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Home My WebLink About99-04014 Is eJ .o GRANT C. PATTISON, Plaintil7' V. CLARENCE S. DeWALT, Defendant IN TT-IE COURT OF COMMON PLF,AS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 -W40/y ???i `[EJLI?I CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Kindly issue a Writ of Summons in the above-referenced matter and have it served by the Sheriff upon the Defendant at the following address: Clarence S. DeWalt One Ridge Drive Carlisle, PA 17013 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Jered L. Hock, Esquire I. D. No. 19211 3211 North Front Street P.O. Box 5300 Harrisburg, PA ! 7110-0300 (717) 238-8187 Attorneys for Plaintiff Date: June Z7 , 1999 Oxurneni N: 155843.1 1 ` ? ^V ` L ? J ' ? ^ I .. ? ?V // N 7 ^? _ ? ? ?? i T _ ??? ? ?G? T. _ i Y. i S _ _ _ _ n ? C l q` `1 - fi _' IJ _ ?? GRANT C. PATTISON, IN T IE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 .- CIVIL (?! ui L?lLh? CIVIL ACTION - LAW CLARENCE S. DeWALT, Defendant JURY TRIAL DEMANDED WRIT OF SUMMONS TO: Clarence S. De Walt One Ridge Drive Carlisle, PA 17013 You are hereby notified that the above-named Plaintiff, Grant C. Pattison, has commenced an action against you. 'Prothonotary Date: JUur- 20 /991 Seal of the Court Deputy Document4 !55843./ SHERIFF'S RETURN - REGULAR CASE NO: 1999-04014 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PATTISON GRANT C VS. DEWALT CLARENCE S CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon DEWALT CLARENCE S the defendant, at 12:05 HOURS, on the 2nd day of July 1999 at 1 RIDGE DRIVE CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to CLARENCE S. DEWALT a true and attested copy of the WRIT OF SUMMONS and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 4.34 Affidavit .00 Surcharge 8.00 $$ MI mafislne, 5 eri ioz DOETZG/R. ICKERSHAM by p y er Sworn and subscribed to before me this O t' day of 19 \99/11 A.D.//' ,17 rocnonotar GRANT C. PATTISON, Plaintiff V. CLARENCE S. DeWALT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4014 CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Girard E. Rickards, Esquire, of the firm of Wix, Wenger & Weidner, on behalf of Defendant Clarence S. DeWalt in the above-captioned matter. WIX, WENGER & WEIDNER By l!/?/ / ?C-r?C Girard E. Rickards, I.D. #58867 Attorneys for Defendant 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 Dated: November 15, 1999 AIJD . -61i5 tA( L5 I r? l o ae epvY Gk t I r loci4t?)-p? 1q'K' k WA a & I?C_. uk , 16 1? w ° z m Q o 0 wsw^ ? ? z N w1 < < W N pm ? J N ^/ N W K 1 z U ? z O ° h s W ? r N X a _ x IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION GRANT C. PATTISON, Plaintiff V. File No. 99-4014 Civil CLARENCE S. DeWALT, Defendant PRAECIPE AND RULE TO FILE x A COMPLAINT A BILL OF PARTICULARS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue rule on Plaintiff to file a Complaint in the above case within twenty days after service, of the rule or suffer a judgement of non pros. DATE: Nov. 15. 1999 Signature: Print Name. Girard E. Rickards Attorney for: Defendant Address: 4705 Duke Street Telephone No: (717) 652-8455 Supreme Court ID No.: 58867 NOW, Jwt_"4/t_ a , 19 of (NOTE: Fi in duplicate) By: PROTHON.-12 ?, .. ,,t ;. ; .? _ vN ?? ,S C ? h?1 GRANT C. PATTISON, IN THE COURT OF COMMON PLEAS Plaintiff' CUMBERLAND COUNTY. PENNSYLVANIA V. NO. 99-4014 Civil CIVIL ACTION-LAW CLARENCE S. De WALT, Defendant JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717- 249-3166 800-990-9108 Document # 166394 GRANT C. PATTISON, Plaintiff V. CLARENCE S. DeWALT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4014 Civil CIVIL ACTION - LAW JURY TRIAL DEMANDED AVISO USTED IJA SIDO DEMANDADO/EN LA COUTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las paginas, debe tomar accion dentro de los proximos viente (20) dias despues de la notification de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriortnente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamation o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u ostros derechos importantes pars usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABODAGO 1MMEDIATAMENTE. SI LISTED NO TIENE UN ABODGADO O NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 Ihicumem a 166394 GRANT C. PATTISON, IN THE COURT OI' COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-4014 Civil CLARENCE S. DeWALT, CIVIL ACTION ?.AW Defendant JURY TRIAL DEMANDED COMPLAINT AND NOW comes Plaintiff, Grant C. Pattison, by his attorneys, Metzger, Wickersham, Knauss & Erb, P.C., and makes complaint against Defendant as follows: Plaintiff, Grant C. Pattison, is an adult individual residing at 325 Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania 17013. Defendant, Clarence S. De Walt, is an adult individual residing at One Ridge Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. On or about August 8, 1997, at or about 5 p.m., the Plaintiff was the equitable owner and operatorof a 1988 Cadillac Sedan, bearing Pennsylvania registration number AYA0584. 4. On the aforesaid date and time, the Defendant was the owner and operator ofa 1992 GMC pickup, bearing Pennsylvania registration number CE25957. 5. On the aforesaid date and time, the Plaintiff was lawfully operating his vehicle on Claremont Drive, travelling westbound. 6. At the intersection of Claremont Drive and Harmony Hall Drive, the Plaintiffs vehicle was struck on the right front by the vehicle being driven by the Defendant, causing injuries and damages to the Plaintiff. IA1aunwu a 166394 7. The accident was caused directly, proximately, and substantially by the negligence of the Defendant in the following particulars: (a) Failing to keep alert and maintain a proper lookout while operating his vehicle; (b) Failing to observe the Plaintiffs vehicle as it was travelling lawfully on Claremont Drive; (c) Failing to yield preferential right-of-wayat an intersection at which he was at stop sign, in violation of 75 Pa. C.S.A. §3323(a)(b); (d) Failing to yield right-of-way to traffic on a through highway, in violation of 75 Pa. C.S.A. §3321(b)(1); (e) Turning a vehicle on a roadway under conditions that were not reasonably safe to do so, in violation of 75 Pa. C.S.A. §3334(e). (f) Operating his vehicle in careless disregard for the safety of others, and the Plaintiff in particular, in violation of 75 Pa. C.S.A. §3714. (g) Proceeding in disregard of hazards then and there existing, including particularly hazards to Plaintiff. g. As a proximate result of the Defendant's violation of the Pennsylvania Vehicle Code, the Defendant is negligent per se. 9. As a result of the aforesaid accident and negligence of the Defendant, the Plaintiff has suffered serious injuries, including but not limited to, injuries to his back, neck, head, shoulder region, joints and muscles, as well as suffering from neck and thoracic pain, sprain and strain, persistent headaches and migraine headaches, neck pain extending to the shoulder blades, limitations in the range of motion of the neck, and spasms, all of which have required extensive treatment, including medical appointments, medical tests, physical therapy and medications, and claim is made therefor. DOCUMcnl# 166394 10. As a result of the aforesaid accident and negligence of the Defendant, the Plaintiff was forced to incur medical bills and expenses for the injuries he has suffered and will continue to incur medical bills and expenses in the future and a claim is made therefor. 11. As a result of the aforesaid collision and negligence of the Defendant, the Plaintiff suffered a loss of ability to perform his usual activities, as well as productivity, and a claim is made therefor. 12. As a result of the aforesaid accident and negligence of the Defendant, the Plaintiff has undergone and in the future will undergo great mental and physical pain and suffering, mental anguish, discomfort, loss of sleep, difficulty in concentration, inconvenience and distress, embarrassment and humiliation, past, present and future loss of his ability to enjoy the pleasures of life and limitations in his pursuit of daily activities, all to his great loss and detriment and claim is made therefor. 13. As a result of the aforesaid accident and negligence of the Defendant, the Plaintiff has also suffered incidental costs and expenses, including medication. 14. As a direct and proximate result of the negligence of the Defendant, Plaintiff's vehicle was damaged in the amount of Three Thousand Eight Hundred Twenty-One Dollars and Seventy-Two Cents ($3,821.72), for which Plaintiff was obligated to make payment in respect to the vehicle, of which he was the real party in interest. In addition, Plaintiff was forced to incur expenses for a damage waiver or similar waiver on a rental vehicle at a cost of One Hundred Seventy-Two Dollars and Forty=Two Cents ($172.42), for which Plaintiff was obligated to make payment as aforesaid. In addition, Plaintiff was obligated to obtain a rental vehicle for which charges were made and for which claim is made herein. Document# 166394 15. As a direct and proximate result of the negligence, carelessness and recklessness of the Defendant, the Plaintiff has sustained and in the future will sustain wage loss as the result of his inability to work. 16. Plaintiff is covered by the full tort option. WHEREFORE, the Plaintiff, Grant C. Pattison, demands judgment against Defendant, Clarence S. DeWalt, for damages in an amount in excess of Twenty-Five Thousand Dollars ($25,000), plus interest, costs, and such other relief as this I lonorable Court may deem appropriate. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: ? Jere lock, Esquire I.D. No. 19211 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717)238-8187 Attorneys for Plaintiff Date: January 17, 2000 Document a 166394 CERTIFICATE OF SERVICE AND NOW, this 17°i day of January, 2000, 1, Jered L. Hock, of Metzger, Wickersham, Knauss & Erb, P.C., attorneys for Plaintiff, hereby certify that I served the foregoing Complaint this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressedto: Girard E. Rickards, Esquire WIX, WENGER & WEIDNER 4705 Duke Street Harrisburg. PA 17109-3099 By: Jered L. Hock, Esquire Document# 166394 ai •i - u c? - r ItL f. 7 7 r _ Sm _' u 'i GRANT C. PATTISON, Plaintiff V. CLARENCE S. DeWALT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4014 CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Grant C. Pattison c/o Jered L. Hock, Esquire METZGER WICKERSHAM 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 YOU ARE HEREBY NOTIFIED to plead to the enclosed New Matter within twenty (20) days from service hereof or a default judgment will be entered against you. DATE: \- a`-0 O BY: Respectfully submitted, WIX, WENGE?,fi WEIDNER hard E. Ri ar -s , Esquire ID# 58867 4705 Duke Street Harrisburg, PA 17109 (717) 652-8455 GRANT C. PATTISON, Plaintiff V. CLARENCE S. DeWALT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4014 CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER TO THE PLAINTIFF'S COMPLAINT 1. Admitted. 2. Admitted. 3. Admitted in part, denied in part. Admitted that on or about August 8, 1997, at about 5:00 p.m., the Plaintiff was the operator of a 1988 Cadillac Sedan, Pennsylvania registration AYA0584. The remaining averments of Paragraph 3 are specifically denied. To the contrary, the Defendant believes and therefore avers that the owners of the vehicle being driven by the Plaintiff, on the day of the accident, are Donald and Joan B. Pattison. 4. Admitted. 5. Admitted in part, denied in part. Admitted that on the aforesaid date and time, the Plaintiff was operating his vehicle on Claremont Drive, traveling westbound. After reasonable investigation, Defendant is without sufficient knowledge to form a belief as to the truth of the remaining averments of Paragraph 5. Therefore, the remaining averments of Paragraph 5 are specifically denied and strict proof thereof is demanded at the time of trial. 6. Admitted in part, denied in part. Admitted that at the intersection of Claremont Drive and Harmony Hall Drive a collision occurred between the Plaintiff's and Defendant's vehicles. The remaining averments of Paragraph 6 are specifically denied and strict proof thereof is demanded at the time of trial. To the contrary, the Plaintiff's vehicle struck the Defendant's vehicle. 7. The averments of Paragraph 7 constitute a conclusion of law to which no response is required. To the extent that a response is deemed required, each and every averment of Paragraph 7 is specifically denied and strict proof thereof is demanded at the time of trial. 8. The averments of Paragraph 8 constitute a conclusion of law to which no response is required. To the extent that a response is deemed required, each and every averment of Paragraph 8 is specifically denied and strict proof thereof is demanded at the time of trial. 9. After reasonable investigation, Defendant is without sufficient knowledge to form a belief as to the truth of the averments of Paragraph 9. Therefore, each and every averment of Paragraph 9 is specifically denied and strict proof thereof is demanded at the time of trial. 10. After reasonable investigation, Defendant is without sufficient knowledge to form a belief as to the truth of the 2 averments of Paragraph 10. Therefore, each and every averment of Paragraph 10 is specifically denied and strict proof thereof is demanded at the time of trial. 11. After reasonable investigation, Defendant is without sufficient knowledge to form a belief as to the truth of the averments of Paragraph 11. Therefore, each and every averment of Paragraph 11 is specifically denied and strict proof thereof is demanded at the time of trial. 12. After reasonable investigation, Defendant is without sufficient knowledge to form a belief as to the truth of the averments of Paragraph 12. Therefore, each and every averment of Paragraph 12 is specifically denied and strict proof thereof is demanded at the time of trial. 13. After reasonable investigation, Defendant is without sufficient knowledge to form a belief as to the truth of the averments of Paragraph 13. Therefore, each and every averment of Paragraph 13 is specifically denied and strict proof thereof is demanded at the time of trial. 14. After reasonable investigation, Defendant is without sufficient knowledge to form a belief az to the truth of the averments of Paragraph 14. Therefore, each and every averment of Paragraph 14 is specifically denied and strict proof thereof is demanded at the time of trial. 3 15. After reasonable investigation, Defendant is without sufficient knowledge to form a belief as to the truth of the averments of Paragraph 15. Therefore, each and every averment of Paragraph 15 is specifically denied and strict proof thereof is demanded at the time of trial. 16. After reasonable investigation, Defendant is without sufficient knowledge to form a belief as to the truth of the averments of Paragraph 16. Therefore, each and every averment of Paragraph 16 is specifically denied and strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Clarence S. DeWalt, respectfully requests Your Honorable Court to dismiss the Plaintiff's Complaint with prejudice. NEW MATTER 17. The Defendant's Agents have already paid the Plaintiff the sum of Three Thousand Seven Hundred Fifty-Nine and 61/100 ($3,759.61) Dollars, representing the damage done to the vehicle involved in the accident and a reasonable allowance for a rental vehicle. 18. The Plaintiff's claims for damages to the vehicle and any incidental expenses arising therefrom are barred by the doctrine of accord and satisfaction. 19. The Plaintiff's claims for non-pecuniary damages may be 4 barred pursuant to the limited tort option of the Pennsylvania Motor Vehicle Financial Responsibility Act. 20. The Plaintiff's claims for medical expenses and/or wage loss are barred, or should be reduced in accordance with § 1722 of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, Defendant, Clarence S. DeWalt, respectfully requests Your Honorable Court to dismiss the Plaintiff's Complaint with prejudice. Respectfully submitted, WIX, WENGER & WEIDNER B Girard E. Rickards, I. . No. 58867 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 5 VERIFICATION I, Clarence S. DeWalt, have read the foregoing Answer With New Matter which has been drafted by my counsel. The factual statements and/or denials contained therein are true and correct to the best of my knowledge, information and belief. I am authorized to make this verification. This verification is made only as to the factual averments contained therein and not to legal conclusions and averments authorized by counsel in his capacity as attorney for the party or parties hereto. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities which provides that, if I knowingly made false averments, I may be subject to criminal penalties. Clarence S. DeWalt CERTIFICATE OF SERVICE AND NOW, this 28th day of January, 2000, I, Girard E. Rickards, Esquire, of the firm of Wix, Wenger & Weidner, hereby certify that I have served a copy of Defendants Answer With New Matter to Plaintiff's complaint on this date, by depositing a copy of the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania addressed as follows: Jered L. Hock, Esquire METZGER WICKERSHAM 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 WIX,?Wff G R & WEIDNER i' By: -- G rd E. J. ckards, Esquire -Ir IDO 58867 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 i } W ? z 0 0 W,w f W ?r?z NN f f H ? z LIJ W ¢ ? ? W m ? X a x GRANT C. PATTISON, Plaintiff V. CLARENCE S. DeWALT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4014 CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that: (1) a notice of intent to serve the subpoenas with a copy of the subpoenas attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoenas are sought to be served, (2) a copy of the notice of intent, including the proposed subpoenas, are attached to this certificate, (3) no objection to the subpoenas has been received, and (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. WIX, WENGER & WE DNERR --Girard E. Rickards, Esquire I.D. No. 58867 Attorney for Defendant 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 Date: April 14, 2000 GRANT C. PATTISON, Plaintiff V. CLARENCE S. DeWALT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4014 CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Jered L. Hock, Esquire, Attorney for Plaintiff 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 Defendant, Clarence S. DeWalt, intends to serve subpoenas identical to the ones that are 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 subpoenas. If no objection is made, the subpoenas will be served. Date: 3-a4- r,o card E. Rickards, Esquire I. D. No. 58867 Attorney for Defendant 4705 Duke Street Harrisburg, PA 17109-3099 (717) 652-8455 OOt^IONATALTH OF P&M'SYLVANIA CXWrY OF CUK3ERL*0 GRANT C: PATTISON,. Plaintiff V: File No. 99-4014 CLARENCE S. DeWALT, Defendant SUBPOENA TO PRODUCE DOCU-ENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Hospital, 246 Parker St., Carlisle, PA 17013 (NaTr_ of Person or Entity) ?- Within twenty (20) days after service of this subpoena, you are ordered by the court to Produce the following doa? ts or things: All medical records, notes correspondence and other materials relating to Plaintiff, C. Pattison. an at Wix, Wenger_ &Weidner, 4705 Duke Street, Harrisburg, PA 17109 (Addres?) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of e the reasonable arrpliance, to the party making this request re the address listed above. You have the right to seek in advanc cost of preparing the mpies or producing the things sought. If you fail to produce the docments or th;rgs required by this subpoena within twenty (20) days after its service, the Party serving this subpoena may seek a court -x-der compelling you to ocply wit_1 it. THIS SUBPOENA WAS ISSU-D AT THE REOfST OF THE FCLLONIN3 PERSON: NAME: Girard E. Rickards, Esquire ADDRESS: 4705 Duke Street Harrisburg, pA 17109 TELEPHONE:-A717) 652-8455 SLPREvE COURT ID # 58867 ATTORNEY FOR: Defendant DATE: a?I?LU_ Seal of the Court (Eff. 7/97) GRANT C. PATTISON' '. Plaintiff V;* CLARENCE S. DeWALT, Defendant File No. 99-4014 SUBPOENA TO PRODUCE DOCLjMENTS OR THIN FO7 DISODVERY PURSUANT TO RULE 4009.22 TO: 0&-re of Person or Entity) ??Ivy., Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docents or things: All medical records, notes cor_resoondencg and other materi_ als relating to lain i an C. Pattison. at Wix, Wenger 6 Weidner_ 4705 Duke Street, Harrisburg, PA 17109 (Address) -" You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together, with the certificate of ccrrpliance, 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 codes or producing the things sought. If you fail to produce the docurents or th;rgs required by this subpoena within twenty (20) days you its service, the party serving this subpoena may seek a court order ccrrpelling corrply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Girard E. Rickards, Esquire ADDRESS: 4705 Duke Street _ Harrisbura, PA 17109 TELEPHDNE:_17171 652-8455 SUPREME COURT ID # 58867 ATTORNEY FOR: Defendant DATE: ?/` r nLL_ Seal of the Court --r--I ODFSONn'FALTH OF PENNSYLVANL4 ZUNI Y OF Cl1rffiFRLAAID (Eff. 7/97) GRANT C: PA.TTISON,, Plaintiff V, CLARENCE S. DeWALT, Defendant File No. 99-4014 SUBPOENA TO PRODUCE DOMMNTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 TO: Penn's Wood Physical Therapy, 425 Ston (Nam of Person or Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docu;?ents or things: All medical records, notes, corresoondenra a„a ' ?.. rattison. at Wix, Wenger`ner, 4705 Duke Street, Harrisburg, PA 17109 (Addres?) You may deliver or mail legible copies of the docunents or produce things requested by this subpoena, together with the certificate of carpliance, 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 docu-,ents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order ca*pelling you to cc ply wit,,i it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLONING PERSON: NAME: Girard E. Rickards, Esquire ADDRESS: 4705 Duke Street _ Harrisburg, PA 17109 TELEPHONE:-(,717) 652-8455 SUPREME COURT ID q 58867 __ ATTORNEY FOR: Defendant DATE: Seal of the Court OODM hNTALTH OF PENNSYLVANIA OXWrY OF OJKBERIAND (Eff. 7/97) M OJKMDNWFALTH OF PENNSYLVANIA COUNPY OF 01MERLAND GRANT C: PATTISON,. .. .. .Plaintiff , ... ...... ... ... .. . V• File No. 99-4014 CLARENCE S. DeWALT, Defendant SUBPOENA TO PRODUCE DOal-ENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: n Street. Ca of Person or Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doarents or things: All medical records, notes, eoKX-esoondencg and other materials relating to laint;ff C. Pattison. --?- Gran at & Weidner, 4705 Duke Street, Harrisburg, PA (Addres-) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of co7pliance, 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 &ci ents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to caply witl it. THIS SUBPOENA WAS ISSUED AT THE REST OF THE FCLLOYING PERSON: NAME: Girard E. Rickards, Esquire ADDRESS: 4705 Duke Street _ Harrisburv, PA 17109 TELEPHONE:_(717) 652-8455 SUPREME OOU3T ID tl 58867 __ ATTORNEY FOR: Defendant DATE: 1"a ' 1C? Seal o the urt (Eff. 1/97) CO" MNWFALTN OF PE^4.SYLVANn COUNIY OF CUMBE RIAND GRANT C: PATTISON;. Plaintiff V:, File No. 99-4014 CLARENCE S. DeWALT, Defendant SUBPOENA TO PRODUCE DOCU ENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Philip A. Neiderer, D. .a nres li Suite 109 Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doaments or things: All medical records, notes cgrresDOndence and other materials relating to Plaintiff Cr C. Pattison. at Wi & weidner_ 4705 Duke Street 9 (Addres?) You may deliver or mail legible copies of the doaments or produce things requested by this subpoena, together with the certificate of crmpliance, 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 dxvnents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order corpelling you to oorply witn it. THIS SUSPOENA WAS ISSUED AT THE REQUEST OF IHE FOLLOWIIJu PERSON: NAME: Girard E. Rickards, Esquire ADDRESS:4705 Duke Street -Harrisburg, 17109 TELEPHONE:_J7_17)6455 SUPREME COURT ID {) 588588- 867 - _ ATTORNEY FOR: Defendant DATE: n?L ?? Seal of the Court (Eff. 7/97) ?? ; - , _> . :, GRAN'I' C. PATTISON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-4014 CIVIL CIVIL ACTION- LAW CLARENCES. DeWALT, Defendant JURY TRIAL DEMANDED PRAECIPE FOR DISCONTINUANCE TO THE PROTHONOTARY: Please mark the above case settled, discontinued, and ended. METZGER, WICKERSHAM,KNAUSS & ERB, P.C. By: _ v V Jered L. Hock, Esquire I.D. No. 19211 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Date: February ?' 2001 Moment M: 197951.1 i 4 ? C•_ ::. i ` _; - :r i. ? '-. _• ti?? [p ??1J 1tL _? J