plaintiff suffered aggravation of pre-existing injuries including, but not limited to, the following: (a) cervical degenerative disc disease; (b) lumbar degenerative disc disease; (c) left shoulder bursitis; (d) trigeminal neuralgia; and (e) headaches. 13. As a result of the injuries she received in this collision, Plaintiff has in the past, and may incur in the future, reasonable and necessary medical and rehabilitative costs and expenses for treatment of her aforesaid injuries. 14. As a further result of this collision, the Plaintiff has suffered a loss of earnings, and impairment of her earning capacity and power, and claim is made therefore. 15. As a further result of this collision, the Plaintiff has suffered a permanent disability and permanent diminution of her earning power and capacity. 4~~s~`a~~ ~ ~ C,~ 16. As a further result of the aforesaid collision, the Plaintiff has suffered permanent diminution of her ability to enjoy life and life's pleasures. 17. As a result of the injuries she received in this collision, Plaintiff has undergone in the past, is undergoing in the present, and will undergo in the future great pain and suffering. 18. As a direct and proximate result of this collision, the Plaintiff has incurred other financial expenses or losses which exceed the sums recoverable under the limitations and exclusions of the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, Plaintiff demands judgment against Defendant, in an amount in excess of Thirty Thousand ($30,000.00) Dollars, exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. Respectfully submitted, d~~' "" U 1 Richard F. Maffet Jr., squire ~~ VERIFICATION I, TINA V. ROSSON, have read the foregoing Complaint and hereby affirm that it is true and correct to the best of my knowledge, or information and belief. This verification and statement is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities; I verify that all statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa. C.S.A. X4904. Dated: 3159 ~ /lin.R~' A V. ROSS ,Plaintiff i I bl IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA CIVIL DIVISION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . TINA V. ROSSON, Plaintiff File No. 96-SU-04222-01 v HEATHER McKEITHAN, Defendant CERTIFICATE OF SERVICE The undersigned hereby certifies that he served a true and correct copy of the foregoing Complaint upon counsel of record by depositing same in the United States Mail, postage prepaid, at Harrisburg, PA, addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402 Dated: 03/05/99 ~~~/'J ~ ~/~~ Richard F. Maffett, Jr. Esq. ~~AI ~~~ :.,~ ,~ 1 W r~ ; IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Civil Action -Law Plaintiff ~, ,. w ~ ~ vs. No. 96-SU-04222-01 -~~~^; ca - . :~--_' " HEATHER McKEITHAN, JURY TRIAL DEMANDED m~ - _ Defendant - ~' CERTIFICATE OF SERVICE~Q AND NOW, this ~ day of 1999, I, Michael B. -~ Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, Esquires, hereby certify that I have, this date, served a copy of Defendant's Interrogatories and Request for Production of Documents to Plaintiff by United States Mail, addressed to the party or attorney of record as follows: Richard F. Maffett, Jr., Esquire 2201 North Second Street Harrisburg, PA 17110 GRIFFITH, STRICKLER, LERMAN, SOLYMOS &CALKINS ark/MBS/mckeith.int MICHAEL B. SCHEIB, ESQUIRE Attorney for the Defendant Sup. Ct. I.D. No. 63868 110 South Northern Way York, PA 17402 Telephone: (717) 757-7602 ~, '~~%~~~~~„I'I'1~P y IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Civil Action -Law Plaintiff vs. : No. 96-SU-04222-01 ~y T ~ HEATHER McKEITHAN; : JURY TRIAL DEMANDED ~ _ Defendant ~ ~- ~ r ---: ~ - -' -~; ~, AFFIDAVIT OF SERVICE ~. _ ry ~ ~ ~`~+ ~ ~ COMMONWEALTH OF PENNSYLVANIA N ~' ss -~' COUNTY OF YORK Before me, a Notary Public in and for said Commonwealth and County, personally appeared Michael B. Scheib, Esquire, who being duly sworn according to law, deposes and says that he caused to be served on Richard F. Maffett, Jr., Esquire, a true and correct copy of the original Rule to File Complaint filed in the above captioned mater, by certified mail, as evidenced by the enclosed receipt for certified mail, on the 17th day of February, 1999. ~uG~~rs r.C / MICHAEL B. SCHEIB, ESQUIRE Sworr, and su5scribed to befor me this c~`~L' day of ~~{~ 1999. tar~i ublicublic My Commission Expires: d/CGU~-~-3 ~°~ Notanal Seal Angela R. Kovacs. Notary Public SpringeasDUry Twp., York County My Commission Expires May 13.2002 Member, Pennsylvania Association of Notaries i~ s 2 ~ y ,k ~~ ... r e C: C a c u c Z 316 9~,7 6D2 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for Intematlonal Mail See reverse i R AFd=r & Number D KTFt 5~,~0 S Postote~e stata,a~ coda (~ /,7/ h l P~ st age ,$ Certified Fee d , Spatial Delivery Fee ResldrAed Delivery Fee 0 ~ Relum Receipt Showing to ' Wham & Date Delivered ~ + fiehun ReceiplShowingm WMm, • Date,BAddressee'sAddlass ~ TOTAL Postage & Fees ~ $ D Postmark or Dat i ~ I/ ~~n~ ~ / 7 Q~ SENDER: t slap wish to receive the .Complete items 1 and/or 2 for additional services. folOW ing SONICBS (for an • Complete items 3, 4a, and 4b. - .Print your name and address on the reverse of this Corm so that we can return this extra fee): ~ cab to you. • Attach his form to the front of the mailpiece, or on the back if space does not 1. ^ AddreSSee'S AddreSS ,E Z permit. • Write "Refum Receipt Requested"on the mailpiece below the article number. 2. ^ Restricted Delive ry .The Return Receipt volt show to whom the article was delivered and the date Consult postmaster for fee. g delivered. 0 3. Article Addressed to: 4-a-~. Article Number /~ g/7 ~~~ m {ZIGNAKQ ~ M~FF~.TP7 ab erv~ c [~ ^ Registered `.Certified d v m ~1 ®~ ~~.,~c p 5~~~,j~ S' ~ ^ Express Mall ^ Insured ~ O~ (~ ^ Return Recejpt for Merchandise ^ COD 5 ~~,~ ~~R/ P~ ~~//~ 7. Date of Del, ery ~ o `~i o 5. Received By: (Print Name) 8. Addresse ''s Ad ass (Only if requested m and tee i paid) ~ r 6. Sign t e• ( dress o Ag t) ~ 9 T C. ~^ Ps Form, 11,',pecembe+isy ~ ,o2sss-sa-a-o22s Domestic Retum Receipt ~~I~~~t~~.fl ~ r.-.,~„ ~,..,.~ IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKEITHAN, Defendant Civil Action -Law : No. 96-SU-04222-01 : JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please enter a Rule upon Tina V. Rosson, Plaintiff, to file a Complaint within twenty 1201 days from the date of the service of this Rule or suffer Judgment non-pros. GRIEFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS BY _ ' MIC AEL B. CHEI , ESQ IRE Attorney for Defendant Sup. Ct. I.D. No. 63868 110 South Northern Way n York, PA 17402 0~ Telephone: 1717) 757-7602 ~=-; Ll / x ~ Dated: y/o~-ll{o ~~~ ~~ D ~ r NOW, ~w' (/ ~ 1999, RULE ISSUED AS ABOVE. S ~~.~. PROTHONOTARY acs - .ta - -~ = m ~.:, rn '~ r~, ~ T ~' ~.~~ _: .C F; BY: Gvl+.~tx- ~ ~7~~~. ~. DEPUTY 1' t IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff vs. HEATHER McKEITHAN, Defendant Civil Action -Law No. 96-SU-04222-01 JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE PURSUANT TO Pa.R.C.P, 1012 TO THE PROTHONOTARY: Kindly enter the appearance of Michael B. Scheib, Esquire, of Griffith, Strickler, Lerman, Solymos & Calkins, as attorneys for the Defendant, Heather McKeithan, in': the above-captioned matter and mark the docket accordingly. ,_' GRIFFITH, STRICKLER, LERMAN, ' , SOLYMOS & CALKINS -~ ~- BY ©~ ,' MICHAEL B. SCHEIB, U E Attorney for the Defendant Sup. Ct. I.D. No. 63868 110 South Northern Way York, PA 17402 Telephone: (7171757-7602 Date: D IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA TINA V. ROSSON, Plaintiff Civil Action -Law vs. No. 96-SU-04222-01 HEATHER McKEITHAN, JURY TRIAL DEMANDED Defendant CERTIFICATE OF ERVICE AND NOW, this ~ay of , 1999, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS &CALKINS, Esquires, hereby certify that I have, this date, served a copy of a Praecipe for Entry of Appearance by United States Mail, addressed to the party or attorney of record as follows: Richard F. Maffett, Jr., Esquire 2201 North Second Street Harrisburg, PA 17110 GRIFFITH, STRICKLER, LERMAN~' SOLYMOS &CALKINS t `_ BY MI HAEL B. SCHEIB, ESOUIR Attorney for the Defendant Sup. Ct. I.D. No. 63868 110 South Northern Way York, PA 17402 Telephone: (7171757-7602 - ~~.?+ 3`M*. bRe'.ti+nbk"~P;5F1"~-may. ~ .. Y - - I ;~v,~^r,~.,,.T ~. +~:aca:.x~w~ .. r.-crwz~.,sw~q_a~:w.xn~« ~ .. TINA V. ROSSON, v. Plaintiff HEATHER McKEITHAN, Defendant IN TP:E COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA NO. 96-SU-04222-01 CIVIL ACTION - LAW ORDER AND NOW, this ,~/ST day of ~E~~~~~j 1997, upon consideration of the Petition of Defendant's Co/unsel for Leave to Withdraw, it is hereby ORDERED and DECREED that said petition is GRANTED and that Petitioner, Marshall, Dennehey, Warner, Coleman and Coggin and Lynn F. Reutelhuber, Esquire, be permitted to withdraw her appearance of record for the Defendant in the above matter. f t~ ~ ~;3 ` `t t __ __ __ ..,~ T~ y ~~ ~ ~~; G) 'S ~ C -~? l~ y ~` ............. CERTIFICATE OF SERVICE I, Susan M. Williams, an employee of Marshall, Dennehey, Warner, Coleman & Coggin, do hereby certify that on this 31st day of January, 1997 served a copy of the foregoing document via First Class United States mail, postage prepaid as follows: Richard F. Maffett, Jr., Esquire 2201 North Second Street Harrisburg, PA 17110 SUSAN M. WILLIAMS If,~~~~,a~''~4;~ ~ ~~"~' ~ ~,j TINA V. ROSSON, Plaintiff v. HEATHER MCKEITHAN, Defendant IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLVANIA NO. 96-SU-04222-01 CIVIL ACTION - LAW ORDER AND NOW, this day of 1997, upon consideration of the Petition of Defendant's Counsel for Leave to Withdraw, it is hereby ORDERED and DECREED that said petition is GRANTED and that Petitioner, Marshall, Dennehey, Warner, Coleman and Goggin and Lynn F. Reutelhuber, Esguire, be permitted to withdraw her appearance of record for the Defendant in the above matter. J. TINA V. ROSSON, IN THE COURT OF COMMON PLEAS OF Plaintiff YORK COUNTY, PENNSYLVANIA v. NO. 96-SU-04222-01 HEATHER McKEITHAN, CIVIL ACTION - LAW Defendant o `'~i _, y -" m. cn R' en ~} nit PETITION OF DEFENDANT'S COUNSEL _ ~ ~ ~ FOR LEAVE TO WITHDRAW HER APPEARANCE - ~~ "" _ <'? < . -o : r~+ ~.o z The petition of Marshall, Dennehey Warner, Coleman an~1j ":` ° ,~ Goggin and Lynn F. Reutelhuber, Esquire respectfully represent "~ 1. This law suit was initiated by the filing a writ of summons on September 11, 1996 against Defendant, Heather McKeithan (hereinafter referred to as "Defendant".) 2. On December 30, 1996, Petitioner entered an appearance with the Court for the Defendant. 3. Petitioner was retained by Atlanta Casualty Companies to defend the interests of the Defendant in this case. 4. As this matter was initiated by a writ of summons, the exact nature of the claim against Defendant was unknown at the time of the filing of the entry of appearance. 5. Defendant had automobile coverage with Atlanta Casualty Companies from June 28, 1996 to December 28, 1996. 6. On July 21, 1996, Defendant`s boyfriend had been involved in a motor vehicle accident in North Carolina, which occurred during the Defendant's policy period of coverage with Atlanta Casualty Companies. 7. Believing that the present action may have arisen out of that July 21, 1996 accident, the ~,~fas retained to °: ,y a enter an appearance for the Defendant and to defend the Defendant in this suit by Atlanta Casualty Companies. 8. However, on January 29, 1997, Petitioner was informed that the lawsuit at hand arose out of a September 15, 1995 motor vehicle accident, during a telephone conversation with counsel for the Plaintiff. 9. On January 30, 1997, counsel for the Plaintiff forwarded a copy of the police report to the Petitioner, which indicated that Defendant, at the time of the accident, had coverage through TICO Insurance Co. 10. Upon a phone call with a representative of TICO, the Petitioner confirmed that TICO was aware of the suit, and had been in contact with Plaintiff's counsel, concerning the Defendant, through her policy with TICO. 11. Therefore, there is no authority by TICO to represent the Defendant in this case, and there is no coverage by Atlanta Casualty Companies, who had retained the Petitioner to represent the Defendant concerning the accident out of which this lawsuit arises. 12. Moreover, no Complaint has been filed by the Plaintiff in this case, so that no responsive pleading is due and owing at this time. 13. Hence, good cause exists therefore under Rule 1.16(c)(5) of the Pennsylvania Rules of Professional Conduct for Petitioner's withdrawal. WHEREFORE, Petitioner respectfully requests that this Court '~~~~~s" .. grant Petitioner leave to withdraw her appearance for the Defendant in this action. MARSHALL, DENNEHEY, COLEMAN AND GOGGIN BY: LYNN F. RErTTELHUBER, ESQUIRE 100 Pine Street, Fourth Floor P.O. Box 803 Harrisburg, PA 17108-0803 (717) 232-4641 I.D. No. 66887 ATTORNEYS FOR DEFENDANT DATE: Janaury 31, 1997 '~~ ~ ~' CERTIFICATE OF SERVICE I, Susan M. Williams, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this 31st day of January, 1997 served a copy of the foregoing document via First Class United States mail, postage prepaid as follows: Richard F. Maffett, Jr., Esquire 2201 North Second Street Harrisburg, PA 17110 cam- ~ L~LU,ux~a~~ SUSAN M. WILLIAMS ~--V LAW QFFICES MARSHALL; DENNEHEY, WARNER ALI.ENTOWN, PENNSYLVANV, COLEMAN ~ GOGGIIV (610) 776.7500 FAX: (610) 776.7994 DOYLESTOWN, PENNSYLVANIA (215) 348-1611 A PROFESSIONAL CORPORATION FAX: (215) 348.5439 LANCASTER, PENNSYLVANIA (717)399-1845 FAX: (717) 399.1853 MEDIA, PENNSYLVANIA (610) 892.8700 FAX: (610) 892-8730 NORRISTOWN, PENNSYLVANIA (610) 292-4440 FAX: (610) 292-0410 100 PINE STREET, 4TH FLOOR P.O. BOX 803 [-L4RRISBURG, PENNSYLVANIA 17108A803 (717) 232-1022 CABLE ADDRESS-MARSHALL FAX: (7t7) 232-1849 PITTSBURGH, PENNSYLVANIA (412) 3944090 FAX: (412) 232-3655 January 31, 1997 Stacia N. Gates, Prothonotary York County Courthouse 28 E. Market Street York, PA 17401 RE: Rosson v. McKeithan CCP (York County) No. 96-SU-04222-01 Our File No. 20614-00109.307 Dear Ms. Gates: PHILADELPHW, PENNSYLVANIA (215) 575-2fi00 FAX: (215) 575-0856 SCRANTON, PENNSYLVANIA (717) 342.1999 FAX: (717) 342-0999 WEST CHESTER, PENNSYLVANIA (610) 431.4100 FAX: (6I0) 4314522 MARLTON, NEW JERSEY (609) 985-3900 FAX: (609) 985-3934 ROSELAND, NEW JERSEY (201) 994-0303 FAX: (20q 9944965 WILLIAMSPORT, PENNSYLVANIA (711) 326-9091 FAX: (717)326-5507 Direct Dial 232-4641 Enclosed please find an original and two (2) copies of the Petition of Defendant's Counsel to Withdraw Her Appearance and Proposed Order, to be filed of record in the above-referenced matter. Please time-stamp the extra copy provided and return to the undersigned in the self-addressed, pre-stamped envelope. Please contact me if you have any questions regarding the above. Thank you in advance for anticipated cooperation in this matter. ~.o t ~, -_ r -~: Very truly yours, -`" r+; '? ~s n_ ' " i / t ~ f '..-.) r *t r,Cy . z2 r~ n- LY F. R TELHUBER ~ _ ~~m ~ r° LFR/smw n c ~ ~ 'T3 ~.. - .„ Enclosures sv co cc: Richard F. Maffett, Jr., Esquire (via regular mail) ~ Heather McKeithan (via certified mail) TINA V. ROSSON, IN THE COURT OF COMMON PLEAS OF Plaintiff YORK COUNTY, PENNSYLVANIA v. NO. 96-SU-04222-01 HEATHER McKEITHAN, CIVIL ACTION - LAW Defendant ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter our appearance in the above-captioned case for Defendant, Heather McKeithan. MARSHALL, DENNEHEY, WARNER, COLEMAN AND GOGGIN BY: LYND7 E~. REUTELHUBER, ESQUIRE 100 Pine Street, Fourth Floor P.O. Box 803 Harrisburg, PA 17108-0803 ~a _ (717) 232-4641 ~''~ - r• ~ - I.D. No. 66887 ~ ^ ;- C.7 _'_. n ATTORNEYS FOR DEFENDANT '~="; G - ' _:. ~~}} I ^ ~ x~ _ DATE : ~Qli ~/~ ~ ~ ~~ ~{' ~ IUw~ _. cn - ~ ~ ~~ ,.~ CERTIFICATE OF SERVICE I, Susan M. Williams, an employee of Marshall, Dennehey, Warner, Coleman & Coggin, do hereby certify that on this 27th day of December, 1996 served a copy of the foregoing document via First Class United States mail, postage prepaid as follows: Richard F. Maffett, Jr., Esquire 2201 North Second Street Harrisburg, PA 17110 1 ~V~ W l/~V`~ SUSAN M. WILLIAMS I-AW OFFICES MARSHALL, DENNEHEY, WARNER ACCENT°W`,'' PEN1ssYLVA',"A COLEMAN ~ G4~GGIN (bl0) 776.7500 FAX: (610) 776-7994 IX)YLESTOWN, PENNSriVANIA (213) 348.1611 A PROFESSIONAL CORPORATION FAX: (215) 348-5439 LANCASTER, PENNSYLVANIA 100 PINE STAEEF, 4TH FLOOR (717) 399.1845 P.O. BOX 803 FAX: (7l7) 399-1853 HARRISBURG, PENNSYLVANIA 17108A803 (717) 232-1022 MED[A, PENNSYLVANIA CABLE ADDRESS -MARSHALL (610) 892-6700 FAX: (717) 232-1849 ' FAX: (610) 892.8730 NORRISTOWN, PENNSYLVANIA (610) 292-4440 FAX: (610)292-0410 December 27, 1996 PITTSBURGH, PENNSYLVANIA (412) 394-4090 FAX: (412) 2324655 Stacia N. Gates, Prothonotary York County Courthouse 28 E. Market Street York, PA 17401 RE: Rosson v. McKeithan CCP (York County) No. 96-SU-04222-01 Our File No. 20614-00109.307 Dear Ms. Gates: `PHILADELPHIA, PENNSYLVANIA (215) 575-2600 FAX: (215) 575-0856 SCRANTON, PENNSYLVANIA (717) 342-1999 FAX: (717) 342-0999 WEST CHESTER, PENNSYLVANIA (610) 4318100 FAX: (610) 4318522 MARLTON, NEW IERSEY (609) 985-3900 FAX: (609) 985-3934 ROSELAND, NEW JERSEY (201) 9940303 FAX: (201} 994.19fi5 WILLIAMSPORT, PENNSYLVANIA (717) 326-9091 FAX: (717) 326-5507 Direct Dial 232-4641 Enclosed please find an original and one (1) copy of the Entry of Appearance on behalf of Defendant, Heather McKeithan, to be filed of record in the above-referenced matter. Please time-stamp the extra copy provided and return the same to the undersigned in the self-addressed, pre-stamped envelope provided. Tf you ha«e any q~.~estions, please do not hesitate to contact me. Very truly yours, L F. REU ELHUBER ~' ~ 1~ ~: o _. ~ - LFR/smw ~3'j ~ ~.~~~= Enclosures ='"~ ~ ~ s„ cc: Richard F. Maffett, Jr., Esquire (w/enc.) ~ .,, - ~ cn ~ '~' fTl !V ca .u Cli _~ 96 SU 4222-O1 ~~ ~~ Served ~® ~~ Summons- in Civil Action p Heather McKeithan u on .--------•------------------° the within named defendants by handing to and leaving with September 30, 1996 true and attested Copy of the Same at -_?$_E_ -Market St. , York County Courthouse, York, PA at -----4 -50----------- O'clock .--P'-1eL, and informed her Sheriff s Costs $ 25.58 Paid her of the contents therecf. So Answers, Sworn of this -_._llth_---------- day of ---------°----October---------------- 1996----- ----- - -- ----- - - - - Pro onot .. Sheriff of YU_ CflTJIdTY ~ Y: cn -., r; o ~, . ~ ~ c-~ ~- - o ~ -t .~ - ~ - ~~~ A __ C _._ - fir: 7 ' ~ 9~~ J %,~ ~ i~~ if ~=S ~ ~;~~ d . °~ !N THE COUAT~~ COMMON PLEAS OF YOFj,~,,000NTY, PENNSYLVANIA ~d .,.. CIVIL DIVISION Plaintiff(s) & Address(es): TINA V. ROSSON 6 Russian Olive Drive Etters, PA 17319 vs. Defendants} 8 Address(es) HEATHER McKEITHA. 424 East Main Street Dallastown, PA 17373 File No. ~~0 ~1~~ U`1~ ~~~I Civil Action - Law PRAECIPE FOR SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue summons in in the above case. `-~+ cs+ c-. u~ ~ r ,. ~ ~ ~' -_ ~- ~ ~ ~,-y =~;:; - ~C ~! c u; - _ - r ~ •- r; Yx Writ of Summons shall be issued and forwarded to Attomey/ heriff. d,~ Signature of A ey Date: ~~ ~~ ~b Richard F. Maffett, Jr., Esquire or econ ree :iarrisburg, PA 17110 717-233-4160 Name/Address/Telephone Number of Attomey Supreme Court ID Number 3 5 5 3 9 . . SUMMONS IN CIVIL ACTION TO: HEATHER MCKEITHAN YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION ALAI YOU. Date _- r ~ ~ C i 5~~~~, ~ ~~c~,~ Prothonotary/Clerk, Civil Division Deputy a. e - ~ ;" fi, ~ ~a s ~+ ~~ \. ~~ Tf 4:- (~ ~+F6 r CE?FaW f .~-~^.~ =yy^r-Ypyi4i vx&*# f =F?Y~i^ I.~ . ' IN THE COURT OF~OMMON PLEAS OF YORI~'UNTY, PENNSYLVANIA ( ((~' 1 \~ ~~ CN1L DIV1SlON \J` Plaintiff(s) & Address{es): TINA V. ROSSON _ 6 Russian Olive Drive _ - Etters, PA 17319 __ __ alV ~~04~~,2~ .: V 3 File No. vs. C1viI Action - Law Defendant(s) & Address{es) HEATHER McKEITHAN 424 East Main Street Dallastown, PA 17373 ~ o ~ -n c~ n -<c o~ ~ car -_ PRAECIPE FOR SUMMONS ~"` _ TO THE PROTHONOTARY/CLERK OF SAiD COURT: ~ ~ ~ ~'_ ~, =' T ~ U Issue summons in in the above case ~' -' . Yx Writ of Summons shall be issued and forwarded to Attorney/ heriff. ~~ Signature of At orney Richard F. Moffett, Jr., Esquire or econ reet Harrisburg, PA 17110 71'7-233-416 Date: ~~ ~~ ~fb Name/Address/Telephone Number of Attomey Supreme Court ID Number, . . TO: HEATHER McKEITHAN SUMMONS IN CML AC710N YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF{S) HASJHAVE COMMENCED AN ACTION AGAINS- YOU. Date: ~ I I I ~ "` Prothonotary/Clerk, Civil Division by~ l ~ ~ ~~ ~ _~~,~ Deputy f~a:~~~ ~LI~ ~ 4 35539 RICHARD F. MAFFETT, JR. Attorney at Law 2201 North Second Street Harrisburg, Pennsylvania 17110 Telephone (717) 233-4160 September 10, 1996 Office of the Prothonotary York County Court House 28 East Market Street York, PA 17401 RE: Tina V. Rosson v Heather McKeithan Dear Sir or Madam: Fax (717) 233-2342 Enclosed please find the following items in connection with the above-captioned matter: 1. Original and 3 copies of Praecipe for Summons; 2. Check made payable to the Prothonotary in the amount of $55.00 for the filing fee; 3. Check made payable to the Sheriff in the amount of $50.00 for service charges; and 4. a self-addressed, stamped envelope. Please file this Praecipe and return a time-stamped copy and receipt to me in the envelope provided. I would also appreciate it if you would forward the Writ of Summons and check to the Sheriff for service. Thank you for your assistance in this matter. If you have any questions, or require additional information, please contact my office immediately. Wit best regards, ~y V Richard F. Maff tt, Jr. RFM/cs Enclosures .. MAFFETT Er ASSOCIATES By: Richard F. Maffett, Jr., Esquire #ID #35539 2201 North Second Street Harrisburg, PA 1711 O 717-233-4160 Attorneys for Plaintiff TINA V. ROSSON, Plaintiff IN T1iE COIIRT OF CONMON PLBAS CIIMBSRLAND COIINTY, PENNSYLVANIA v HEATH8R fficK82THAN, Defendant NO. 01-4821 CIVIL ACTION - LAtfP PRAECIPE TO THE PROTHONOTARY OF SAID COURT: Please mark the above-captioned matter settled and discontinued with prejudice. Dated: September 20, 2001 Richard F. Maffet r. Esq. c= c ~:,, a___ vG m - ;- ; ~ ; _o can ~ -c ~ ~` ~ - C J !7 - ,~ -x ; ~~ I _. -.~R~ ,~erv~>~p~ s. .~v~ t ..~~tm~m~vxama.