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Home My WebLink About99-00128 ~ .11) 0> .C Jj . .., 7 L. 'd -;r.. : / , .I I . / / ~ '- . ~! J ()O nS - I 0- \ ) i ! , , i ,~ " ~ '" . , JOHN A. HAIR and DEBRA HAIR, his wife, Plaintiffs # 5 OLER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ANDREA L: SINGISER, Defendant No. 99-0128 CIVIL TERM IN RE: PRETRIAL CONFERENCE A pretrial conference was held in the chambers of Judge Oler in the above-captioned case on Wednesday, April 10, 2002. Present on behalf of the Plaintiffs was Jason Imler, Esquire, standing in for Matthew S. Crosby, Esquire, who will be trying the case. Present on behalf of Defendant was Donald R. Dorer, Esquire. This is a negligence action for personal injuries to Plaintiff John A. .Hair arising out of a two-car accident on January 28, 1997, in Mechanicsburg, Cumberland County, Pennsylvania, which occurred when Defendant failed to stop at a red light and her vehicle and Plaintiff's vehicle collided. Plaintiff Debra Hair sues for loss of consortium. Defendant admits liability for causing the accident, leaving factual issues to be resolved by the jury of causation and damages. This will be a jury trial in which each side will have four peremptory challenges, for a total of eight. The estimated duration of trial is two and a half days. .-. o No unusual issues are expected to arise during trial. To the extent that deposition testimony is to be shown or read to the jury and contains objections which require rulings by the trial judge, counsel are directed to furnish to the Court a copy of the affected transcript(s) at least three days prior to commencement of the trial term at which this case is tried, with the areas of objection being pursued highlighted and with brief memoranda in support of counsels' respective positions on the objections. Pursuant to an agreement of counsel reached at the pretrial conference, Plaintiffs' pretrial memorandum is deemed to be amended by the inclusion of an additional exhibit, which is an economic loss chart prepared by Plaintiffs' vocational expert. With respect to settlement negotiations, Plaintiffs have demanded $200,000.00, and Defendant has responded with an offer of $15,000.00. It is noted that counsel are participating, on April 11, 2002, in a mediation conference with a view toward possibly resolving the case. By the Court, Jason Imler, Esquire Michael S. Crosby, Esquire For the Plaintiffs w Wesley -- (J: -.... t::; i..U_"_ '.~~ (~l ~:~~ '-:'t":' ~;~~ j.:'-: 1\_ o . ~ tV:' ~;. >- '7 :5< ')-.,. b~ C)~ ~-~~ i_LitiJ ~c.. => U -- c:: t>:: 0,_ ""'" '" o -, -, DI '" ... 1.01>> '( ~-oo ~.A ~ u 8;:: u-N '- u:o.::::r--...o _ ~O ~ cC o c_o tt~~8 ... '( 1>>-- 01 ~ 0 Ov:l-o '" ~2.~C';l m "" _C ... )... ~ ~ '" ~ -~~.....:. 'VCOlU ::) ~ ~("") >-'" ~ cO 0> tJ)N V) LU ID~ ""f ~~ V) .S :; r-.:. <(...:t:-:;;"'- I:J -0 C2-"--R- uoo- ~ g OEt'-- Z-..;f~'" '- :5-..9 '- I"'O '( _I , , . ! ') J-IPR 0 2 2002 "\) ~ . JOHN A. HAIR and, DEBRA HAIR, his wife Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No, 99-00128 ANDREA L. SINGISER, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED PLAINTIFFS' PRE-TRIAL MEMORANDUM I. STATEMENT OF FACTS: This case arises out of a motor vehicle collision that occurred on January 28, 1997, at approximately 12:50 p.m. Plaintiff, John Hair, was traveling northbound on South Market St. in Mechanicsburg, Cumberland County. At approximately that same time, the Defendant, Andrea L. Singiser, was traveling eastbound on Simpson St., approaching the intersection of Simpson and South Market Streets. The Defendant failed to stop tor a steady red traffic signal at that intesecion, tailing to yield the legal right-ot-way to Mr. Hair's vehicle, and causing the ensuing collision. As a result of the collision, Mr. Hair has sustained severe, permanent, and disabling injuries to his neck and head. -1- , II, STATEMENT OF ISSUES 1. It is anticipated that the Defendant will admit liability. 2. Damages are at issue. III. SPECIAL EVIDENTIARY ISSUES AND ADMISSIONS 1. Department of Public Welfare lien. 2. Medicare lien. IV. ESTIMATED LENGTH OF TRIAL: 2 - 3 days. V. WITNESSES: 1. John Hair. 2. Debra Hair. 3. Defendant, Andrea Singiser. 4. Dr. Vitaly Gordon, by way of videotape. 5. Dr. Claire Flaherty-Craig, by way of videotape. 6. Dr. Todd Samuels, by way of videotape. 7. Dr. A. Craig Houston, economist. 8. Patrolman Timothy E. Dyer. 9. Shannon Hair, Plaintiff's daughter. 10. John Lauser, Plaintiff's friend. 11. Judith Rathfon, Plaintiff's mother. -2- J 12. Eric Givler, Plaintiffs brother-in-law. 13. Rich Steele, Plaintiffs former employer. 14. Scott Gramm, eyewitness. 15. Buck Beaver, eyewitness. 16. Claudia Luci, eyewitness. Plaintiffs also reserve the right to call any of the witnesses listed by the Defendant. Plaintiffs further reserve the right to seasonably supplement their witness list in a manner consistent with the Pennsylvania Rules of Civil Procedure. V. EXHIBITS: 1. Vehicle photographs. 2. Medical treatment calendars. 3. Deposition transcripts. 4. Anatomical diagrams. 5. Transcribed recorded statements. 6. Police Accident report. 7. Videotapes and transcripts of expert medical testimony. 8. Medical records. 9. Defense medical examination report. 10. Vocational expert report and attached Exhibits. -3- ) Plaintiffs reserves the right to use any exhibits identified by the Defendant. Plaintiffs also reserve the right to seasonably supplement their Exhibit list in a manner consistent with the Pennsylvania Rules of Civil Procedure. VI. SPECIAL DAMAGES: 1. Net vocational loss of $732,803 to $1,066,984.00, per Dr. Houston's vocational report and anticipated testimony. 2. Department of Public Welfare lien, in the amount of $1,420.94. 3. Medicare lien. Plaintiffs' counsel has repeatedly attempted to contact Medicare to obtain a current lien number, but without success. Plaintiffs' counsel will continue to attempt to contact Medicare to finalize the lien figure. 4. Out-of-pocket medical bills. This total will be provided to opposing counsel and the Court very shortly. VII. CURRENT STATUS OF SETTLEMENT NEGOTIATIONS: Defendant has made a settlement offer of $15,000. Plaintiffs' current demand is $200,000.00. Respectfully submitted, HANDLER HE NING & ROSEN G,LLP BY: atthew S. Crosby, Esq. Supreme Court 10 No. 69367 1300 Linglestown Rd. P.O. Box 60337 Harrisburg, PA 17108 Tel. No.: 717-238-2000 Attorneys for Plaintiffs Date: -4- CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served on the Defendant by sending a copy of the same to her counsel of record, as follows, by first- class United States Mail, in Harrisburg, Pennsylvania, on April 1, 2002: Donald R. Dorer, Esq. 214 Senate Avenue Ste 503 Camp Hill, PA 17011 p DATE: 4 }//6'"L B Matthew S. Crosby, Esq. Attorney I.D. #69367 P.O. Box 60337 Harrisburg, PA 17106 (717) 238-2000 Attorneys for Plaintiffs ATTORNEY LAW Of'BeES JACOllS & SABA 214 S~;N.'\TE An:Nl'l': StllTE 503 CAMP HILL. PA 17011 (717) 731,09l1l1 E\x, (717) 731-0987 €~) " TO YOU ARE HEREBY NOTIFIEO TO FILE A WRITTEN RESPONSE TO THE ENCLOSED WITHIN TWENTY (201 DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU BY WE DO HEREBY CERTIFY THAT THE WITHIN IS A TRUE AND COR- RECT COPY OF THE ORIGINAL FILED IN THISA. CTlON ;~ BY I'-\PRA~~N~[1,: / LA WU.1<.1<lC.t;SUJ!' JACOBS-&-SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendant, Andrea L. Sin JOHN A. HAIR AND DEBRA HAIR, HIS \VIFE, PLAINTIFFS IN 1HE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA iser VS. No. 99-128 CIVIL TERM ANDREA L. SINGISER, DEFENDANT CIVILAcrION-LAW JURY TRIAL DEMANDED PRE-TRIAL CONFERENCE MEMORANDUM OF DEFENDANT, ANDREA L. SINGISER I. STATEMENT OF FACTS: = Please see Plaintiffs' Pre-Trial Memorandum. The Defendant, Andrea L. Singiser stipulates as to her sole negligence for the occurrence of the motor vehicle accident of January 8, 1997. The police accident investigation report is attached hereto as Exhibit "N' for the reference purposes of the Court. The Defendants position as to the damages claimed by Plaintiff, John A. Hair is as set forth in an independent medical examination report of David Buchholz, M.D., a neurologist practicing in LutherviIle, Maryland dated July 31, 2000, attached hereto as Exhibit "B" for the reference purposes of the Court. II. STATEMENT OF ISSUES: = Please see Plaintiffs' Pre-Trial Memorandum. ., ID. PRE-TRIAL LEGALIEVIDENTIARY ISSUES: Please see Plaintiffs' Pre-Trial Memorandum. IV. ESTIMATED TRIAL LENGTH: Two (2) to three (3) days. v. WITNESSES: 1. Plaintiff, John A. Hair (as on cross-examination) 2. Plaintiff, Debra Hair (as on cross-examination) 3. Defendant, Andrea Singiser 4. David Buchholz, M.D. The Defendant reserves the right to list and/or call such other and further witnesses as may be listed by Plaintiffs, as well as any treating healthcare providers, upon notice to Plaintiffs. VI. EXHffiITS: 1. Photographs depicting damage to 1993 Ford Taurus operated by Defendant, Andrea L. Singiser. 2. Photographs depicting damage to 1994 Subaru Justy operated by Plaintiff, John A. Hair. 3. Records of Neurology Center, P.C. 4. Records of Holy Spirit Hospital 5. Records of Bruce Goodman, M.D. 6. Records of Health south Rehab ofMechanicsburg 7. Records of Keystone Spine Center, Inc. -, 8. Records of Orthopaedic Institute of Pennsylvania 9. Records of Pinnacle Health HospitallPhysical Therapy 10. Records of First Place Healthcare 11. Records ofthe Family Medicine Center of Southpointe 12. Records of the Milton S. Hershey Medical Center 13. Records of Community Family Medicine The Defendant reserves the right to list and/or present such other and further exhibits as may be listed by Plaintiffs, as well as any other medical records exchanged between counsel during the course of discovery. VII. SPECIAL DAMAGES: Please see Plaintiffs' Pre-Trial Conference Memorandum. VII. SETILEMENT NEGOTIATION STATUS: = The current status of settlement negotiations is accurately set forth in Plaintiffs' Pre-Trial Conference Memorandum. By way of further statement, the parties are participating in a non- binding mediation proceeding on April 11, 2002 by mutual consent and agreement. LA By: Do aid R. Dorer, Esquire Attorney for Defendant Identification No. 39126 Date: April 4. 2002 EXHIBIT .A 1_ __ m .' 'xx~ REFER TO OVERLAY SHEETS i @! COMMONWEAL TH OF PENNSYLV".~:A POLICE ACCIDENT REPORT REPORTABLE KXl tJON - REPORTABlED ~@IP:W 7. ~~T~STIGATjQ~il_28_97- 8. ~1~~iVAl ACCIDENT INFORMATION 9. ACCIDENT 1 28 97 10. DAY OF WEEK Tu d DATE - - es ay i i:~~~EOF-i25o --.>;---- -. -. fi:~~~~~~~._- 2 "lJ".'iH<iLIEO-O- 4~aiNjUREti. 0-- i5:~~~~~~P. Y r-J N ~ 10. DID VEHICLE HAVE TO DE 17. VEHICLE DAMAGE REMOVED FROM TtiE SCENE? 0 - NONE UNIT 1 UNIT 1 UNIT 2 1 . LIGHT 2. MODERATE 3 - SEveRE POLICE INFORMATION 0382-97-019 1. INCIDENT NUMBER '2.AGEi-,CY . -..---- NAME Mechanlcsburg Police 3. STATIONi N/A PRECINCT ' -5:"iNVESTIGA TOR Ptl~ Timot~ E. Ilyer 6. APPROVED BY Department ~TROL ZONE BADGE NUMBER BADO'E NUMBER 1256 yUN~~ yI<!SN[] yO N [:]- 19. PHINDDT PROPERTY UNIT # 1 yO UNIT2 18. HAZARDOUS MATERIALS t~ 37. REG. PLATE JJB808 46483492602 36. LEGALLY Y PARKED 7 0 - j9.-PA'1'ifIE-OR-' ,.- our-oF-STATE VIN 40. ownER N/A 12 [iJ [~J NO 38. STATE 1'.'" PENNOOT USE ONlY ACCIDENT LOCATION"<;i;';'~': 20. COUNTY CUIrberland 21:~ruNTciPA[ffYM~~-h~k~bucg 22. ROUTE NO, OR STREET NAME S.R. 2014/Simpson Street 23. S'PEEO --124jfYPE 125JACCESS LIMIT 25 J~HIGHWAY 0 I'-'CONTROl 1 INTERSECTING ROAD: 26'~~~~:~~:-~R: 0114/South ~~rket Street 2....sPEE5--.25-r2.~TYPE 0 I~ACCESS 1- _ LIMIT _.T.-.!:!IGHW~_ ,CONTROL IF NOT A T INTERSECTION: 3b~-CRbsssmEETOR'. SEGMEtH MARKER 31:blRECTION FROM SITE N 5 3i~Disf^NCE- WAS ~ 32. DISTANCE E ~_J FROM SITE o ESTIMATED FT. MI. D ~)CO"STRUCTID" ZONE ' MEASURED @TRAFFIC CONTROL DEVICE INTERSECTING [?J PRINCIPAL ID o UNIT # 2 36.LEGAllY Y NI37.REG. _ .PAnKE[)?_l;:HQ\_~0TE~~.?JI~_2u ;~:~~~1~'i..~:V", JFlKA7229RB701009 '46:oWHE'R . John A. & Debra Halr 38. STATE _,_RB-. R.L. & Andrea__[.:__~ingiser 41. OWNER ADDRESS 200 S. York St. 42:: CITY,STATE ----- &ZIPCODE Hechanicsburg PA 17055 ~=:~~~~:3_]~""MAKE FO~~ __. 4s'ri6g~~g~~T Taur:-us ~46.lr~':rn uD uNKD ,~. :~f,{l ";~~f --1 ~:~y~tir--'oo~~=---= ;2;O.:~~:~IP =919 . -'POINT '-'STATUS. .- SPEED ,'3:)VEHicLE --1- 5-I.)DRIYER .- 1 ' '55) DRIVER 1 . - GRADIENT -- PRESEUCE - cmmmON 56. ~~::;'~~R 11432511 1ST. STATE PA S8~ DRIVER NAME Andrea L. Singiser 59:-BRIVER-- ADDRESS 200 S. York St. 60. ciTY, STATE , & ZIPCODE Hechanlcsburg PA 61.-58< 62. DATE OF F BIRTH G.t. CO MM. Vel t. 65. DRIVER Y '-, II XX CLASS 61.CARRIER-- 17055 6t7~o/j766-5076 41. OWNER-- ADDRESS 304 Wall St. 42. CITY,STATE & ZIPCODE Hurm:elstown PA 17036 -4=~Y~~~ ~994 r:;"AKE Suburu 45. MODEL - (NOT BODYTYPEI Just 41)BODY 02 4S-)'iPECIAL . -' TYPE - USAGE :5OJiiilTTACTMPACT 12' Sl~VEHICLE ~-- POINT -'STATUS !s3.jvEHICLE 1 5-IJDRIVER '-'GRADIENT -' PRESENCE 56. DRIVER NONE NUMBER 58.~~~~~R John A. Hair 59. DRIVER ADDRESS 60. ~'~~.;'~~~E Hurrrnelstown PA 17036 61.SEX-M 62. DATE OF 8lRTH 64. CO MM. VEH'j65. DRIVER YOl/1()( CLASS 67. CARRIER 1. 99 1 o I'S.INyS.= NO 0 -L AD. UtlK 49)VEHICLE - OWNERSHIP 5l TRAVEL SPEED SS DRIVER CONDrrIO~1 57_STATE o 304 Wall St. 68~CARRIEft--' ADDRE~iS 59.CITY,SrATE & ZIPC:lDE 70. usooi""" =:~E~_ 13,CARGO '1l9DYTYPE l16)HAZ AROOUS - MATERIALS PUC# ~". CONF IG. 7S. NO. OF AXLES M.45 (11195) 1'. GVWR 68. CARRIER ADDRESS 69. CITY. STATE & ZIPCODE 10. USDOT #. ~~:::SE OF ~~:J~-II YON 0 UN<ill ~ennOOT _ BtiSTE ICC "# 77. RELEASE OF HAZMAT YDNDUNKD \S EH. CONFIG. 75. NO. OF , AXLES 2308706 ~i8,:-RESt!ONqING EMS AGENCY N/A 79. MEDICAL FACILITY N/A , 80,reOPLE INFORMATION G NAME ...ABCOEF 1 1 F 56 3 1 9 DRIVER, UNIT 2 1 M 32 3 1 9 DRIVER, UNIT 2 3 ~l 23 3 1 9 Scott Gearrm, (if!~ ILLUMINATION ~ @.l WEATHER ~ r:~/ ROAD SURFACE [!J 84. PENNSYLVANIA SCHOOL DISTRICT (IF APPLICABLE) N/A 65. DESCRIPTION OF DAMAGED PROPERTY OWNER N/A ADDRESS PHONE (i..::',DENT #: 0382-97-019 IACCIOENT DATE: 1 28-97= 'ADDRESS H I J K L 1 0 0 0 B 0 2 . 0 0 0 B 0 6315 Beandy Ln., Mechanicsbueg PA 0 0 0 B 0 .. o o o 86, DIAGRAM ~":"' I~ 1I1~' ~..:;.. LJ I I 3*** I I ,,,,,..,...,, ",. ....., "....\.....-. .. .......... ".....~..-,-,...-......, ,.,1..---..-. .... I I ' i. ! I ! i I """"1""""'."'" ..".. , ,..""!,,.... "".,........,..'" .....-l,....-...-.-...... ,.. , I I r ) : i ..: ..., ....... .--....-. .....1..._..,___.._...._,.._.1..._.........,.._.....,..._ --,-----. ..'. ..'.. :, 1 ' . I I ! ! i "7 o N/A ***SEE DIAGRA}l PAGE ......,....._'" ..,.,..1 i , I , ! '.....'....'.'....'......1...-.....'...-'.. ! , , ! ..__.M........ ...M__.........:...- i --.,--: i- , 81. NARRATIVE a IDENTIFY PRECIPITATING EVENTS. CAUSATION FACTORS, SEQUENCE OF EVENTS. WITNESS STATEMENTS, AND PROVIDE ADDITIONAL DETAllS,lIKE INSURANCE INFORMATION AND lOCATION OF TOWED VEHICLES. IF KNOWN. Unit 1 was eastbound on W. Simpson St. appeoaching S. Maeket St.& had a red traffic signal. Unit 2 was northbound on S. Maeket St: approaching Simpson St. & had a green traffic signal. The deivee of Unit 1 advised that she saw that the teaffic signal was red. She said she sa" the cae in feont of hee tuen right & then she peoceeded into the intersection to continue east on Simpson St. The deiver of Unit 2 stated that he saw Unit 1 enter the intersection but was unable to avoid a collision. Witnesses Buck Beaver & Claudia Luci peovided accounts similar to those of the drivees of Units 1 & 2. Unit 2 was towed bV Towing to their garage at 145 Gettysburg pike, Mechanicsbucg PA 17055. INSURANCE . I COMPANY INFORMATION 'INati,Q!t~de ~lut.lJ.<!;L Insueance CO. UNIT POLICY __ _ . .., , NO 58 31 A911'" Tl NAME ADDRESS ee. Buck Beaver 599 Lewisberrv Rd...! New CUmbedand PA l}070 WITNESSES NAME ADDRESS Claudia Luci 35 W. Coover St., Mechanicsbura PA 17055 __ eg...VIOLATIONS IUD_ICATE_D______,.__... 190. SE.CTlON NUMBERS (ONLY IF CHARGED) Utlli', Traffic-control signals 1I"UT2 Drivers required to be licensed ~91,)f'ROBABLE ,92.HYPE 93)RESULTS lXXNOTEST.91.)PROBABlE - USE -' TEST _4 D REFUSE -- USE UNITt . 0 0 0'_-%0 UNK UNIT2 0 M-45 (11/95) 2308706 , I I ! ..., Hess I I ., l I i INSURANCE INFORMATION UNIT 2 COMPANY Allstate Insurance PO~'gY F.. ? A Co.. PHONE (7ULZ:M.=3758 __ PHONE (71'ii"69l 1339 TG tH~ ~TYPE TEST o (' ,.. j . ~ I :VRESULTS XXJNO TEST 94.1NVESTlGATlor; o REFUSE COMPLE 1 E ? 0'_-%0 UNK YES ~ N~_~J. :. . ' PennOOT a UH,:)Tc PAGE: -2- ~ ~. .~i-~i;~>k'7;.' li!. .... ~...i ::2..:;':;,\~"'~::I':'" ,..,~ ~ -. ~. "'I6'"",.,...h" ... ' u ~., ~ /:t Vi~,:~.i.~""J(;~i.'.~, ,.:.. I": ~ ~. ~~.~;:';'g~~.{~-'~ ::;~;t '. ~ 11: '"::p ,;)CIl~~C :~f~ ;.. . 'r ;; So:.: r~. :J.*l" .~1~;; _,' N ~':;~W~ '~'A.I~~:'~'" ~ ~ . ~ .:-:: ;:j:~~.- . ~~~":,:. '. ...:I ~. ... , '" ll.,."..,...CJ ".:.c..''''\'' ,-i. < ~. .. .' "" ,,'."" ". .. 'N Q.i ~:..,>;;}.\t ~":fli'~ ~.. "'H: \l. : \- .,.~..",- .:M'-1: It t) 't ~ ~:i:1:;:~;~f~: M;~. ~ !2! ~ 0 "". \:.. -~J.....;'lt~;t;~n-. ........~' tj i tj ~ r;-~. ~:r~;.~;{~~~~~~.~~ 4- Z . ". ...-:::~.~ ~:~ . eo ~'/oi.,.....,... ,~ '....~I/;. ..:-. ',1. '.~ '-~:,;'g~'ii~2~~ii~~~~~.;~;:~~:~~~;: :- , "." ~""".' . gj . 'il"1' ',7-,' ",".'. " .0- . ~,.', ..,'. . "In '>,.,.,.! . .sCJ'-;;;..s)(:,'.< . ....c: : d$,... ::....:... ~ ro -" -. +, '" ' '!i p '!i'~'.:i":-: '. (d ':.,' It 1"""'1 U '. ~ u !i!..: , " . : :'ri~t~i,:1~,:;:'" ..... '":7'3'L:~'PM . . . :.' : :,~:-:.! '!-1,.~, ." .. . ..;:.~~rY:.::""" :i1~1~}~:, . - ., , ,;ih,':~' .,;~,~<~,.:.:. "'5~i" .. - ",' . . ::::O'\~tl'::. -, :.~':;i~ktf;'; i:' ',."~:~::~'~;;~;~ ~ - ."' " . , ~':D-r:~~:-'" " ."' , ...;_", " M.' ~ ' " ':",';,::;':":. '~ '..M]."' lA~~@ .;;~0r~~~r:- . ' " 1 : ". ~ l' ~ ::t oQ ~~ Vht ~~ ffi -:j ~ ~ 811 . I.' < N (< N ,:..\~ ^ ,-i - :::: "'/ \' :j;\-~ .,!i~ ,.. ----- it ~ ~ Vi~ ~t1 a ~ ~ ~ .. ..' I Ii ,I .-. , Telephone (410) 583-2830 DAVID BUCHHOLZ, M.D. Neurology Johns Hopkins at Green Spring Station 10753 Falls Road, Suite 315 LuthervilIe, MD 21093 Telecopier (410) 583-2835 July 31, 2000 Mr. Donaid R. Dorer Suite 503 214 Senate Avenue Camp Hill, PA 17011 Re: John A. Hair Dear Mr. Dorer: This report documents my comprehensive neurological examination of Mr. Hair on 7/6/00 and summarizes my opinions regarding a motor vehicle accident in which he was involved on 1/28/97. I explained to Mr. Hair that I was evaluating him but would not be involved in his care as a treating physician, and he acknowledged .his understanding of this arrangement. The historical information detailed below is solely that provided to me by Mr, Hair on 7/6/00 and does not additionally represent the contents of his records. HISTORY ACCORDING TO MR. HAIR Mr. Hair is 36 years old and right-handed. He has been out of work since 1/28/97. He completed ninth grade and has not obtained a GED. Since leaving school he has done warehouse and dock work, cooking, roofing, and "jockeying trailers." . . At the time of the accident of 1/28/97 Mr. Hair had worked for Red Neck Trailer Supplies for 45 days. His duties included driving a forklift, loading freight, constructing trailers, and working in a warehouse. He hasn't worked at all since the accident of 1/28/97. He is married and lives with his wife and two daughters, aged 12 and 17 years. Mr. Hair has not served in the military , Regarding his health prior to 1/28/97, Mr. Hair reported fracturing his right foot at approximately age 10 and his right collarbone at approximately age 12-13. He did not require surgery for either fracture, and he has had no residual problem from either, He fractured his right hand in a motorcycle accident at approximately age 19-20, and neither required surgery nor has had residual problem. ..,.' ., .;.)t. ,--. <: .::- Mr. Donald R. Dorer July 31, 2000 Page Two Re: John A. Hair Mr. Hair denied any other fracture prior to 1/28/97. He reported "scars" on both knees and elbows as a result of injuries. He also reported having received stitches, but he was unable to provide .the details. He denied any other injury for which he received medical attention prior to the accident of 1/28/97, including injury as a result of any motor vehicle accident. work, sports, slip/fall, or beating. As a child he wore a full length left leg cast for three months for "Osgood-Schlatter," involving his left knee, and he had no residual problem. He denied surgery or overnight hospitalization prior to 1/28/97. Mr. Hair developed asthma at around age 23-24. It is an ongoing problem treated with an albuterol nebulizer, an albuterol inhaler, and a Pulmocort inhaler, all of which he uses daily. He was treated by Dr. Birch on Route 1 in Rehoboth Beach, DE, prior to coming under the care of Dr. Burkholder in Hummelstown (and in the process ofrelocating to Middletown). Mr. Hair denied any emotional, mental health, psychological, or psychiatric problem, or treatment for any such problem (such as counseling or medication) prior to 1/28/97. He denied ever having a drug or alcohol abuse problem - or treatment for any such problem - prior to 1/28/97. He has no known medication allergy. Mr. Hair's family history is positive for a stroke in his maternal grandmother approximately ten years ago, diabetes in his maternal grandfather, and possibly diabetes in his paternal grandmother, There reportedly is no family history of headaches. He denied family history of any emotional, mental health, psychological. or psychiatric problem, including depression, suicide. and drug or alcohol abuse. He then added, "I think my father might drink too much - just on the weekends." He later recalled that his brother was in rehabilitation approximately four years ago for heroin addiction but has overcome the problem. On 1/28/97 Mr. Hair was the belted driver of a 1994 Subaru. He and a coworker (the front seat passenger) were on lunch break. Mr. Hair's vehicle was moving through a green- lighted intersection, and his buddy said, "Look out." (Mr. Hair is uncertain if the passenger was injured long-term. The passenger reportedly was out of work for one week and may have had subsequent low back complaints, which may have resulted in him being fired.) Mr. Hair remembers seeing a glimpse of a car coming from the left at the last second before the accident. The left front of his car collided with the right front of the other car. driven by a woman. He remembers hearing a "sound - very loud" from the impact. His knees both hit under the dashboard, and he experienced pain in, but not bruising of, his knees. ~ (,. . ......... I~ ( . Mr. Donald R. Dorer July 31, 2000 Page Three Re: . John A. Hair Mr. Hair did not strike his head, and he had no subsequent lump, cut, or bruise on his head, including the right occipital region. Asked if he lost consciousness, Mr. Hair replied, "r believe," and added, "More like reality, r !!uess." His first recollection following the accident is a witness offering his card to Mr. Hair. Mr. Hair was standing outside his vehicle at this time. Police came to the scene of the accident and asked Mr. Hair if he was okay. He responded, "r think so." He was asked if he wanted to go to the hospital because of his complaints of knee pain, and he said, "No, I think I'll be fine." He had no symptom other than knee pain at the scene of the accident. His vehicle was towed from the scene and was repaired for approximately $3,000, Mr. Hair's knees healed, but he reported woke up the night of the accident with headaches. His problems since then have been his "neck and head." He denied any neck or head pain or headaches prior to the accident of 1/28/97. Asked if he had ever had a headache prior to 1/28/97, he admitted that he had, but he denied having had a headache "problem." He reported not having received medical attention for headaches prior. to 1/28/97. When pre-accident headaches occurred, infrequently he would take aspirin. He denied any pre-accident "migraine" or "sinus, stress, or tension" headaches. Mr. Hair indicated that headaches have worsened since their onset following the accident of 1/28/97, Headaches reportedly are "pretty much so" constant. Pain is on the right; previously it had been on the left to a lesser degree, but left head pain has resolved. Pain begins posteriorly and spreads to his right temple and behind his right eye. Pain is "very throbbing" and accompanied by "tenderness." He has "tenderness" and "soreness" also involving his right more so than left trapezius muscle region and posterior neck. He attributes this to "protecting his head" in response to headache pain. Headaches are accompanied by nausea, photophobia, and phonophobia but not visual disturbance. He has dizziness with headaches, which he suspects may be secondary to medications. Headaches are exacerbated by movement of any type and by activity in general. They are also worsened by hearing train noise (near his home). He has had headaches triggered by drinking beer and in cold weather. c .. Mr. Donald R. Dorer July 31, 2000 Page Four Re:. John A. Hair Currently Mr. Hair takes methadone 10 mg four times daily. Asked if this helps his headaches, he replied, "Oh, yes." Methadone helps more than Vicodin did, and it helps him to sleep. He:also takes Motrin 600 mg four times daily and Neurontin 300 mg twice daily, which is being tapered and eliminated because of its cost. Mr. Hair also takes tetracycline 250 mg daily for bleeding from his "bellybutton," which he indicated has been attributed to Motrin. He has had this problem for six to nine to twelve months, and he underwent surgery for this approximately four to five months ago. Mr. Hair was unable to provide details of the surgery. He did not have an umbilical hernia, to his knowledge. He was referred by Dr. Burkholder to Dr. Harris, and he underwent surgery at Osteopathic Hospital in Harrisburg. Mr. Hair also takes asthma medications as noted previously. He smokes one pack or more of cigarettes daily. He drinks alcohol up to once per week. He initially indicated that he drinks beer but then noted that it triggers headaches, and he reported having switched to Windsor and Coke. He doesn't drink regular coffee, tea or cola daily, because he avoids caffeine. He has not been on a headache-preventive diet. Mr. Hair pointed out that he had gained weight - from 210-215 pounds at the time of the accident to 330 pounds over the first year following the accident - but has lost weight and now weighs 184 pounds. He was not trying to lose weight, but methadone has suppressed his appetite. Vicodin had had the opposite effect (it stimulated his appetite). Mr. Hair is seen at Hershey Medical Center every six months. Asked what treatment he previously received for post-accident headaches, he reported multiple right occipital injections once or twice monthly. These proceeded to become "shot gun injections." He then underwent other procedures including right occipital nerve stimulation followed by cryosurgery. He stated, "That [cryosurgery] is what seemed to really mess it up." Prior to cryosurgery headaches were only activity-related (but subsequently became constant). Mr. Hair told me that overall his condition worsened under the care of the physicians at Hershey Medical Center. No further treatment (other than his current treatment) is planned, although laser therapy was mentioned. He remains under the care of both Dr. Burkholder and the physicians at Hershey Medical Center. ."-'. i. = Mr. Donald R. Dorer July 31, 2000 Page Five Re: John A. Hair Mr. Hair has not been reinjured since the accident of 1/28/97. He denied any new medical problem, unrelated to the accident of 1/28/97, since the accident, other than bleeding from his bellybutto~ as noted above. Asked if he has had any emotional problems since the accident, he replied, "You do have emotions." He has not been treated for any emotional problems since the accident of 1/28/97. Mr. Hair has no plan to return to work. He has not received vocational rehabilitation. He is receiving Social Security disability payments. He said that he can't work because he experiences headaches with activity, lifting, exposure to light, and traffic. He does best with sleep and being in the dark. His activities include walking, driving "very rarely" (to pick up medications or cigarettes), watching television, and reading. He doesn't work around the house, shop, or cook. His wife works. Mr. Hair "hardly - ever at all - very rarely" goes out of the house or visits friends. EXAMINATION OF MR. HAIR Mr. Hair appeared healthy and generally comfortable except that he held his head somewhat stiffly. He otherwise had normal posture and movements. He exhibited normal cognition and neutral affect. Mr. Hair complained of diffuse tenderness in his right posterolateral neck and occipital region. There was no specific pain related to palpation of the right occipital groove, and no Tinel's sign over the right occipital groove. Pinprick sensation was normal in the occipital nerve distributions bilaterally. Cervical spine passive range of motion was full and painless. There was no spasm of paracervical or trapezius muscles. Mr. Hair had normal pupils, optic discs, visual fields, eye movements, facial pinprick sensation, facial strength, hearing, speech, palatal rise, shoulder shrug, tongue movements, limb strength, fmger-to-nose testing, rapid alternating movements of the hands, deep tendon reflexes, plantar responses, distal upper and lower extremity pinprick sensation, distal lower extremity vibratory sensation, gait, tandem walking, and ability to hop on each foot alone. r" , , . Mr. Donald R. Dorer July 31, 2000 Page Six Re: . John A. Hair OPINIONS The following opinions are held by me within reasonable medical probability and are based upon the findings of my comprehensive neurological examination of Mr. Hair on 7/6/00 and my review of the following medical records and other documents: 1. Neurology Center, P.C. 2. Holy Spirit Hospital 3. Bruce Goodman, M.D. 4. HealthSouth Rehab of Mechanicsburg 5. Keystone Spine Center, Inc. 6, Orthopedic Institute of Pennsylvania 7. Pinnacle Health Hospital/Physical Therapy 8. First Place Health Care 9. Family Medicine Center of Southpoint 10. The Milton S. Hershey Medical Center 11. Police accident report 12. Vehicle damage photographs 13. Deposition transcript of John A. Hair 14. Todd Samuels, M.D. ,r-, ( , -=- Mr. Donald R. Dorer July 31, 2000 Page Seven Re: John A. Hair 15. Community Family Medicine 16.. Red Neck Trailer Supplies 17. Vilaly Gordin, M,D., 6/28/00 My opinions are subject to modification pending additional pertinent information. As a result of the motor vehicle accident of 1/28/97 Mr. Hair at most sustained cervical musculoligamenlous strain (temporary soft tissue injury) and transient post-traumatic migraine. He did not suffer occipital nerve injury (or otherwise acquire occipital neuralgia) or injury to his cervical spine as a result of this accident. He incurred no other neurological problem from this accident. Soft tissue injury by nature resolves spontaneously within no more than a few weeks to months of onset. Whatever soft tissue injury Mr. Hair sustained in the accident of 1/28/97 resolved within that time frame, and subsequently he has had no symptom, disability, or need for evaluation or treatment related to whatever temporary soft tissue injury he may have experienced. Similarly, post-traumatic migraine - which can generate not only headaches but also neck pain and other symptoms - is a transient phenomenon that subsides within weeks to months. Persistence of head and neck pain complaints beyond that interval implies that one or more other driving forces - such as analgesic rebound, or psychological and emotional factors - have taken over subsequent to waning of the post-traumatic effect. In Mr. Hair's case, both such driving forces apply; his headache complaints have been promoted by not only the rebound effect of chronic narcotics but also psychological and emotional factors such as influences of disability status and this litigation. The latter influences have led to embellishment ofMr. Hair's complaints of whatever headaches he may actually continue to experience as a result of rebound. Subsequent a matter of months following the accident of 1/28/97 - by which time whatever transient post-traumatic migraine Mr, Hair experienced would have subsided - he has no symptom, disability, or need for evaluation or treatment attributable to the accident of 1/28/97. r" (, . Mr. Donald R. Dorer July 31, 2000 Page Eight Re: John A. Hair None of the treatment directed at the diagnosis of occipital neuralgia - including the injections and cryosurgery at Hershey - was necessitated by this accident, since Mr, Hair never had occipital neuralgia, .related to this accident or otherwise. Resolution of Mr. Hair's headache complaints could best'be advanced by elimination of the factors that are currently promoting these complaints, including narcotics, disability status, and this litigation. Yours sincerely, ~~ David Buchholz, M.D. DB:CM 99HB-00136 . LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendant, Andrea L. Sin iser JOHN A. HAIR AND DEBRA HAIR, HIS WIFE, PLAINTIFFS IN DIE COURT OF COl\Il\ION PLEAS ~1BERLANDCOUNTY,PENNSYLVAN1A VS. No. 99-128 ClVlL TERM ANDREA L. SINGISER, DEFENDANT ClVlL ACTION - LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the, attached Pre-Trial Conference Memorandum of Defend anI. Andrea L. Singiser to be served by regular first class mail upon: Matthew S. Crosby, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road, P.O. Box 1177 Harrisburg, P A 17108 . / Y iLI/ Date: Aoril4. 2002 Ji D nald R. Dorer, Esquire Attorney for Defendant . --. . 1-- -. Commonwealth of Pennsylvania County of Cumberland John A. Hair and Debra Hair" his wife Court of Common Pleas VI. No. __mu2.9_,:J_~!L(::j"yj"lu't~);:!!L_m 19__u Andrea L. Singiser 200 S. York St. Mechanicsburg PA 17055 In _ __ ___uG;1..x;1.J" _Ar;;; .b.!9JL_-=-__4.<!JL__________ l Andrea L. Singiser: To You are hereby notified that ._ _ ___ u_3_<?AI} _ _f},~. Ii9_;~ ._~ p_(LJ1!;J.QLcU!gJ_r;:,__ QJ..!2__~j._~!;J______ u_ _m__ _______m _ _ _ ____ the Plaintifl3 hlYe commenced an action in ____u_.s.llIIlIllons__-=_J::.i.'lil_Actinn__~_L.aK___u___ against you which you are required to defend or a default judgment may be entered against you. /' (SEAL) -' '. . CURTIS R. LONG r ~-.~. -- Date _____;[gJl1.1A!'Y.._!l_L___________ 19__~_9 1 1 I I '" .... E l-l Q) E-< o-i .r! > .r! U '" N .... I "', "'. <l Z . -. '- '. '- '- . " 'tl c: en rtl'r! .c: l-l 'r! rtll-l :I:..-i rtl .:I: o<l; rtl c: l-l .c:.o o <ll .-,Q <ll .... '.-i " l-l <ll en 'r! 01 c: .r! tn s! . ...:l rtl <ll l-l 'tl c: o<l; 1:1 .... a I tI) " rtl ...:l c: o .r! ..... o o<l; o-i 'r! > 'r! U "'-. ~._'. Ii ~ It !. litn8 ~ ~~j~f~ "'0 o-i .... ..... ..C"")~ _ ~ ~ ~ -< ,- C) t~ L1'': i':~ ~ UJ C"; N <::: () , , ~._~ . r-:: ~...,. ~.' L:- - ,~j i " ~j , .. _C C'::) ,:-.~ ..--: Lc ... li.:. " ( LI ~.:;~ (J... -, , L en :':") C~l C~l 0 ~ >- '" :3: (-1; '"---.: ~o::~ffi .... 00 '. , -' 0 0-. ,- " N c~ , r<\ " ..... ..... 0 0 uJ- . .... 0 ("-,. . . ):: caca~~ .... ..... - M : 'yo Vi 0 , r~~' '1:;~j .... ~ N M - ~:jl.- ti , M . - v.I >< 00 N , ' , ) .".- W' SZ~ca >- -" 0 :i.ll""i ~ ,-_.; . ~ .:,.. .... CO ....N ..... ~ oj L_]'-- .'c._ r :E ::l ~- l...~ ~ : i: ~ J ~f::3 rJJ :z: ci ~ ..... ..... :!CL '" ~ a:: 0-. .,,; 'E ..... >< ::s ~ ,. " ::t::~~~ <:> M oj oj -I Cl ;.... (,) .... ::: t.L. .... .... ~ ~ <.. r "-. ... ~ -. ~ , ~ , ~ ~ .,."t t ~ 1 ~ .' \ ~. ... -- '- -- , -" \ JOHN A. HAIR and DEBRA HAIR, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUl\IBERLAND COUNTY, PENNSYLVANIA NO. 99- ;;)<i Civil v. CIVIL ACTION - LAW ANDREA L. SINGISER, Defendant JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue a Writ of Summons against the Defendant, Andrea L, Singiser, at tile following address: 200 South York St. Mechanicsburg, PA 17055 and have the Sheriff of Cumberland County serve the same, mitted, IENER, HENNING ERG BY: Matthew S. rosby, Esq, ID No. 69367 319 Market St., P.O. Box 1177 Harrisburg, PA 17108 Tel. No,: 717-238-2000 DATE: "(/1/09 Attorneys for Plaintiffs r--- I I I I SHERIFF'S RETURN - REGULAR -----------~ I CASE NO: 1999-00128 P CO""ONWEALTH OF PENNSYLVANIA: COUNTY OF CU"BERLAND HAIR JOHN A ET AL VS. SINGISER ANDREA L CPL. "ICHAEL BARRICK CU"BERLAND County, Pennsylvania, to law, says, the within WRIT OF . Sheriff or Deputy Sheriff of who being duly sworn according SUM"ONS was served upon SINGISER ANDREA the defendant, at 9:16 HOURS, on the 14th day of January 1999 at 200 S. YORK ST MECHANICSBURG. PA 17055 .CU"BERLAND County, Pennsylvania, by handing to RANDY SINGISER a true and attested copy of the WRIT OF SU""ONS and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.20 .00 8.00 So answers :.., =--("?~ ~ 7. ..;?~~~ /",,,,g' . H. I'homas KIJ.nel S erJ. 1 B~~.~0 HANDLER, WIENER, HENNING 01/19/1999 by.. /<<j.' ,-./,/,- ~/~-~ /l /// ,..\' " Sworn and~subscribed to before me ti.- 9' this J'i,;' - day of ""~'/ A .... ~ I 19 9'i~ A.D. ~ ~ Cf,. ntd ~~7i( . .... rothono arf,...- ,., " CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR, HIS WIFE -AUTO TERM. -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE defendant certifies 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 the 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. @~{C2.o ~ DATE: 06/01/2000 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DEll-186870 :L9454-L02. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR, HIS WIFE -AUTO TERM, -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS RED NECK TRAILER SUPPLIES COHHllNITY FAMILY MEDICINE TODD L. SAMUELS. M.D. EMPLOYMENT MEDICAL MEDICAL TO: MATTHEW S. CROSBY. ESQUIRE MCS on behalf of DONALD R. DORER. ESQUIRE 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 pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: OS/25/2000 MCS on behalf of DONALD R. DORER. ESQUIRE Attorney for DEFENDANT CC: DONALD R. DORER. ESQUIRE MARGARET DRISCOLL - 99HB-00136 - 5837A911811 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-1229Z2 :L 9 4.5 4 - C 0 2. .-"-. , . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN A. & DEBRA HAIR, H/W VS File No. 99-128 ANDREA L. SINGISER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: RED NECK TRAILER SUPPLIES (Name of P~rson or Entil)') Within t'n"enty (20) days after service of this .subpoena. you are ordered by the court to produce the foIl owing documents or things: SEE ATTACHED .t MCS GROUP INC. 1601 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 (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 tv.'enty (20) da)'s after its service. the party serving this subpoena may seek a court order compelling )'OU to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOYVING PERSON: SAME: DONALD R. DORER, ESQUIRE ADDRESS: 214 SENATE AVENUE, SUITE 503 CAMP HILL PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID It: ATTORNEY FOR: THE DEFENDANT DATE: fYl ':J '1 ;):? .:LDOO . Prolhonotary/Clerk, Civil Oi n a~ p '77?rJV2.<~ / Deputy '--- Se.l of the Court E..'XPLt\NATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RED NECK TRAILER SUPPUES 10 ROADWAY DRIVE CARLISLE, PA 17013 RE: 19454 JOHN A HAIR Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject: JOHN A HAIR 304 WALL STREET, HUMMELSTOWN, PA 17036 Social Security#: 211-58-1720 Date or Birth: 03-24-1964 SUlO-249252 ::L.94S4-L02. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR, HIS WIFE -AUTO TERM. -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE defendant certifies 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 the 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: 06/01/2000 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DEll-186871 ~9454-L03 ,II COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER OF: COURT OF COHMON PLEAS JOHN A & DEBRA HAIR. HIS WIFE -AUTO TERM. -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS RED NECK TRAILER SUPPLIES COMHONITY FAMILY MEDICINE TODD L. SAMUELS, M.D. EMPLOYMENT MEDICAL MEDICAL TO: HATTIIEll S. CROSBY. ESQUIRE MCS on behalf of DONALD R. DORER. ESQUIRE 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 pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: OS/25/2000 MCS on behalf of DONALD R. DORER. ESQUIRE Attorney for DEFENDANT CC: DONALD R. DORER; ESQUIRE MARGARET DRISCOLL - 99HB-00136 - 5837A91IBl1 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-122922 19454-C02 COMMON1VEAL TH OF PENNSYLVANIA, COUNTY OF CUMBERLAND JOHN A. & DEBRA HAIR, H/W VS File No. 99-128 ANDREA L. SINGISER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: COMMUNITY FAMILY MEDICINE (Name of Person or Entity) \,\'ithin twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC. 1601 MARKET STREET SUITE 800 PHILADELPHIA PA 19103 (Address) You may deli\'er 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 YOll fail to produce the documents or things required by this subpoena, within twenl)' (:!O) 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 FOLLO\^lING PERSON: ~AME: DONALD R. DORER, ESQUIRE ADDRESS: 214 SENATE AVENUE, SUITE 503 CAMP HILL PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID 1': ATTORNEY FOR: THE DEFENDANT DATE: r>2~" ~? .J. C"~oC\ ( , Prolhonot~l')1aerk. Ch'U Di...i . a~, p ~t??~"G f . Deputy ----- Seal of the Court E.."U'LANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMUNITY FAMILY MEDICINE CENTER OF SOlTI1IPOINT 1305 MIDDLETOWN ROAD HUMMELSTOWN, PA 17036 RE: 19454 JOHN A HAIR INCLUDE ANY AND ALL REPORTS. Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: JOHN A HAIR 304 WALL STREET, HUMMELSTOWN, PA 17036 Social Security#: 211-58-1720 Date of Birth: 03-24-1964 SUIO-249254 19454-L03 f CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR, HIS WIFE -AUTO TERM, -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE defendant certifies 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 the 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: 0610112000 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DEll-186872 1. 9454 -L 0 4 . I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR, HIS WIFE -AUTO TERM, -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS RED NECK TRAILER SUPPLIES COMMUNITY FAMILY MEDICINE TODD L. SAMUELS. M.D. EMPLOYMENT MEDICAL MEDICAL TO: MATTHElI' S. CROSBY. ESQUIRE MCS on behalf of DONALD R. DORER. ESQUIRE 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 pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 05[25[2000 MCS on behalf of DONALD R. DORER. ESQUIRE Attorney for DEFENDANT CC: DONALD R. DORER. ESQUIRE MARGARET DRISCOLL - 99HB-001.36 - 5837A911.81.1. Any questions regarding this matter, contact THE MCS GROUP INC. 1.601. MARKET STREET #800 PHILADELPHIA. PA 1.91.03 (21.5) 246-0900 DE02-1.22922 ~94.s4-C02 ... "- , . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN A. & DEBRA HAIR, H/W VS FileNo. 99-128 ANDREA L. SINGISER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: TODD L. SAMUELS, M.D. (N.ame of Penon or Enrit),) \\.ithin h\.enty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED .t MCS GROUP INC. 1601 MARKET STREET SUITE 800 (Address) PHILADELPHIA PA 19103 You may delh'er 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 abo\'e. You have the right to seek. in advance, the reasonable cost of preparing the copies or producing the things sought. If you faj] to produce the documents or things required by this subpoena. within twenty (~O) days after its service, the party serving this subpoena may seek a court order compelling )'ou to comply with it. THIS SUBPOE!\:A WAS ISSUED AT THE REQUEST OF THE FOLLOWI!\:G PERSON: !'\AME: DONALD R. DORER, ESQUIRE ADDRESS: 214 SENATE AVENUE, CAMP HILL PA TELEPHONE: (215) 246-0900 SUPREME COURT lD Ii: ATTORNEY FOn, SUITE 503 17011 THE DEFENDANT DATE: (Yl;-,y .;).11 ;;;l.not'~ Prothonota1)'/Oerk, Ch..n Divis' ~ @.-,. 0 P ~O?~~r- Depu. '- Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TODD L. SAMUELS, M.D. 890 POPlAR CHURCH ROAD SmTE 107 CAMP HILL, P A 17011 RE: 19454 JOHN A HAIR INCLUDE ANY AND ALL REPORTS. I Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and inclnding the present. Subject: JOHN A HAIR 304 WALL STREET, HUMMELSTOWN, PA 17036 Social Security #: 211-58-1720 Date or Birth: 03-24-1964 SUlO-249256 :L 9 4- 54- - L 0 4- ~ cO "E. :;z C'-' ~ 0 N ::::>.0: 'CI'~' 8~ _2(~:1 "c \..........-.. C- 0;;-"- '.I .L. et-- ,",.5:! ("> U"l ;'!}~ c.: I HO- - n:.:-Z ~!l.'1 ,,- L",jU..l u-::-.:. :::> t1Jo.. l-' .., :z '6 c:> {3 c:> ;s:: ("") N ~ C.,; .., 0" ~ ::-J O~ O~ (J~ ~~ a:Z LUUJ 0)0... ::;: a ~ wO c..)~ ~['i:?1J )~~, u~ U.J ,)- ~~q J.- t-- ...0 ..::: o :r.: """ ~ '') '" - II Q';;:: ~ cl'jClC: :5 u_o ffiQ~ >- u::(j)~ u.....C'J I..l..<llr--..,O _~o "I~ ~ 0-"_0 u...~'00 V> 0 OVi:::::g ~]g:~ a::: ~~'"'f ~ 0 'M ~:;:: ~";J UJQ~~ ~ ~~ t;; ,-~M ~;:::~::::: <t:UJ2""r ::c::i~ u<{u>r--.... <(("")t:r--.... zoo~ :r: 0 :5"'<t~r--... << :r: -,3 , . III... .' JOHN A. HAIR and, DEBRA HAIR, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 99-128 CIVIL ACTION- LAW JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice is served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense or objections to the claim set forth against you. You are warned that if you fail to do so the case may proceed without you and 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. NOTICIA Le han demand ado a usted en la corte, Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene vienta (20) dias de plazo al partir de al fecha de la demand a y la notificacion. Usted debe presentar una apariencia escrita 0 en persona a por abogado y archivar en la corte en forma escrita sus defensas 0 sus objectiones alas demandas en contra de su persona, Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda, Usted puedo perder dinero o sus propiedades 0 otros derechos importantes para usted, LLEVE ESTA DEMANDA A UN ABODAGO IMMEDJATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEPONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL, ANDREA L. SINGISER, Defendant DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 North Front Street, Harrisburg, PA 17101 Telephone: (717) 232.7536 H ING & ROSENBERG By Matthew S. Cros I. D. No. 69367 319 Market Street P. O. Box 1177 Harrisburg, PA 17108.1177 (717) 238.2000 Attorneys for Plaintiffs , Seq/complaint.-';;/hair.mva JOHN A. HAIR and, DEBRA HAIR, his wife Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 99-128 ANDREA L. SINGISER, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED COMPLAINT AND NOW, come the Plaintiffs, JOHN A, HAIR and DEBRA A. HAIR, by and through their attorneys, HANDLER, HENNING & ROSENBERG, by Matthew S, Crosby, Esquire, and make the within Complaint against Defendant, ANDREA L. SINGISER, and in support thereof, avers as follows: I. Plaintiff, John A. Hair, is an adult individual currently residing at 304 Wall Street, Hummelstown, Pennsylvania, 17036, 2, Plaintiff, Debra Hair, is an adult individual currently residing at 304 Wall Street, Hummelstown, Pennsylvania, 17036, 3, Defendant, Andrea L, Singiser, is an adult individual currently residing at 200 South York Street, Mechanicsburg, Pennsylvania, 17055, 4, At all times material hereto, the road and weather conditions were clear and dry, 5, At all times material hereto, Plaintiff, John A. Hair, operated a 1994 Suburu Justy, Delaware Registration No, 438892, owned by John A. Hair and Debra Hair (hereinafter "Plaintiffs' vehicle"), s 6, At all times material hereto, Defendant, Andrea L. Singiser, was the operator of a 1993 Ford Taurus, Pennsylvania Registration No. JJB808, owned by R,L. Singiser and Andrea L. Singiser (hereinafter "Defendant's vehicle"), 7, On or about January 28, 1997, at approximately 12:50 p.m" the Plaintiffs' vehicle was traveling northbound on South Market Street approaching the West Simpson Street intersection in Mechanicsburg, Cumberland County, Pennsylvania. I I. On or about January 28, 1997, at approximately 12:50 p,m" Defendant's vehicle was traveling eastbound on West Simpson Street approaching the South Market Street intersection in Mechanicsburg, Cumberland County, Pennsylvania, 12, At approximately that same time, Defendant's vehicle approached the traffic light at the West Simpson Street-South Market Street intersection, Defendant saw that the traffic light was red for eastbound West Simpson Street traffic, but despite that knowledge, she proceeded into the intersection, 13, At approximately that same time and place, Plaintiffs' vehicle approached the traffic light at the West Simpson Street-South Market Street intersection, Plaintiff noticed that the traffic light was green and proceeded into the intersection, attempting to continue northbound on South Market Street. 14, Suddenly and without warning, Defendant's vehicle struck the Plaintiffs' vehicle and a violent collision resulted. 15. The aforementioned collision was so severe that Plaintiffs' vehicle was rendered inoperable and necessitated towing. 16, At the time of this collision, Plaintiffs', John A. Hair and Debra A. Hair, were insured under a motor vehicle policy through Allstate Insurance Company written and issued under the laws 2 . of the State of Delaware, Inasmuch as Plaintiff, John A. Hair was operating a motor vehicle registered in a state other than Pennsylvania, he is presumed to enjoy benefits of full tort coverage pursuant to 75 Pa, C,S,A. 91705(d), 17, As a direct and proximate result of the negligence of Defendant, Plaintiff, John A. Hair and Debra Hair, sustained serious and extensive injuries as set forth more fully below, COUNT I JOHN A. HAIR v. ANDREA L. SINGISER 18, Plaintiff, John A. Hair, herein incorporates paragraphs I through 17 ofthis Complaint into this count as if fully set forth at length, 19, The occurrence of the aforementioned collision and all of the resultant injuries to Plaintiff, John A, Hair, are the direct and proximate result of negligence, carelessness, and/or recklessness of the Defendant, Andrea L, Singiser, generally and more specifically as set forth below: (a) In failing to be reasonably vigilant to observe the position of Plaintiffs' vehicle or the roadway; (b) In failing to operate said vehicle in such a manner that would allow her to apply the brakes and stop before striking Plaintiffs' vehicle; ( c) In failing to operate said vehicle under proper and adequate control in order that she could avoid striking Plaintiffs' vehicle; (d) In failing to operate said vehicle at a speed, and under such control, so as to be able to stop within the assured clear distance ahead, in violation of75 Pa, C.S,A. 93361; 3 (e) In failing to exercise the high degree of care required of an operator of a motor vehicle entering and/or approaching an intersection; (f) In failing to yield the legal right of way to Plaintiffs' vehicle; (g) In failing to maintain proper and adequate observation of the traffic conditions then and there existing; and (h) In failing to stop for a red traffic-control signal then and there existing, in violation 75 Pa,C,S.A. S 3112, 20, As a direct and proximate result of the negligence of Defendant, Plaintiff, John A. Hair, sustained severe injuries including, but not limited to, occiptal nerve neurlagia, severe headaches, shoulder and neck pain, and muscle spasms. 21. As a result of Defendant' s negligence, Plaintiff, John A. Hair, has suffered great physical pain, discomfort, and mental anguish, and will continue to endure the same for an indefinite period of time in the future, to his great physical, emotional, and financial detriment and loss, 22. As a result of Defendant's negligence, Plaintiff, John A. Hair, has suftered lost wages and will in the future continue to suffer a loss of income and/or loss of earning capacity, 23, As a result of Defendant's negligence, Plaintiff, John A. Hair, has been compelled, in order to effect a cure for the aforesaid injuries, to spend money for medicine and/or medical attention, and will be required to expend money for the same purposes in the future, to his great detriment and loss, 24. As a result of said Defendant's negligence, Plaintiff, John A. Hair, has been, and probably will in the future be, hindered from attending to his daily duties, to his great detriment, loss, humiliation, and embarrassment. 4 25, As a result of Defendant's negligence, Plaintiff, John A. Hair, has suffered a loss of life's pleasures, and will continue to endure the same in the future to his great detriment and loss, 26. Plaintiff, John A. Hair, believes, and therefore, avers that his injuries are permanent in nature. WHEREFORE, Plaintiff, John A. Hair, seeks damages from Defendant, Andrea L. Singiser, in an amount in excess of twenty-five thousand dollars ($25,000,00), and demands a trial by jury, COUNT II DEBRA HAIR v, ANDREA L. SINGISER 27. Plaintiff, Debra Hair, herein incorporates paragraphs I through 26 as iffully set forth at length, 28, As a result of the negligence of Defendant, Plaintiff, Debra Hair, has suffered a loss of consortium, society, and comfort from her husband, John A. Hair, and she will continue to suffer a similar loss in the future, 5 WHEREFORE, Plaintiff, Debra Hair, seeks damages from Defendant, Andrea L, Singiser, in an amount in excess of twenty-five thousand dollars ($25,000.00), and demands a trial by jury. Respectfully Submitted, Date:~QI , ENNING & ROSENBERG Matthew ,C ,sqUIre I.D. No, 69367 319 Market Street P,O. Box 1177 Harrisburg, P A 17108-1177 (717) 238-2000 Attorney for Plaintiffs 6 VERI FICA nON THE UNDERSIGNED hereby verify that the staternents in the foregoing document are based on information that was gathered by counsel in preparation of this lawsuit. The language of the above-narn~d document is of counsel and not our own, We have read the said document and, to the extent that it is based on information that we gave to counsel, it is hue and correct to the best of our knowledge, infonnation and __ belief. .To the extent that the contents of1he said document is that of counsel, we have relied upon our counsel in preparing this Verification, THE UNDERSIGNED also tmderstand that the statements therein are made subject to the penalties of 18 Pa.R.C.P. 2252(d) C.S. Section 4904, relating to unsworn falsification to authorities, DATE: 11-11~C;1 J, DEBRA HAIR ~' / '~~ >- a; "'- ,- w9 0'" fFs; cj;::= 1 C. Or- UJ:". -...' - G:::!.:' , ~ lL ~) tr. ~ ~ => 0:;( 07 if:. Q~ ~,.~ :51:.;; "1m ~n'o... -' 9 :::: c.. -"" N ;:,. CJ :z: CT> <.n , , ..., '" -- - Q:l ;.,J .- ::l<rJ ~QO~ wOO ;0.. f"") - ~ Q i:...':l.t < 0 < =,.l ...~ ~ to =-.i I f'I"'j o r.1'l to- W. ..._r-- ~=:i!:::3~r::- ., 0 '" " - ~ur.l::loo::t:r::-;:: < ~ c.. -- ~N ~ c ~ u ~ ,. .~ ~\ . , ~ ,.99HB-00136 " .... ~ LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendant, Andrea L. Sin iser JOHN A, HAIR AND DEBRA HAIR, HIs WIFE, PLAINTIFFs IN DIE COURT OF COMMON PLEAS CUl\1BERLAND COUNTY, PENNSYLVANIA VS. No. 99-128 ClVlL TERM ANDREA L. SINGISER, DEFENDANT ClVlL ACTION - LAw JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO TIlE PROmONOTARY: Please enter a RULE upon plaintiff to fIle a C m the entry of a Judgment of NonPros. r suffer Date: November 23. 1999 nald R. Dorer, Esquire Attorney for Defendant RULE TO FILE COMPLAINT AND NOW, this d,,4- day of c.:r~ , 1999 a RULE is hereby entered upon the Plaintiffs to fIle a Complaint herein within 20 days after service hereof or suffer the entry of a Judgment of Non Pros. '- " ," '< .::- -,' " " ., ," ............\,.' . 99HB~136 ~ .~ LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attome s for Defendant, Andrea L. Sin iser JOHN A. HAIR AND DEBRA HAIR, HIs WIFE, PLAINTIFFs IN DIE COURT OF COMMON PLEAS CUl\1BERLAND COUNTY, PENNSYLVANIA VS. No. 99-128 ClVlL TERM ANDREA L. SINGISER, DEFENDANT ClVlL AcrlON - LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecioe for Rule to File Comolaint to be served by regular first class mail upon: Matthew S. Crosby, Esquire Handler, Henning & Rosenberg 319 Market Street, P.O. Box 1177 Harrisburg, PA 17108 Date: November 23. 1999 Donald R. Dorer, Esquire Attorney for Defendant >- ~ ~ Ln M =>:'!:; UJ8 o=,.. 0,.,.- x: u;r: ti:.~.? a.. >' '.L.,...t... ,-::)'2 ~f/ -=r :i'co <'oJ .~JZ ti! ;l~ feZ :::.. ll!W = -rno- I- ~ '..",-;; "- en => 0 "" U - .... ~ - QO ~~ ~~~ '" -< ~ - Cl'I I o...l,.,., , "'"'...... =_ ~".J. < -= ~ I"" I.o.o~ lI) _I'""- ...""",,, ~ l.o.l .Jr"i_ OU'l""l:!-o....lf"-r--- ;:tCQZS::a-t:: ~o~oo ~_ ~ u e:..... .. <~ ~-~ ~M U '- ... '.- j-.... ~ - ;-99HB-00136 ",- LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp HiD, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendant, Andrea L. Sin iser JOHN A. IIAIR AND DEBRA IIAIR, HIs WIFE, PLAINTIFFs IN DIE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 99-128 ClVlL TERM ANDREA L. SINGlSER, DEFENDANT ClVlL AcnON - LAw JURY TRIAL DEMANDED ENTRY OF ApPEARANCE TO THE PROTIIONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendant, Andrea L. Singiser. Respectfully submitted, iaa&SABA 'Donald R. Dorer, Esquire Attorney for Defendant Identification No. 39126 Date: November 23. 1999 , - <'99HB-00136 . - LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendant, Andrea L. Sin iser JOHN A. HAm AND DEBRA HAm, HIs WIFE, PLAINTIFFs IN DIE COURT OF COMMON PLEAS CUl\1BERLAND COUNTY, PENNSYLVANIA VS. No. 99-128 ClVlL TERM ANDREA L. SINGISER, DEFENDANT ClVlLACTION-LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Entrv of Aooearance to be served by regular first class mail upon: Matthew S. Crosby, Esquire Handler, Henning & Rosenberg 319 Market Street, P.O. Box 1177 Harrisburg, P A 171 08 Date: November 23. 1999 .:'t C" 2; ;c Cf' C1' E; ~j~ ('")~ c'):~ ~_::J:3 :r- (~',:- ~,[~ ~ . j ill ~_,} !J.- ~;:-;.. --) (j ~ ,- n U.('/ Uc ~~~~ , ' c:> u., ~ \---- 'L <:> N ..-: M - ~ c.. --~.- ~== ~ Cl:: ~c:i::: :'i u_o u-N u:: '"->~ ~I~~ u.. ~"'o iliO 0--0 u::~...oo ~ 0 u......-r--...o ~]~~ OVl~o 00: :?~ '"'f => 0 -M ~ Q ~~M ~ ~~ es ~ g>~ Vlll.JQ.lV ::ci~ C2o--5l~ 15<<nr--:. ~;:;-i::'" zoo~ :r: 0 ::s">t~r--... :r: - 0 ~ - ~ .. . , . .' J " ' JOHN A. HAIR and DEBRA HAIR, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- DO 12~ Civil v. CIVIL ACTION - LAW ANDREA L. SINGISER, Defendant JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF DAUPHIN I, MATTHEW S. CROSBY, hereby certifY that I served the Complaint; Plaintiffs' First Set ofInterrogatories Propounded upon Defendant; and Plaintiffs' Request for the Production of Documents Propounded upon Defendant in the above-captioned matter on Defendant, Andrea 1. Singiser" by Certified first-class United States mail, return receipt requested, and said docmnents were received by said Defendant on November 22, 1999, as evidenced by the signed return receipt card, attached hereto and made a pmt hereof, along Sworn to before me and ~u..bscribed this ::? 3 day of NgVQMhov' 1999, ~#~/ N . ary Public ' NOTARtAl SEAL VERA F, FREED, Nol1lry PubIc City of HIltrIsburg, Dauphin Counly M Commisslc'f; ::~ '~'P~r~s A . 28. 2001 (SEAL) with the copy of the transmittal letter. , /' C Complete items 1 and/or 2 for additional serv~(!s.. Campi ale items 3, 4a, and 4b. C Print your name and address on the reverse olll1l~ torm so that wa can relum this card to you. C Attach lhis form 10 the fronl ollhe mailpiece. or (In l!'le back If space does nol permit. C Write "Return Receipt Requested"on Ihe mallpll:,ce belowlhe article number. [J The Relurn Receipl will show to whom the er1IL.1a was delivered and !he date delivered. 3. Article Addressed to: N b A,:;o~'EA- SeJ\.lG IS'Z. R.. 2.00 ~cUTI-\ 'lORY- IT NC.(.l.\f\>-=lIC.$JRG- PA- 170'55 , .. ~ ,.., .~ ': I~ ,> i!! , ~ "" ,- 'c o ,'" {l '0. E '0 u SENDER: '<< ,I~ c 6. Signature (Addressee or Ag I II 11\ III I ',!!! PS Form 3811 , December 1994 NSC. ::71-1 I also wish to receive the follow- ing services (for an extra fee): 1. 0 Addressee's Address 2. 0 Restricted Delivery fOG, ~ertified o Insured ndise 0 COD II I 111111111 I II ( III 10<:595-99-8-0<:23 Domestic Return Receipt ~ ....' . , > ,-, ,; u 1: ~ '" Q. .. u ~ a: c )j ~ a: '" c u; ~ ~ oS ~ o >- '" c '" "" .... . . -. ,- i \ .. .- ~.. .i I ~. ~ . HANDLER HENNING& ROSENBERG .,....".. D w........... Z 318 819 106 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use fOf International Mail See reverse Se '.~TOf1"C"C ," , .:~ i 1\ ~'>: ~ ~ _' ;-' :... 319 Market Street, PO, Box 1177 Harrisburg, PA 17108 (717)238-2000 ' (717}233-3029 Fax November 19, 1999 'Postage $ Crosby@hhrlaw.com Certified Fee Special Delivery Fee Re: Hair, et ux, v, Sinqiser Cumberland County No, 99.128 Civil Civil Action - Law; Jury Trial Demanded Restricted Delivery Fee on ~ Return Receipt Showing 10 .... \oVhom & Dale Delivered "8,. Retum Rec~ Showing to Whom, <( Dale, & Addressee's M:tess o :i6 TOTAL Postage & Fees $ M Postmark or Date E o LL CJ) ll.. Ms, Andrea L, Singiser 200 South York St. Mechanicsburg, PA 17055 Dear Ms, Singiser: In con.nection with the above.referenced matter, enclosed please find the following: 1, A Complaint in this matter; 2, Plaintiffs' First Set of Interrogatories Propounded upon Defendant; and 3, Plaintiffs' Request for the Production of Documents Propounded upon Defendant. We are serving these documents"on you and urge you to either seek legal counselor inform your insurance company of this lawsuit; then, you should provide these documents either to your attorney or to your insurance company. Thank you for your attention to these matters. J .. Matthew S, Gros MSC/vf/enclosure VIA CERTIFIED MAIL-RETURN RECEIPT REQUESTED cc: Mr. and Mrs. John Hair \ >- a' f':: a; C -7 ~ N :"3 -< UJc"? (J ~ -f2() C.J 'L "*_ c- 0 ?I C)t--~, , ., tn I . , ,- :-tt L" L__ s::: G~l.J_ LL: Lt~; .: U I I.U l.....! ';) CL ~. = :.5 u. en 0 'J' U - ... < '" - 00 " 0 00 '" '" z ... 00 0 ~ -< '" - '" I ~'" 0_ ~oo <<:oa:; ,,,, ....~ t.JlI) -... ~ .... '" :r~ ~ o v:l o<t!-o ;: := z ;:; -~- :=...... <o~tI.:l -~ ...lu... :....... .. :>: - ~ <- " " ....,.... u ~ I ~ .' .' ~ - . , 99HB-00136 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp HiD, P A 17011 Telephone Number: (717) 731-0988 Attorne s for Defendant, Andrea L. Sin iser JOHN A, HAIR AND DEBRA HAIR, HIS WIFE, PLAINTIFFS IN DIE COURT OF COMMON PLEAS CUl\1BERLAND COUNTY, PENNSYLVANIA VS. No. 99-128 ClVlL TERM ANDREA L. SINGISER, DEFENDANT ClVlLAcrION-LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANT, ANDREA L. SINGISER, TO PLAINTIFFS' COMPLAINT 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 11} Admitted. 12.-17. Denied. These paragraphs are generally denied pursuant to Pa.R.C.P. U029(e). 1 By way of further statement, the paragraphs in Plaintiffs' Complaint are misnumbered, and Answering Defendant has numbered the paragraphs as designated in Plaintiffs' Complaint. 18. Paragraph 18 is an incorporation by reference paragraph as to which no response is required by Defendant. 19.-26. Denied. These paragraphs are generally denied pursuant to Fa.R.C.P. U029(e). 27. Paragraph 27 is an incorporation by reference paragraph as to which no response is required by Defendant. 28. Denied. This paragraph is generally denied pursuant to Fa.R.C.P. ~1029(e). WHEREFORE, the Defendant respectfully prays this Honorable Court to dismiss Plaintiffs' Complaint, and to enter judgment against the Plaintiffs and in favor of the Defendant. NEW MATTER 29. Paragraphs 1 through 28 are incorporated herein by reference, and made a part hereof as if set forth in full. 30. Plaintiff's claims are barred in whole or in part by the provisions of the Pennsylvania No-Fault Motor Vehicle Insurance Act and/or the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, the Defendant respectfully prays this Honorable Court to dismiss Plaintiffs' Complaint, and to enter judgment against the Plaintiffs and in favor of the Defendant. Respectfully submitted, OF JA5~S (s: . By: ~~( DOn d R. Dorer, Esquire Attorney for Defendant Identification No. 39126 Date: December 9. 1999 99HB-00136 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, P A 17011 Telephone Number: (717) 731-0988 Attome s for Defendant, Andrea L. Sin iser JOHN A. HAIR AND DEBRA HAIR, HIs WIFE, PLAINTIFFS IN DIE COURT OF COMMON PLEAS CUl\1BERLAND COUNTY, PENNSYLVANIA VS, No. 99-128 ClVlL TERM ANDREA L. SINGISER, DEFENDANT ClVlLAcrION-LAw JURY TRIAL DEMANDED VERIFICATION I, Andrea L. Sinlriser , verify that the statements made in the foregoing Answer with New Matter of Defendant. Andrea L. Sinlriser. to Plaintiffs' Complaint , which are within the personal lmowledge of the undersigned, are true and correct, and as to the facts based on the information of others, the undersigned, after diligent inquiry, believe them to be true. And further, this Verification is signed on the recommendation of my attorneys, who advise me that the allegations and language in this document are required legally to raise issues for resolution at trial, by the Court, or by continuing investigation and preparation for trial. I understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete and I leave the determination of these matters to my attorneys on their advice. I understand that all statements herein are made subject to the penalties of 18 Pa.C.S.A. ~4904, relating to unsworn falsifications to authorities. Dated: li7, (It"Jlr/<l/'(/ (. /t/tl1 , UJtlif1P Ie. X, x.t /)~(J < 4 "/( J Andrea L. Singiser ----~ --- - - , 99HB-00136 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp HilI, PA 17011 Telephone Number: (717) 731-0988 Attome s for Defendant, Andrea L. Sin iser JOHN A. HAIR AND DEBRA HAIR, HIS WIFE, PLAINTIFFS IN DIE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 99-128 ClVlL TERM ANDREA L. SINGISER, DEFENDANT ClVlLAcrION-LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Answer with New Matter of Defendant. Andrea L, Simriser. to Plaintiffs' Comolaint to be served by regular first class mail upon: Matthew S. Crosby, Esquire Handler, Henning & Rosenberg 319 Market Street, P.O. Box 1177 Harrisburg, PA 17108 Date: December 9. 1999 (l) I~ Donald R. Dorer, Esquire Attorney for Defendant '\ >- :f .-: U I ~.:~ C) '. f.F_ (~)~- (':'1 C.J L.~ :._.~ __.J u:.: c, c: i~ >- L~~,; .;-~; ~-,. C- " o U l, ~ c.~ G''\ (.;."\ ~/ , .'Il) 1...1- " , ::-) o . ~ 3= ==~ffi <C w ~ u_o UQ;8 EE~;::::o I :s~~ ~ 0--0 u:~-.oo ~ 0 u...._r--.o l')Q;cf~ oV}~o 0> " ~~ 00 ~ .~cf:.~ => a OlM ~:ci~ ~~~';l !-:::..::: ~M <./)Ll.J'-"'<l'" u::o-.-R~ <(<{2' u ~ "- ~M "Er--. zoo...... :r: 0 :::s"'<l'"~'" :r: -3 <C " r " .. JOHN A. HAIR and DEBRA HAIR, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-128 Civil v. CIVIL ACTION - LAW ANDREA L. SINGISER, Defendant JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO DEFENDANT'S NEW MATTER AND NOW, come the Plaintiffs, John A. Hair and Debra Hair, his wife, by and through their attorneys, HANDLER, HENNING & ROSENBERG, by Matthew S, Crosby, Esq., and reply to Defendant's New Matter, as follows: 29. Paragraph 29 is a paragraph of incorporation and, therefore, no response is required. 30, Denied. The allegations in Paragraph 30 contain conclusions of law to which no response is required, If it is judicially determined that a response is required, the averments contained therein are specifically denied. Page -1- . . .' ~. WHEREFORE, Plaintiffs respectfully request this Honorable Court deny Defendant's allegations and enter judgment in favor of the Plaintiffs, Respectfully submitted, HANDLER, HENNING and ROSENBERG Date:~ ~ By Matthew S, Crosby, Esq. Supreme Court 1.0. # 69367 319 Market Street P.O. Box 1177 Harrisburg, PA 17108 (717) 238-2000 Attorneys for Plaintiffs Page -2- , , " CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was served on the Defendant, ANDREA SINGISER, by sending a copy of the same to her counsel of record, Donald R. Dorer, Esq"JACOBS & SABA, 214 Senate Ave" Ste, 503, Camp Hill, PA 17011, by United States Mail, regular service, in Harrisburg, Pennsylvania on December 10, 1999. By Matthew S. Crosby, Esq, Attorney I.D. #69367 P.O. Box 1177 Harrisburg, PA 17108 (717) 238-2000 Attorneys for Plaintiffs DATE: 1'Llto I q 0, HANDLER HENNING& ROSENBERG ATTORNEYS AT LAW .' 319 Market Street. P. Q. Box 1177 . Harrishurg, PA 17108 . (717)238-2000 140A Eosl King Street, lOIl(osler, PA 17602 . (717}431-4000 - JOHN HAIR, and DEBRA HAIR. his wife. Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 99-128 v. ANDREA SINGISER. Defendant CIViL ACTION. LAW JURY TRIAL DEMANDED AND NOW. this CERTIFICATE OF SERViCE ~/~y of January. 2000. I hereby certify that I have. on this date. served the within Plaintiffs' Responses to Defendant's Request for Production of Documents by sending a true and correct coPy of the same to the attorney of record via first class United States mail, postage prepaid and addressed as follows: Donald Dorer. Esquire 214 Senate Avenue Suite #503 Camp Hill PA 17011 Respectfully. HANDLER. HENNING (4ERG --- ~ Matthew S. Crosby, Esquire fD #69367 319 Market Street POBox 1177 Harrisburg PA 17108 717-238-2000 '>- "I ~ cr.; j:3: ::J< UJ~~ ~ o~~ O'-c U~. G..: ~,::~ 0:: Q::i 'I........ c::.)(==; ~,.~ :>- ;" (I) or~_ -" ~'1;-::: luL- I ~l-Z ci;: <:::l ,dIU W ,1.10- r.:: ....... .<'. ". = ::-.:> 0 0 0 , HANDLER HENNING& ROSENBERG ATTORNEYS AT LAW , - --- --- 319 Merkel Slreet ' P. 0, Box 1177 . Herrisburg, PA 1710B . (717)238-2000 . Fox (717)233.3029 JOHN HAIR, and DEBRA HAIR, his wife, Plaint;iffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No, 99,128 v. ANDREA SINGISER, Defendant; CIVIL ACTION - LAW JURY TRIAL DElv1ANDED CERTIFICATE OF SERVICE 2=-' ' AND NOW, t;his ..$/ day of January, 2000, I hereby certify t;hat; I have, on t;his dat;e, served t;he wit;hin Plaint;iffs' Answers t;o Defendant;'s Int;errogat;ories by sending a t;rue and correct; coPy of t;he same t;o t;he anorney of record via first; class Unit;ed St;at;es mail, post;age prepaid and addressed as follows: Donald R, Dorer, Esquire 214 Senat;e Avenue Suit;e # 503 Camp Hill PA 17011 Matthew S. Crosby, Esquire ID #69367 319 Market; St;reet; POBox 1177 Harrisburg FA 17108 (717) 238-2000 Anorney for Plalnt;iffs .,... "I b. (1; ;:;0 z .. :;:>~ " ..::x I.1j~,> '-.)=-"7 ~?(O) c:: u~ \--:-j: -::J.::J ct" '.....-- , ' -'" :::-~ (I) cr: I .)2: \ uJl:: ,;.: :z: ~:i~ en ULU UJ ,;-)n_ t... u... .....-;; \ --0" c::> :5 a (,) " HANDLER J H~G& ROSENBERG ATTORNEYS AT LAW ,.-~ 319 Markel Slreet . P. o. Box 1177 . Harrisburg, PA 17108. (717)238-2000 - 140A Easl King Street, lancoSler, PA 17602 . (717)431-4000 JOHN HAIR, and DEBRA HAIR, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 99-128 ANDREA SINGISER, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 7~ay of February, 2000, I hereby certify that I have, on this date, served the within Notice of Deposition, by sending a true and COlTect copy of same to the attorney of record, and including a copy to all parties of interest via first class United Statcs mail, postage prepaid, and addressed as follows: (Andrea Singiser) Donald Dorer, Esquirc JACOBS & SABA 214 Senate Avenue Suite #503 Camp Hill PA 17011 HANDLER, HENNING & ERG By: Matthew . rosby, Esquire ID #69367 319 Market Strcet POBox 1177 Harrisburg PA 17108 (717) 238-2000 Attorneys for Plaintiff E= ""i" \_: Ujs.~ W,F c:.> ~: 1-" tl_. L) U) C': M '>- ,-- Iz ~<.'" l-);::;:? 00 - ~.....~ ;':.~ <:.:::: ~;?~ U..ILU :"1"1U-.. --s,; ::5 (,) 0- co I co Lw u... <::) c:> ~ , ~ . CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN TllE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR, HIS WIFE -AUTO TERM. o -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE defendant certifies 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 the 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: 02/21/2000 rI/;~/~ ~ DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DEll-162057 ::r...9454-LO::r... " COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR. HIS WIFE -AUTO TERM. o -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS ALLSTATE INSURANCE COMPANY INSURANCE TO: MATTHEW S. CROSBY. ESQUIRE MCS on behalf of DONALD R. DORER. ESQUIRE 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 pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/30/2000 MCS on behalf of DONALD R. DORER, ESQUIRE Attorney for DEFENDANT CC: DONALD R. DORER. ESQUIRE MARGARET DRISCOLL - 99HB-00136 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-112770 :L 9 454 - C 0 2. ~ , , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN A. HAIR & DEBRA HAIR. H/W VS FileNo. 99-128 A1~REA L. SINGISER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ALLSTATE INSURANCE COMPA1'Y (Name oC Person or Entity) \Vithin ty,,'enty (20) days after service of this subpoena. you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC. 1601 MARKET STREET SUITE 800 (Add~55) PHILADELPHIA PA 19103 You may deliver or maillebible 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 ty.'enty (10) days after its service, the party sen'ing this subpoena may seek.a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: ~AME: DONALD R. DORER, ESQUIRE ADDRESS: 214 SENATE AVENUE, SUITE 503 CAMP HILL PA 1701] TELEPHONE: (215) 246-0900 SUPREME COURT 10 It: ATTORNEY FOR: THE DEFENDANT DATE: Jo.t11{AC~ 172 CJ~ ,:)cf'>(\ ~ Seal of the Court I'r:::(( ?/C"7\ '" EXPIANATION OF REQillRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALLSTATE INSURANCE COMPANY 6345 FLANK DRIVE surm 1000 HARRISBURG, PA 17112 RE: 19454 JOHN A ~WR POLICY NO: 1782961799 INSURED:JOHN A HAIR LOSS DATE: 01/28/1997. Any and aU claims files. Dates Requested: up to and including the present. Subject: JOHN A HAIR 304 WALL STREET, HUMMELSTOWN, PA 17036 Social Security #: 211-58-1720 Date of Birth: 03-24-1964 Date of Loss: 01/28/1997 5U10-232460 19454-LOl )0- S( ,-- l\.' ~~) ,", " '1' t__' l~ , __i .L: r=--: LL o Cl U:. N f:: ;Z~ {~~ 2l:L ," > ,"-:'1:-1 ._.r"-,- >(0 -:1/:':: .!..:;..:: '_lJlLt :Do.... :5 U ::-:c: c._ r- I ::s -, o kM-9!HLO. A!>-ftILO' lB-tlIWI. :ra-r;gLLO "ON Wl:KH -:!Nt "l'f'NOUVNl:lliNl PiV1S-',.... JO NOIS,^IO v "lVD31llV.LS"TlV ;;- ~ = r-- <_ Q oe '" !:: z r-- QC ~ .... ...... ~ .... QO I :::::n~~~~~ t~","lrlg.;":"r-- O:r.~~~~r=: ~=czS:::_- ~ O~:I1:C:~C ...:!~~ ;:t:~ .... ore. ...:: ~M U ~ - -- ~ File No.: 99HB-00136 ~-- PRAECIPE FOR l1ISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate.) -' TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case (check one): ( x) for JURY trial at the next term of civil court. ( ) for trial without a jury. CAPTION OF CASE: (Entire Caption Must Be Stated In Full) (Check One) ( ) Assumpsit John A. Hair and Debra Hair, his wife, ( ) Trespass Plaintiffs (x) Trespass (Motor Vehicle) vs. ( ) Andrea L. Singiser, (Other) Defendant The trial list will be called on Au,,"st 14. 2001 Trials commence on Seotember 10. 2001 Pre.trials will be held on Au,,"st 22. 2001 (Briefs are due S days before pre-trials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to an counsel, pursuant to local Rule 214~1.) No. 99-128 Civil_ 19 99 Indicate the attorney who will try case for the party who files this praecipe: Donald R. Dorer, Esouire. Attornev for Defendant: Jacobs & Saba. 214 Senate Avenue. Suite 503. Caron Hill. Pennsylvania. 17011: (717) 731-0988. Indicate trial counsel for other parties if known: Matthew S. Crosbv, Attornev for Plaintiffs: Handler. Henning & Rosenber 1300 Un lestown Road P.O, Box 1177 Harrisbur PA 17108' 717 238-2000 s~~JJfJ n/fl Print Name: Donald R. Dorer. Esquire This case is ready for trial. Attorney for: Defendant. Andrea L. Singiser Date: June 6. 2001 I 99HB~0136 ,-, -" LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attome s for Defendant, Andrea L. Sin iser JOHN A. HAIR AND DEBRA HAIR, HIS WIFE, PLAINTIFFS IN DIE COURT OF COMMON PLEAS CUl\1BERLAND COUNTY, PENNSYLVANIA VS, No. 99-128 ClVlL TERM ANDREA L, SINGISER, DEFENDANT C1VlL ACTION - LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecioe for Listing Case for Trial to be served by regular first class mail upon: Matthew S. Crosby, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road, P,O. Box 1177 Harrisburg, P A 171 08 Date: June 6.2001 ;Id Donald R. Dorer, Esquire Attorney for Defendant CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR. HIS WIFE -AUTO TERM, -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER. ESQUIRE certifies that 'l (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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: 06/12/2001 MCS on je'f)~f tt1't~ORER~RE Attorney for DEFENDANT DE12-214257 :I. 9 454 - L 0 5 06>'12/01 15:17 HRNDLER HENNING & ROSENBERG ~ 1215245a959 NO. 393 [;101 ..- I ZlI81._-U. 22112 1&87 p.el/ml ClWC&) ll1l1l Market Stroot, Suit, IW, t'hlladelpllia P-.yJvaia 19103 (m) Mll . 09lIll Pa l'I\uabc1' (215) 246 - DIl59 UBGENI'lUll URGENTl1l1l URGENTJIlU Jt11112. 211111 JtIIt... " !IIIlA lWa. lU5 1lIBi JtIIt A IIAZa ~ "" AIIJIa L, 5IHmiI!1l. -SIII:rZl JlIIJlll8 " llA1ll IJ;ftI\U) II. mu, m:ptlII - (717) 7J1-O!I87 "" ~ '- mplItai by tI. ~t1al8d l:lUlftl fD ~ IIStnlAl III 11I1 .. ~t8ll 111m fmIl t1w 111~ U- ~. 111 ol:\1Br tII c::Iqlly1lilb th1a ~_ _)..,. ,.,.... o~ ~,l:IIac l'QI_ ttII -..t,-<lay I!IItU:e proriaI ~ m a.1n o\OlIt.Z1,m:lI,009,U, P1-.!ax ~ faIIn!O \10 A_ ':-17,$ (ZIJI ~6-OlI5~ "Irith 1WI' .4 -tuq 10 I!hD -1I8t cClll>4' 'II1l:h tbia nqa~. ~ 1llIR J ~....um1all4~ pWItq~. ~, waIIIl'IlA "'_1_, H IImmZ CI1ftDI. .............nur~... IIIKIIX . ...._ ~ . ~... __ lIi'1'.IlR IlUl11) a. llJIDI. D.O. __ III1\IlIIL l3I!BR - JtlWllAt, - lI1lICAL . ICI\l:W. - Il!IIIrAL - cmn. - Itill7r& - 0IIIlR .a.-l. !fm!IJl S. CBUr. ~ (717) :D1-J029 I .. w -- *'~ ll8r:IIIl ~ t c _ ... t:D 1111... lUll' Data. 61f).~ I ~: YlO_Ib.2{ tIIlt.: 1Ul.lfJ.-1332U :l. 9 4.1S 4 - C O:L. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A , DESRA HAIR. HIS WIFE -AUTO TERM. -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER NOTICE OP IHTEN'l' TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS POR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations 1 TO: MAT'I'IIEV S. CROSBY. ESQUIU MCS on behalf of DONALD I.. DOltElI.. ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frDlll the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if. no objection is made. then the subpoena may be served. Complet~_ copies of any reproduced records may be ordered at your expense by completinB the attached counsel card and returning same to MCS or by contacting our local MCS office. I- .. .. DATE: 06/12/2001 MCS on behalf of DONALD I.. DOltElI.. ESQUIU Attorney for DEFElIIlAlft CC: DONALD I.. DOltElI.. BSQUIU HAll.GARET DUSCOLL - 998.-00136 - 581 1A911111 " Any questions regarding this matter. contact TIlE MCS GROUP IHC. 1601 HARDT STREET #800 PRILADBLPBIA. PA 19103 (215) 246-0900 DE02-1SS610 :L 9 4 5 4 - C02 >>> LOCATIO. LIST <<< RECORDS REQtJES'l'ED PAGE, LOCATIOH MAHB ~ MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL O'l'llBa .... THB 1IBftXCK: l;.UOYAK C~UT OSTEOPATHIC HOSP. FAMILY (, IH'l'BIXAL H1mICIBJ: DISCOVEl.Y HOUSE REHAB OPUONS DAVID R. BIRCH. D.O. IIE1lSI1BY H1mICAL CEIlTER. ~ - "",--' DE02-1SS610 :J.. 5) 4 54 - C 02. COMM01'lWEAL TH OF PENNSYLVANIA , COUNTY OF CUMBERL.~"D JOHN A, & DEBRA HAIR, H!W VS FiI~ :0-;0. 99-128 ANDREA L. SINGISER SUBPOENA TO PRODUCE DOCUMThlS OR THI:-IGS FOR DISCOVERY PURSUA."-l TO RULE 4009.21 TO: CUSTODIAN OF RECORDS FOR: THE HETRICK CENTER (S.m. o( P~non or Endry) \o\'ithin rwe~' (:OJ days alter sen'ice or this subp~na. you ue ordered by the court to produce the toltowin! documents or things: SEE ATTACHED . .1 MCS GROUP INC;', 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA 19103.- (,~<tclrft.) You; m.~' demon' Of m..n legible copies of the documents ar produce thinss requested by this subpoenz. together with the ctrtifiCJte cr: compliance. to the puty m&king this request at the address listed .above. You h.J.\'e the risht to seek. in .adVAnce. the ~.uonable cost of prtpmn! the copies or producing the thinp soupt. If you f.a.il to ?,=,oduct the documents or thing! required by this subpom.a. wit~..in twenty (~) c!a~'s uter its service. the ?ut)' servin! this s\:opotna m.y seek.. court order C'ompellins: ~'ou to comply with. r_ THIS SLllPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: DONALD R. DORER, ESQUIRE 214 SENATE AVENUE. SUITE 503 CAMP HILL PA 17011 TELEPHOSE: f2l5) 246-0900 Sl:PRE.'fE COI.lllT 10.: ArrOR."E'"t. FOR: THE DEFENDANT :O-;AME: ADDRESS: DATE:........ )'1 ~~C I~ .Jc>oI , BY~~j~T7! ~ Prothonotaty.~' I Div;,... .ao~ '" -p-_'C'J)~, ) ry '-- SuI of the Court ~:f 7/:;:-'1 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: llIE HErRICK CENTER 500 NORllI UNION STREET MIDDLETOWN, PA 17057 RE: 19454 JOHN A HAIR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. \. Dates Requested: up to and induding the present. Subject: JOHN A HAIR . 304 WALL STREET, HUMMELSTOWN, PA 17036 Social Security#: 211-58-1720 Date of Birth: 03-24-1964 5U10-310246 :::L9454-L05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR, HIS WIFE -AUTO TERM, -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER. ESQUIRE certifies 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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. MCS on behalf of DATE: 06/12/2001 DONALD R. DORER. ESQUIRE Attorney for DEFENDANT DE12-214258 :J...9454-LO 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF, COURT OF COMMON PLEAS JOHN A , OEaRA HAIR, HIS WIFE -AUTO TERM, -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER NOTICE OF IN'rEN'r TO SERVE A SUBPOENA TO PRODUCE DOCtJMEIl'rS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enc10sed list of locations 1 TO: MATTBEV S. CROSBY. ESQUIIlB MCS on behalf of DOIlALD R. DOIlB1I.. ESQUIIlB intends to serve a subpoena identicsl to the one that is sttached to this notice. You have twenty (20) j. days from the date listed below in which to file of record and serve upon the .- undersigned an objection to the subpoena. If the twenty day notice period is waived or if, no objection is made. then the subpoena may be served, Complete._ copies of any reproduced records may be ordered at your erpense by completing the attached counsel card and returning S8lll8 to MCS or by contacting our local MCS office. DATE: 06/12/2001 MCS on behalf of DOIlALD R. DOIlB1I.. ESQUIIlB Attorney for DEFElIDAHT CC: DOIlALD R, DORD. ESQUID HAllGABE1' DJUSCOLL _ 9981-00136 - SU1A911I11 .. Any questions regarding this matter. contact THE MCS GROUP INC. 1601 HA!lI[K'f STIlEET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-1SS610 :L 9 4- 54- - C02 >>> LOCATIO. LIST <<< RECOIlDS UQIDsrm MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL ormm. PAGE, LOCATIO. RAMI! nm D'lIlIlX cmrrn CotHllIUY OSftOPArBIC BOSP. FAMILY (, DlTDlIAL MEDICDIB DISCOVEllY BOUSB REHAB OPTIONS DAVID K. BIRCH. D.O, BEB.SIIBY MEDICAL CElITBll. 1 . .. ~ DE02-155610 :L 9 4 54 - C 02. COMMO/\/WEAL TH OF PENNSYLVANIA , COUNTY OF CUMBERLA.."D JOHN A. & DEBRA HAIR, H/W VS File So. 99-128 ANDREA L. SINGISER SUBPOENA TO PRODUCE DOCUMThl"S OR THI~GS FOR DISCOVERY PURSUA.."l" TO RULE 4009.2.2 TO: CUSTODIAN OF RECORDS FOR: COMMUNITY OSTEOPATHIC HOSP. (!".lm.. Q( Penon Ot Entity) \4.'i:hin rwe~' rW) d.ys Uter set"\'k, oE this subp~na. you ue ordered. by the court to produce the following documents or thin!" SEE ATTACHED . ., MCS GROUP INC;., 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA 19103... l."ddnu) You m'~' dem'ft' or ml.illegible copies of the documents or produce thi"'!S reqaested by this subpoena. together with the ctrtificJlf a: compliance. to the parry mwng this request.1t the lddnss listed. .above. 'tau N'" the right to seek. in advance. the :"!uonable cost of preparing the copi~ or producin! the thinp sousht. l! ~'ou fur to ?,=,oduce the documentl or things required by this subpoena. within twenty (:OJ c!a~'s uter its ser'\'ice. the PUT)" sel'"dng t:us 1l.:.:,poen.J may seek.. court order compeHin5 ~'ou to comply with T>_ THIS SLllPOENA WAS ISSUED AT THE REQl:EST OFnrE FOLLOWING PERSON: DONALD R. DORER, ESQUIRE 214 SENATE AVENUE, SUITE 503 CAMP HILL PA 17011 TELEPHOSE: (215) 246-0900 St.:PRE.'fE COURT 10 I: .-\ TIOR."n" FOR: THE DEFENDANT SAME: ADDRESS: DATE: _J" 'iJ= IS .:2("~' I jvision SuI of the Court :.:f ;-::;, EXPLANATION OF REQUIRED RECORDS TO: CUSlODIAN OF RECORDS FOR: COMMUNITY OS1EOPATIlIC HOSP. 4300 LONDONDERRY RD. HARRISBURG, PA 17105 RE: 19454 JOHN A HAIR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. 1 Dates Requested: op to and including the present. Subject: JOHN A HAIR ' 304 WALL STREET, HUMMELSTOWN, PA 17036 Sodlll Sec:ority #: 211-58-1720 Date ofBkth: 03-24-1964 SUlO-310248 :J...9454-L06 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR, HIS WIFE -AUTO TERM, -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER As a prerequisite to service of a subpoena for documents and things pursuant tO,Ru1e 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE certifies 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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. MCS on behalf of DATE: 06/12/2001 DONALD R. DORER. ESQUIRE Attorney for DEFENDANT DE12-214259 :L. 9 454 - L 0 7 COMMONWEALTH OF PENNSYLVANXA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A , DE~RA HAIR, HIS WIFE -AUTO TERM. -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] , TO: MArrBEW S. CROSBY. ESQUIRE HCS on behalf of DOHALD 11.. DOREll. ESQUIRE intends to serre a subpoena identical to the one that is attached to this notice. You have twenty (20) ~ days fr... the date listed below in which to file of record and serve upon the~ undersigned an objection to the subpoena. If tbe twenty day notice period is waived or if no objection is made, then the subpoena may be served, Complete.._ copies of any reproduced records may be ordered at your expense by complettDg the attached counsel card and returning s..- to MCS or by contacting our local MCS office. DATE: 06/1Z/ZOOl MCS on behalf of DOHALD 11.. DOREll. ESQUIRE Attorney for DBFEIlDAII"r CC: DOHALD R. DORD. ESQuDK MAll.GAlll!:T DnSCOLL - 9....001 J. - 5'\1"."811 Any questions regarding this matter. c~t.ct TIIB MCS GROUP IHC. 1601 MARIET STREET #800 PBILADELPBIA. PA 19103 (215) Z46-0900 DEOZ-1SS610 :L 9 4. 54. - CO 2. >>> LOCATION LIST <<< Rl!:CORDS llBQUESTED MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL O'l'llD. PAGE. LOCATION MAHI!: rBI!: 1II!:'l'UCK: cmrrn CO!HlllITY OSn:OPATllIC HaSP. FAMILY r. IIlTI!:1l!IAL MEDICIBI!: DISCOvny BOUSE REHAB OPTIONS DAVID R. BIRCH, D.O. BERSIII!:Y MEDICAL CEH'1'E1I. 1. .,.. DEOZ-1.55610 :L 9 454 - C 0 Z COMMOr-.WEAL TH OF PENNSYLVANIA , COUNTY OF CUMBERL-\..'iD JOHN A. & DEBRA HAIR, H/W VS Fil. :-;0. 99-128 ANDREA L. SINGISER SUBPOENA TO PRODUCE DOctJME'>.,.S OR THI~GS FOR DISCOVERY PURSUA."" TO RULE 4009..22 TO: CUSTODIAN OF RECORDS FOR: FAMILY & INTERNAL MEDICINE (S...m~ or P~non or Entiry) \o\"ithin twe~' (~) diyS after sendee of this subpoena. you ue ordered by the C"Oun to produce the following dacum!nt! or thin!,: SEE ATTACHED ~ >. MCS GROUP INC:, 1601 MARKET STREET. SUITE 800, PHILADELPHIA PA 19103' (..ddno'l You ma~' deih'ft or ml.ilIegible COpiH of the documents or produce things req,aested by this subpMn,l. tog!tht~ with thf cenifiCJtf 0: complLlnu. to the PUTY m.aking this request.lt the ,address Usre<l above. You h,a,oe the right to ~fei<.. In .Id\'UtCf. the ~uonable cost of preparing the copies or producing the thinp sought. If you fail ta ?,=,oduce the documents or things required by this subpoena.. wit.....Jn twenty (~) ca~'s uter its Sfr'\'lce. t~e ?UT)' sen'in! th.is sl,::;,poena may sHk I. COUrt order compelling you to comply with;._ THIS SL"BPOENA WAS ISSUED AT THE REQUEST OF THE FOllOWING PERSO:": DONALD R. DORER. ESQUIRE 214 SENATE AVENUE. SUITE 503 CAMP HILL PA 17011 TEtEPHO:'\E: f2l5) 246-0900 ST.;PRE.....fE COURT 10 I: ATIOR."E't' FOR.: THE DEFENDANT :'\AME: ADDRESS: DATE: .... )" ~"\,c _ I~ .J /"'Y>I Seal of the Court =>! ... EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: FAMILY & INTERNAL MEDICINE OFf1CE OF UNION DEPOSIT 4310 LONDONDERRY RD. HARRISBURG, PA 17105 RE: 19454 JOHN A HAIR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. l. Dates Requested: up to and iDdudiDg the present. Subject: JOHN A HAIR 304 WALL STREET, HUMMELSTOWN, PA 17036 Social Security#: 211-58-1720 Date of Birth: 03.24-1964 SU10-310250 :I..94S4-L07 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR, HIS WIFE -AUTO TERM, -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE certifies that L (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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. MCS on behalf of DATE: 06/12/2001 DONALD R. DORER. ESQUIRE Attorney for DEFENDANT DE12-214260 ::L 9 4- 54- - LOa COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF. COURT OF COMMON PLEAS JOHN A & DERRA HAIR, HIS WIFE -AUTO TERM, -VS- CASE NO. 99-128 ANDREA L. SINGISER -SINGISER NOTICE OF INTEN'r TO SERVE A SUBPOENA TO PRODUCE DQCUMEHTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations I TO: MA1'TIIEW S. CROSBY. ESQUIU MCS on behalf of DONALD R. DORER. ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice, You have twenty (20) 1 days frlllll. the date listed below in which to file of record and serve upon the .. undersigned an objection to the subpoena. If the twenty day notice period is waived or if, no objection is made. then the subpoena may be served. C<lIIIplet"-.: copies of any reproduced records may be ordered at your erpense by caBpletin& the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/12/2001 MCS on behalf of DONALD R. DORER, ESQUIU Attorney for DEPEHDAllT CC: DONALD R. DOIBR, ESQuxU HAJlGAllft DIlISCOLL _ 9'181- 00 136 - 51111A9111l11 MY questions regarding this matter, contact THE HCS GROUP INC. 1601 HARDT STllEET 1800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-155610 ~9454-C02. >>> LOCATIO" LIST <<< PAGE: 1 RECOllDS REQUESTED LOCATIOII !IAMB MImICAL MImICAL MImICAL HEDICAL MImICAL MImICAL OTHER rHB 1IETlUCJ: cmrrn Cl>>MOlfi'l'Y OSftOPATllIC ROSP. PAMILY " IIITBRlIAL MImICIBJl DISCOVERY ROUSE REHAB OPTIOIIS DAVID R. BIRCH, D,O. HERSHEY MImICAL CEJITER. .. -, DEOZ-1SS610 :J...94S4-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERL.-\.."D JOHN A. & DEBRA HAIR, H/W VS Fil~ :-;'0. 99-128 ANDREA L. SINGISER SUBPOENA TO PRODUCE DOCUMTh"TS OR THI~GS FOR DISCOVERY PURSUA..l\o"T TO RULE 4009 .,., CUSTODIAN OF RECORDS FOR: DISCOVERY HOUSE TO: (S...mc o( Penon or Ent:hy) ""Oithin ",'e~' (:0) days Utet 5ero'ke of this subp~na~ you ue ordere-d by th~ C'Ourt to produ~e the following doc\.lf'ents or things: SF.F. ATTACHED .. ot MCS GROUP INC.. 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA 19103 1,~d<1res.) You m'~' deih,tT or mail legible copies of the documents or product things requested b~' this subpoena. together with the certificate a: C'ompli.l,nce. to the PArTY moong this request.Jt the address listed .above. You have the right to seek. in .ad\'MlCf. the ~uonable cost of preparing the copies or producing the things sought. l! you f.JjJ to ?,=,oduct the documents or things requited by this subpoen..a.. wit,hin twenty (20) C:."s aiter its ser'\"ice. the pa.ny sen'ing this st.:opoena molY sHk a court order c:ompeIling you to comply with r_ THIS SL"BPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: DONALD R. DORER, ESQUIRE 214 SENATE AVNEUE, SUITE 503 CAMP HILL PA 17011 TEtEPHOSE: (215) 246-0900 Sl,;PREME COliRT 10 It: ....rrOR.;..E"t. FOR: THE DEFENDANT S....ME: ADDRESS: BY DATE: ~U"IF" / S, .;tf"vo. I S~al of lh~ Court '~:f ;/9-:1 EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DISCOVERY HOUSE 99 SOUTH CAMERON STREET HARRISBURG, PA RE: 19454 JOHN A HAIR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. l Dates Requested: up to and indoding the present. Subject: JOHN A HAIR ' 304 WALL STREET, HUMMELSTOWN, PA 17036 Sodal Security II: 211-58-1720 Date of Birth: 03-24-1964 SU10-310Z5Z :L9454-Loa CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR, HIS WIFE -AUTO TERM, -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER. ESQUIRE certifies that l (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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. MCS on behalf of DATE: 06/12/2001 DONALD R. DORER. ESQUIRE Attorney for DEFENDANT DE12-214261 :L 9 454 - LOg CO~ONWE.ALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF. COURT OF COMMOR PLEAS JOHN A & DEaRA HAIR, HIS WIPE -AUTO TERM, -VS- CASE NO. 99-128 ANDREA L. SINGISER -SINGISER NOTICE OP IN'rBN'r TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS POR DISCOVERY PURSUANT TO RULE 4009.21 [ Note. see enclosed list of locations ] TO. MArTBEV S. CROSBY. ESQUIU KCS on behalf of DONALD R.. DOREll, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) ~ days frOlll the date listed below in which to file of record and serve upon the. undersigned an objection to the subpoena. If the twenty day notice period is waived or if. no objection is made, then the subpoena may be served. Complete.. copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to KCS or by contacting our local KCS office. nATE: 06/12/2001 KCS on behalf of DONALD R. DOREll, ESQUIRE Attorney for DEFEIIDAIlT CC. DONALD R. DOREll, KSQUIU MAII".....vRT DaISCOLL _ 9981-00136 - 58)149111111 Any questions regarding this matter, contact '1'IIB KCS GROUP IRC. 1601 MARKET STREET laoo PHD.ADELPBIA. PA 19103 (215) 246-0900 DE02-lSS610 :L 94- 5 4- - C02 >>> LOCATIO. LIST <<< RECORDS REQUESrm MBDICAL MBDlCAL MBDlCAL HJlDlCAL HJlDlCAL HJlDlCAL onma PAGE. LOCAUO. IIAME rBE 1IE1'UCJ: corn CotH1RI'rY OSftOPA'lIIIC HOSP. PAMILY , IIl'l'EIUIAL HJlDICDlE DISCOvny HOUSE REIIAll OPUOllS DAVID R. BIRCH, D.O. BE1lSBEY HJlDlCAL CE1ITEII. 1 .. - .' ," DE02-1SS610 :L. 9 4S 4 - C02 COMMO/'<"Wl;AL TH OF PENNSYl. VANIA . COUNTY OF CUMBERLA..'.'D JOHN A. & DEBRA HAIR, H!W VS File So. 99-128 ANDREA L. SINGISER SUBPOENA TO PRODUCE DOCUMThtS OR THINGS FOR DISCOVERY PURSUA..l\,t TO RULE 4009 .,., TO: CUSTODIAN OF RECORDS FOR: REHAB OPTIONS PINNACLE HEALTH SYSTEMS' (~..mc of Pl!r"50ft or ~,,\rjry) '^"ithin rwt~. ,~) d~ys Uttr ser~;i(e of tNI subpoena. you ue ordered by the C"OUrt to produce the following: d.ocumenu or 'hin!s: SEE ATTACHED . .. MCS GROUP INC.. 1601 MARKET STREET. SUITE 800, PHILADELPHIA PA 19103- (,'d<lrn') You. molY deih'eT or m.aillepble copies of the documents or produce things requested b~' this subpoen~ teget::e::- with the C'ertl!iC)lf a: cOtnpli.ancr. to the PUTY m.aking this request U the .Jddnss listed above. You h..n"" the right to se-ek. in ~dnJ"lce. the :'!uon.Jble coost of preparins the COpi6 or producing the thinp toU.!ht. II you h,jI Ie ?,=,oduce the documents or things required by this subpoena. """t~n twenty (20) c!.I~'s aiter itS sel"',':cl!. t!-\e ?U1!' sen'in! this St:=poenl m..y sHk a COW't order compelling' ~.ou to comply w;th r_ THIS St-SPOENA WAS ISSUED AT THE REQUEST OFmE FOLLOWING PERSO:>i: DONALD R. DORER. ESQUIRE 214 SENATE AVENUE, SUITE 503 CAMP HILL PA 17011 TEtEPHO~= (215) 246-0900 S1.:PRE.\fE C01.ill.T 10 ., ATrOR.'\E"I' FOR: THE DEFENDANT :\.-\.ME: ADDRESS: DATE: ...........)/~~'l.t: IS' ';),-0/ I B~~U~~ ~ ,,",lh.nOWY~ ivi.... .an..... tl [? rf)~ r-- ;)c, SuI of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: REHAB OPTIONS PINNACLE HEALTH SYSTEMS 17 SOUTH MARKET SQ. HARRISBURG, PA 17033 RE: 19454 JOHN A HAIR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. \. Dates Requested: up to and including the present. Subject: JOHN A HAIR 304 WALL STREET, HUMMELSTOWN, PA 17036 Social Security #: 211-58-1720 Date of Birth: 03-24-1964 5U10-310306 :L9454-L09 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR, HIS WIFE -AUTO TERM, -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE certifies that l (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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. MCS on behalf of DATE: 06/12/2001 DONALD R. DORER. ESQUIRE Attorney for DEFENDANT DE12-2l4262 :L 9 4 54 - L:L 0 COMMONWEALTH OF PENNSYLVANIA COUNTY' OF CUMBERLAND IN THE MATTER OF: COURT OF COMHON PLEAS JOHN A , DERRA HAIR, HIS WIFE -AUTO TERM, -vs- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER NOTICE OF INTEN'r TO SERVE A SUBPOENA TO PRODUCE DOCUHEN'rS AND THINGS FOR DISCOVERY PURSUAIIT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MATTBEV S. CROSBY. ESQUIRE HCS on behalf of DONALD R. DORER, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) . days fr.. the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is .' _ived or if. no objection is made, then the subpoena may be served. COIIIplete- copies of any reproduced records may be ordered at your expense by cOlllpleting the attached counsel card and returning same to HCS or by contacting our local HCS office. DArB: 06/12/2001 HCS on behalf of DONALD ll. DORER, ESQUIRE Attorney for DEl'ENDA!lT ce: DONALD ll. DORER. ESQUlU MAllGAIlB'f DllISCOLL - 9....00136 - ~.l1A.ll.ll Any questions regarding this matter, coot.c. THB HCS GllOUP llIC. 1601 MAllD'f STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-1SS610 :J...94S4-CDZ I >>> LOcATIo. LIST <<< REC01lDS REQUESTED PAGE. 1 LOCATIOK IIAHB HImICAL HImICAL HImICAL HImICAL HImICAL HImICAL OTBKB. TIIJI: IIKftICI: l.UtT.... C~'l'Y OSnOPAT!Il:C HOSP. PAKILY " IIlTERHAL HImICDlI: DISCOVDY HOUSE REHAB OPTIOKS DAVID K. BIKCH. D.O. IIKRSIIKY HImICAL CEIITER . DE02-1SS610 ~ 9 45 4 - C02 COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERL.-\..'m JOHN A. & DEBRA HAIR, H/W VS FiJ~No. 99-128 ANDREA L. SINGISER SUBPOENA TO PRODUCE DOC'tJMEI."TS OR THINGS FOR DISCOVERY PURSUA..J\o"T TO RULE 4009.22 CUSTODIAN OF RECORDS FOR: DAVID R. BIRCH, D.O. TO: (S.lme- of Prnon or Entity) 'y\'~thin ~'e~. (20) d~ys &Iter un'ice ot this subp~'fYoNl'f'~e~ br the court to produce the (ol1owin~ docurents or thangs: __ .t MCS GROUP INC., 1601 MARKET STREEf, SUllE tlUU, ~tlLLAU~L~nLa fa 1~le3 . (,~d<lroo.) You m~y deih'er or m.ai11egible copies of the documents or produce things ~uested by this subpoen~ together with the certifinte a! compHance, to th, puty mwng this request .It the .address liste-d ~bove. You h.a'\'f the right to seek. in .td\'Vlce. the :-!uon.able (ost of preparing the ,opi" or producing the things sought. If you (iii to ?=,oduce the documents Dr things required by this subpoena. witl.....in twenty (20) c!.a~'s aiter its service. the ParT'Y sen'ing this st.::,poen.a mAY seek.. court order compelling you to comply with r_ THIS SLllPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: DONALD R. DORER, ESQUIRE 214 SENATE AVENUE, SUITE 503 CAMP HILL PA 17011 TELEPHO:'\:: (215) 246-0900 SlJPRE....fE COlJRT 10 f: ATIOR."EY FOR: THE DEFENDANT :'\AME: ADDRESS: BY DATE: -..J~~ Is:. ::J.""n I SuI of lh~ Court "=.:f 7/9:1 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DAVID R. BIRCH, D.O. 4445 HIGHWAY 1 REHOBOllI BEACH, DE 19971 RE: 19454 JOHN A HAIR INCLUDING REPORTS Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. l Dates Requested: op to and induding the present. Subject: JOHN A HAIR . 304 WALL STREET, HUMMELSTOWN, PA 17036 Social Secorlty II: 211-58-1720 Date of Birth: 03-24-1964 SU10-310256 ~9454-L~O CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR, HIS WIFE -AUTO TERM, -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, ESQUIRE certifies 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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. MCS on behalf of DATE: 06/12/2001 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DE12-214263 :1. 9 4 5 4 - L:1.:1. CO~ONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JOHN A & DEBRA HAIR, HIS WIFE -AUTO TERM, -VS- CASE NO: 99-128 ANDREA L. SINGISER -SINGISER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: MATTIIEW S. CROSBY, ESQUIRE MCS on behalf of DONALD R. DORER, ESQUIRE 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 the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete- copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/12/2001 MCS on behalf of DONALD R. DORER, ESQUIRE Attorney for DEFENDANT CC: DONALD R. DORER, ESQUIRE HA!l.GARET DRISCOLL - 998.-00136 - 5SHA911S11 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 HARlET STREET 1800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-155610 :1. 9 4.s 4 - C o:z >>> LOCATIOM LIST <<< RECORDS REQUESTED MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL OTIIER PAGE: LOCATIOM JlAMB THE HETRICK: Cl!:IlTl!:Il COHHmlITY OSTEOPATHIC HOSP. FAHILY (, IMTERIIAL MEDICllIE DISCOVE1lY HOUSE REHAB OPTIONS DAVID R. BIRCH. D.O. HERSHEY MEDICAL Cl!:IlTl!:Il DEOZ-155610 1. 9 4- 54- - C 0 :z 1 l ~, COMMO~WEAL TH OF PENNSYLVANIA , COUNTY OF CUMBERL-\...'.'D JOHN A. & DEBRA HAIR, H!W VS File No. 99-128 ANDREA L. SINGISER SUBPOENA TO PRODUCE DOCUMTh"TS OR THI~GS FOR DISCOVERY PURSUA.1'I,"TTO RULE 4009 .,., TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER (!\'..m~ o( P~"on or E:u:iry) I'.'!'hin rwe",,'I~O) d.ys Uter service of ,ltis subP"Sl"E:Yl\'l:fICYfffed by the court to produce the (allowing doc'iments or thlnss: __ ., MCS GROUP INC., 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA 19103 . l....ddrn,. You m~~' dein'!!' or maille-gible copies of the documents or produce things re-q1:lested by this subpoenz. together with the cenifi'oItr of compliance, to the PU"tY mwng this request.1t the ,address listed ..bove. You h.l\" the right to s~ek. in Jd\"ancr. the ~uon..ble CDst of ptrpuing the copies or producing the things sought. l! you (~J te ?,=,OdUCf the documents or things required by this subpoeru" ""';thin twenty (20) C.I"'s uter its service. the party sen'ing this J1:.:,porna m.y seek 01 court order comprHin! ~'ou to comply with r_ THIS St.llPOENA WAS ISSUED ATniE REQt."EST OF THE FOLLOWING PERSON: DONALD R. DORER, ESQUIRE 214 SENATE AVENUE, SUITE 503 CAMP HILL PA 17011 TEtEPHO:\:: (215) 246-0900 SUPREME COURT 10 II: ..s. TIOR.'I;E't' FOR: THE DEFENDANT :\..s.ME: ADDRESS: BY DATE:'-..JJ' ~~ / s.. ::lr,..... I ------ Prothonotary/OCic. Civ' d~ 0 p Z!n~j Seal of the Court ~~f 7/9:1 EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER 500 UNIVERSITY DRIVE HERSHEY, PA 11033 RE: 19454 JOHN A HAIR CERVICAL MRI FILMS OF JUNE 13, 1991 Subject: JOHN A HAIR 304 WALL STREEI'. HUMMELSTOWN. PA 17036 Sodal Security #: 211-58-1720 Date of Birth: 03-24-1'64 5U10-310258 l :L.9454-L:L.:L. >- ("T- is l' c:> , , c.), , 'J 0:, ",. E ~- ::J_ ()-~ (.)3 ::)~ ..~ . Pt/) .:)~ ':::2 iUtu .'" .......~'"- "-::';: :5 (.) "'-- ') c'" ===-J .- ~~ 10. John A. Hair and Debra Hair, his wife IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V Andrea L. Singiser NO. 99-128 CIVIL TERM ORDER OF COURT AND NOW, August 14,2001, the above.captioned matter is continued by agreement of counsel, from the September 10,2001 trial term, at the plaintiffs request. Counsel is directed to relist the case when ready. By the Court, Goofdl1MYl Matthew S, Crosby, Esquire For the Plaintiff Donald R. Dorer, Esquire For the Defendant c..o 'f \<c..S lY\o..~\Gd '8-\5-01 Vii'.'V/ilASNN:'d AlNnOJ C":'::'l~::a~n:::J Court Administrator Z'J :5 Iltt S I :JrlV 10 :bb ^~/lC(;:.:>-_~I,..iJ ~:.~.:. :;0 301~:'Q' 03l:J ~ ::: r--- <~ = 00 ~~~ ~~~ :::(/)<a~~i: t::~:...:LO.Q.l":'r-- o :Ii ~;: ~~r:- ;;.. == 7.:; =__ ~C~"-l=~C ~~~ ~C;;.: ~N ..-r. c~ U - ,-- HM"911lLO' AD-S'ilLO 'liU9ILG. ,jB-~~LO "ON WlilC)j ~I 'WNOUVNlBiNI .ll'o'lS-lW JO N01$lAIO V '1\tD31 UV1S-1,.... ~ ,;,., ~ File No.: 99HB-OOl36 PRAECIPE FOR RE-LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate.) ., .- ~ TO THE PROTIIONOTARY OF CUMBERLAND COUNTY: Please list the following case (check one): ( x) for JURY trial at the next term of civil court. ( ) for trial without a jury. CAPTION OF CASE: (Entire Caption Must Be Stated In Full) (Check One) ( ) Assumpsit John A. Hair and Debra Hair, his wife, ( ) Trespass Plaintiffs (x) Trespass (Motor Vehicle) vs. ( ) (Other) Andrea L. Singiser, Defendant The trial list will be called on April 2. 2002 Trials commence on April 29. 2002 Pre-trials will be held on April 10. 2002 (Briefs are due S days before pre-trials.) (The party listing this case for trial shall provide forthwith. copy of the praecipe to aU counsel, pursuant to local Rule 214-1.) No. 99-128 Civil_ 19 99 Indicate the attorney who will try case for the party who files this praecipe: Donald R. Dorer. E<louire. Attornev for Defendant: Jacobs & Saba. 214 Senate Avenue. Suite 503. Camp Hill. Pennsylvania. 17011: (717\ 731-0988. Indicate trial counsel for other parties if known: Matthew S. Crosh Attorne for Plaintiffs' Handle Hennin & Rosenber 1300 Lin lestown Road P.O. Box 1177 Harrishur PA 17108' 717 238-2000 I ~:gdl~dR' ~k;re Attorney for: Defendant. Andrea L. Singiser This case is ready for trial. Date: January 31. 2002 99HB-00136 ;, .. LAW OFFICES OF .JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendant, Andrea L. Sin iser JOHN A. HAIR AND DEBRA HAIR, HIS WIFE, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA VS. No. 99-128 CIVIL TERM ANDREA L. SINGISER, DEFENDANT CIVIL ACTION - LAw .JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecipe for Re-Listing Case for Trial to be served by regular first class mail upon: Matthew S. Crosby, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road, P.O. Box 1177 Harrisburg, PA 17108 Donald R. Dorer, Esquire Attorney for Defendant Date: Januarv 31. 2002 >- ~.. J~'-- LUq C )~'- n: ~J._ (~~:~ -':,,,- li.!.;.. Li..:''-,l -~ ;-. ,,- o ~ a:l C N ~ :J< '=:>--- >'2; ~~'- . :> i;-:1S;:! ~. ;'" (f) 2lz: G.l ?6 OJ a... ';.:; ~ <.) ....- ,. ~ I en lw '-'- '" = ~ . L ~ ," ?:~ 1,>..... V'~ ~'i ~- <.) -'.~ "'.;;; ~.,~~ ~_ ":1 ~ ~'-;; ., :--':J ~ . ')-- C) ) V2 N ..,.- ij l~Ll ~.:,; 1':l CL ::.:i: .. , , '" :::5 .) C:J <.;) ~ <~ =: ~ ~~~ !:;gg~ ~tI'J<a~~"':' :::~~lfl.Q.j"':'~ ~~~t:f~~ ~CQ~;;.;--- <o~cn=!:;C ~~~ ~C:.< """,- < ~ '" U '"' _. HM-9!lllO' A!l~S~LO' lil-f:SILO' oJlI-tII(LO "ON WYO~ ';)NI 'l"'N01~"'NllllNl .u'f'i$-Tl't':IO NOISlIUO'" 'lvtl3:1ll....LS.T1Y '- ~'- .99HB-09136 ~ ..... ... JOHN A. HAIR AND DEBRA HAIR, HIS WIFE, PLAINTIFFS IN DIE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 99-128 CIVIL TERM ANDREA L. SINGISER, DEFENDANT CIVIL ACTION - LAW .JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTIIONOTARY: Please mark the above-captioned case settled, discontinued and ended. By: Matthew S. Crosby, Esquire Handler, Henning & Rosenberg 1300 LinglestownRoad, P.O. Box 1177 Harrisburg, PA 17108 Attorney I.D.# Attorney for Plaintiffs Date: 51 n Joz. . 99HB-Q0136 i' ~, t;-< LAW OFFICES OF .JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Numher: (717) 731-0988 Attorne s for Defendant, Andrea L. Sin iser JOHN A. HAIR AND DEBRA HAIR, HIS WIFE, PLAINTIFFS IN THE COURT OF COMMON PLEAS CmffiERLAND COUNTY, PENNSYLVANIA YS. No..99-128 CIVIL TERM ANDREA L. SINGISER, DEFENDANT CIVIL ACTION - LAw .JURY TRIAL DEMANDED CERTIFICATE OF SERYICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecioe to Settle. Discontinue and End to be served by regular first class mail upon: Matthew S. Crosby, Esquire Handler, Henning & Rosenberg 1300 LinglestownRoad, P.O. Box 1177 Harrisburg, PA 17108 Date: Mav 17. 2002 Donald R. Dorer, Esquire Attorney for Defendant >- '-.D ~ a; N ~ ('~ ~~~< lUG I....h.;,.- L2c:') -- U"'";.o ,,-~ a.. ::::: Cir:, (")"':j 6;; <::> :<~ N ..'):;;;!: u..:<..-l-. 11::;"= ~lll ~- ullU :".I-:r..: ~- 11:1('_ i-- ::.: ...,-~ 1.1. N ::> 0 <::> () . 1~_