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HomeMy WebLinkAbout99-04023 0 L I 1 ci a 1 i 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ANDREA M. HOCH, Plaintiff 601 Landsvale Street Marysville, PA 17053 V. No. 7 7 ?? 33 DENNIS G. BARBAGELLO 6134 Charing Cross Mechanicsburg, PA 17055 NOTICE TO: DEFENDANT NAMED HEREIN: 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 defense 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 importance 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. COURT ADMINISTRATOR 4TH Floor, Cumberland County Courthouse Carlisle, PA 17013 Telephone: (717) 240-6200 GLEA?SON & BAARRBIN, P.C. BR . B SQUIRE Atty. I.D. #36908 EDWARD P. SEEBER, ESQUIRE Atty. I.D. #76084 123 State Street Harrisburg, PA 17101 (717) 232-9200 Attorneys for Plaintiff, Andrea M. Hoch IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ANDREA M. HOCH, Plaintiff 601 Landsvale Street Marysville, PA 17053 V. DENNIS G. BARBAGELLO 6134 Charing Cross Mechanicsburg, PA 17055 COMPLAINT No. 99. q623 &.;-e T. 1. Plaintiff, Andrea M. Hoch, hereinafter "Plaintiff," is an adult individual residing at 601 Landsvale Street, Marysville, Perry County, Pennsylvania. 2. Defendant, Dennis G. Barbagello, hereinafter "Defendant," is an adult individual residing at 6134 Charing Cross, Mechanicsburg, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or about July 3, 1997, at approximately 4:00 p.m. on the Carlisle Pike, Cumberland County, Pennsylvania. 4. At that time and place, Plaintiff was operating her motor vehicle, a 1995 Toyota Celica GTS, in a westerly direction on the Carlisle Pike. 5. At that time and place, Plaintiff was stopped for a red light while in the west bound lane at approximately the 4400 hundred block of the Carlisle Pike. 6. At that time and place, Defendant was operating his motor vehicle and was traveling in the west bound lane of the Carlisle Pike. 7. At that time and place, as the traffic signal turned green, Defendant's vehicle struck the rear portion of Plaintiff's vehicle while Plaintiff was still stopped for the traffic light. 12. Because of the nature of her injuries, Plaintiff has been advised and, therefore, avers that she may be forced to incur similar expenses in the future and claims made therefor. 13. Plaintiffs accident-related medical expenses exceed Fifteen Thousand Dollars ($15,000.00) and claim is made for all expenses incurred above $15,000.00. 14. As a result of the aforementioned accident and injuries, Plaintiff has undergone neck surgery for her herniated disk after receiving extensive physical therapy and in the future will undergo great physical and mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment and claim is made therefor. 15. As a result of the aforementioned accident and injuries, Plaintiff has been and in the future will be subject to great humiliation and embarrassment and claim is made therefor. 16. As a result of the aforementioned accident and injuries, Plaintiff has sustained work loss, loss of opportunity and permanent diminution of her earning power and capacity and claim is made therefor. 17. As a result of the aforementioned accident and injuries, Plaintiff has sustained uncompensated work loss and claim in made therefor. l8. As a result of the aforementioned accident and injuries, Plaintiff continues to be plagued by persistent pain and limitation and therefore avers that her injuries may be of a permanent nature causing residual problems for the remainder of her lifetime and claim is made therefor. 19. As a result of the aforementioned accident and injuries, Plaintiff has sustained scars which will result in permanent disfigurement and claim is made therefor. WHEREFORE, Plaintiff demands judgment against Defendant in an amount in excess of TWENTY-FIVE THOUSAND DOLLARS ($25,000.00), exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsive arbitration. 3 GLEASON & BARBIN, P.C. BRY B N, QUIRE A . I.D. #369 8 EDWARD P. SEEBER, ESQUIRE Atty. I.D. #76084 123 State Street Harrisburg, PA 17101 (717) 232-9200 Attorneys for Plaintiff, Andrea M. Hoch I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ANDREA M. HOCH, Plaintiff 601 Landsvale Street Marysville, PA 17053 V. No. DENNIS G. BARBAGELLO 6134 Charing Cross Mechanicsburg, PA 17055 VERIFICATION 1, ANDREA M. HOCH, verify that the statements made in the foregoing COMPLAINT are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4914 relating to unswom falsification to authorities. C, ANDREA M. HOCH DATED: q3O pj _? J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANDREA M. HOCH, Plaintiff NO. 99-4023 V. DENNIS G. BARBAGELLO, Defendant PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of George H. Eager of the Law Firm of Eager, Reinaker & Spinello as attorney of record on behalf of Defendant Dennis G. Barbagello, in the above captioned action. EAGER, REINAKER & SPINELLO BY: Z--? Z- i George H. Eage Esquire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for Entry of Appearance upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Bryan E. Barbin, Esquire Edward P. Seeber, Esquire Gleason & Barbin, P.C. 123 State Street Harrisburg, PA 17101 DATE: ojn MT EAGER, REINAKER & SPINELLO BY: F //l George H. Eag Esquire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 11 C??- ' r U n 4 c as p??,,.+ a t 1 . W ll Li:? F' ? ^? d (wf]? Z 1? ccm, SHERIFF'S RETURN - REGULAR CASE NO: 1999-04023 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ANDREA M VS. BARBAGELLO DENNIS G BRIAN BARRICK , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT was served upon BARBAGELLO DENNIS G the defendant, at 14:26 HOURS, on the 1st day of July 1999 at 6134 CHARING CROSS MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to DENNIS G. BARBAGELLO a true and attested copy of the NOTICE AND COMPLAINT and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 6.20 Affidavit .00 Surcharge 8.00 R-T o ine, P rc' $32.20-GL$ASON & BARBIN 07/02/1999 by /?J /sue' epu y 5 erhiFf- Sworn and subscribe to before me this day of 19? A. D. ??- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANDREA M. HOCH, Plaintiff V. DENNIS G. BARBAGELLO, Defendant NO. 99-4023 ANSWER AND NOW COMES DEFENDANT, BY AND THROUGH HIS ATTORNEY, GEORGE H. EAGER, AND FILES THE FOLLOWING ANSWER: 1.- 19. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). WHEREFORE, Defendant asks that judgment be entered in his favor and against Plaintiff on all claims set forth in Plaintiff's Complaint. EAGER, REINAKER & SPINELLO BY : l/ Georg Eage Esquire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 VERIFICATION I, DENNIS G. BARBAGELLO, hereby verify that I am the Defendant in the foregoing action, and that the averments of the foregoing Answers to Plaintiff's Complaint are true and correct to the best of my knowledge, information and belief. To the extent that any of the averments of the Answers to the Complaint are based upon an understanding or application of law, I have relied upon counsel in making this Verification. I understand that I am subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities for any false state herein. .7-L?- D Qv(to ZL ENNIS G. BARBAGE LO Dated: CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Answer upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Bryan E. Barbin, Esquire Edward P. Seeber, Esquire Gleason & Barbin, P.C. 1.23 State Street Harrisburg, PA 17101 DATE: r/-),-/-99 EAGER, REINAKER & SPINELLO BY• J =? !2? George H. Eage Esquire Attorney for Defendant I.D. No. 27740 13,17 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 a C LNJ L L . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANDREA M. HOCH, Plaintiff V. DENNIS G. BARBAGELLO, Defendant NO. 99-4023 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of Defendant's Request for Production and Copying of Documents - Set No. 1 Directed to Plaintiff upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Bryan E. Barbin, Esquire Edward P. Seeber, Esquire Gleason & Barbin, P.C. 123 State Street Harrisburg, PA 17101 EAGER, REINAKER & SPINELLO DATE: -7-14-89 BY: George H. Eager squire Attorney for endant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANDREA M. HOCH, Plaintiff NO. 99-4023 V. DENNIS G. BARBAGELLO, Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served an original of Interrogatories of Defendant Addressed to Plaintiff upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Bryan E. Barbin, Esquire Edward P. Seeber, Esquire Gleason & Barbin, P.C. 123 State Street Harrisburg, PA 17101 DATE: q-1y--99 EAGER, REINAKER & SPINELLO BY: i A, George Eage Esquire Attorney for Defendant I.D. No. 27740 1347 Fruitville, Pike Lancaster, PA 17601 (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANDREA M. HOCH, NO. 99-4023 Plaintiff V. DENNIS G. BARBAGELLO, Defendant CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certify that: (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: (,11'11 George H J Eage , Esquire Attorney for D&ktendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANDREA M. HOCH, Plaintiff NO. 99-4023 Vs. DENNIS G. BARBAGELLO, JURY TRIAL DEMANDED Defendant NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT DENNIS G. BARBAGELLO, 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 nerve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. DATE: DIa- Z-2 N? GEORGE H: EAGER DIRE ATTORNEY FOR DEFENDANT DENNIS G. BARBAGELLO I.D. NO. 27740 1347 FRUITVILLE PIKE LANCASTER, PA 17601 (717) 290-7971 0141ONWFALTH OF PENNSYLVANIA CU Wry OF CUMBERLAND ANDREA M. HOCH, Plaintif f vs. DENNIS G, BARBAGELLO, Def endan t File No. 99-4023 SUBPOENA TO PROCUCE DOCINENTS OR THINGS FOR DISOOVERY p'M I TO RULE 4009.22 TO: Broad Street Family Practice, 211 Broad Street, Marysville, PA 17053 Person or Within twenty (20) days after service of this subpoena, you are orderers by the court to produce the following documents or things: Any and all first consultation :reports, office notes, MRI, CT and x-ray films & reports, test results, physical therapy reports, nurses' notes and doctors' orders, along with any and all other medical records and reports concern- iAg Plaintiff Andrea M. Hoc 8 - - --- 1347 Fruitville Pike, Lancaster, Penns. vagia._?7-b= You may deliver or mail legible copies of the docrments or produce things requested h, this subpoena, together with the certificate of request at the address listed above. You have the right to seek inoadvance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the docunents or things required by this subpoena within twentti (20) days after its service, the party serving this subpoena may seek a court order con el ling you to con ly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAPE: George H. Eager, Esquire Eager, Reinaker & Spinello ADORESS: 1347 Fruitville Pike Lancaster, PA 17601 TELEPHONE:_ 0171 290-7977 SUPREME COURT ID # 27740 ATTORNEY FOR: Defendant BY THE COURT: DATE: Prothonotary/Clerk, Civil Division Seal of the Cour t Deputy (Eff. 7/97) CO1*VNWMVM OF PE8ILSYLVMUA COUNPY OF CUMBERLAND ANDREA M. HOCH, Plaintiff vs DENNIS G. BARBAGELLO, Defendant TO: Richard Hallock, M.D File No. 99-4023 SUBPOENA TO PRODUCE DOCUPIENTS OR THINGS FOR DISCOVERY PURSUANT TO RUL_ E QOpg 875 Poplar Church Road, Camp Hill 17bll (name of Person or Entity) Within twenty (20) days after service of this subpoena, You are ordered by the court to produce the following docunents or things: Any and all first consultation :reports, office notes, MRI__ CT and x-rayfilms 6 reports, test results, physical therapy , notes and doctors' orders, along with any g Plaintiff Andrea M. Hoc SSN i and all other medical records andoreportarconcern- : a 1347 Fruitville Pike, Lancaster, Pennsy vagia,. thYou may deliver or mail legible copies of the documents or produce things requested h is subpoena, together with the certificate of request at the address listed above. You have the right toaseek inoadvance themreansonable thi cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order cmrpelling you to mnply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLCWING PERSON: NME: George H. Eager, Esquire Eager, Reinaker S Spinello ADDRESS: 1347 Fruitville Pike Lancaster, PA 17601 - TELEPJ"MEr_ (717)971 SUPREAE COURT ID # 27740 ?- ATTORNEY FOR: Defendant DATE Seal of the Court BY THE COOT: Prothonotary/Clerk, Civil Division Deputy (Eff. 7/97) CC144MEALTH OF PERSMVANIA CXMN OF C(MI I2IAND ANDREA M. HOCH, Plaintiff VS. DENNIS G. BARBAGELLO, Defendant File No. -99-4023 SUBPOENA TO PRODUCE DOCU X4rSi OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009Cj2 TO: Central Pennsylvania Orthopedic & Spinal Assocs.; 805 Sir Thomas Court arr s urg, (Name of Person. or Entitv) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doc mints or things: Any and all first consultation reports, office notes, _nd x-rayfilms & reports, test results h 1 notes and doctors' orders 1 ter, with , p yeica therapy reports, nurses' and all other medical records and reports concern- You may deliver or mail legible copies of the this subpoena, cronts or produce things requested h) together with the certificate of f crnpliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to omply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME, George H. Eager, Esquire Eager, Reinaker & Spinello ADDRESS: 1347 Fruitville Pike Lancaster, PA 17601 TELEPHONE?- (717) 29(1_7971 SUPREhE COURT ID # 27740 ATTORNEY FOR: Defendant BY THE COURRT: DATE. Prothonotary/Clerk, Civil Division Seal of the Court Deputy (Eff. 7/97) COMMDNWEALTfi OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDREA M. HOCH, Plaintiff VS. DENNIS G. BARBAGELLO, Defendant File No. 99-4023 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE, 400"2 TO: Occupational Rehab & Research Associates; 121 Garrison Lane, Carlisle, PA 17013 (Nana of Person or Entity) Within twenty (20) days after service of this subpoena, You are ordered by the court to Produce the following documents or things; Any and all first consul tat ion.Teports, office notes, MRI, CT and x-rayfilms & reports, test results, physical therapy reports, r i notes and doctors' orders, along with any and all other medical records andreports concern- iEig Plaintiff Andrea M. Hoc N: a - - 1347 Frni r..ttte na .._ You may deliver or mail legible copies of the documents or produce things requested b% this subpoena, together with the certificate of compliance, to the party making thi; 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 docunents or things required by this subpoena within tyent? (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON; NAME, George H. Eager, Esquire Eager, Reinaker & Spinello ADDRESS: 1347 Fruitville Pike Lancaster, PA 17601 TELEPHONE.*_ (7171T 90_7971 SUPREME COURT ID # 27740 ATTORNEY FOR; Defendant BY THE COURT: DATE: Prothonotary/Clerk, Civil Division Sea 1 of the Court Deputy (Eff. 7/97) COMUMIWFALPH OF PENNSYLVANIA COUNTY OF 91IIffiFIRIAI D ANDREA M. HOCH, Plaintiff VS. DENNIS G. BARBAGELLO, Def endant File No. 92_4023 SUBPOENA TO PRODUCE DOCiI tFturg OR TH 1 NGS FOR DISCOVERY PLpSUANT To RULE_ 4? TO: Magnetic Imaging Center; 4665 Trindle Road, Mec ((Name of Person or , PA 17055 Within twenty (20) days after service of this subpoena' produce the followi You are ordered by the court to n9 documents or things: Any and all first consultation .Teports, office notes, MRI, CT and x-rayfilms & reports, test results, physical therapy , notes and doctors' orders, along with any and all other medical records andoreports rconcern- S8 Plaintiff Andrea M. Hoc _ _ er, Pennsylvagia,,-j 760T; You may deliver or mail legible copies of the docunents or produce things requested bk this subpoena, together with the certificate of crnpliance, 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 docunents or things required by this subpoena w (20) days after its service, the party serving this s camelling you to ccnply with it. subpoena may seek a within t enty court order . THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAHE: George H. Eager, Esquire Eager, Reinaker & Spinello ADDRESS: 1347 Fruitville Pike Lancaster, PA 17601 TELEPHONEr (717) 990_7971 SUPREME COURT ID # 27740 ATTORNEY FOR: Defendant BY THE COURT: DATE: Prothonotary/Clerk, Civil Division Seal of the Court Deputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMiBFFRIAND ANDREA M. HOCH, Plaintiff VS. DENNIS G. BARBAGELLO, Defendant File No. 99-4023 SUBPOENA TO PRODUCE DOCIJENTS OR THINCIS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO Leonard Jones, D.C., 6520 Carlisle Pike, Mechanicsburg, PA 17055 Jones Chiropractic Center (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all first consultation reports, office notes, MRI, CT and x-rayfilms s reports, test results, physical therapy reports, nurses' notes and doctors' orders, along with any and all other medical records and reports concern- inn 91n 4...114 ?-J..__ .. .._ .... 1347 Fruitville Pike, Lancaster, Pennsylva ie, `AOdress You may deliver or mail legible copies of the docunents or produce things requested b, this subpoena, together with the certificate of corpliance, 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 docunents or things required by this subpoena within twent. (20) days after its service, the party serving this subpoena may seek a court Order" corpelling you to ccnply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FCLLCWING PERSON: NAME: George H. Eager, Esquire Eager, Reinaker 6 Spinello ADORESS: 1347 Fruitville Pike Lancaster, PA 17601 TELEPHONE?_ (717) 29n-7971 SUPREME COURT ID # 27740 ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division DATE: Seal of the Court Deputy (Eff. 7/97) C014UNNFALTH OF PENNSYLVANIA NONPY OF CIDMERLAND ANDREA M. HOCH, Plaintiff VS. DENNIS G. BARBAGELLO, Defendant File NO. .Q9-4023 SUBPOENA TO PRODUCE DOMMENTS OR THtIX3s FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Community General Osteopathic Hospital, 4300 Londonderry Road, P.O. Box 3000 Harrisburg, PA 17105 (Nang of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doaunents or things: an abstract of any and all medical records and films concerning Plaintiff Andrea M. Hoch (SSN: 180-54-6461) (DOB: 1/24/65) at 1347 ille Lancaster, Pennsylvania, 17601. (Address) You may deliver or mail legible copies of the docLirents this subpoena together with the certificate o nc eproduce things requested h, request at the address listed above. You have the right to seek inoadvance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the doainents or things required by this subpoena within twenty (20) days after its service, the party serving this s ccrpeIIing you to ca. ly with it. subpoena may seek a cart order THIS SUBPOENA WAS ISSUED AT THE REGUEST OF THE FCLLCWING PERSON: NAPE:George H. Eager Esquire Eager, Reinaker & Spinello ADDRESS: 1347 Fruitville Pike Lancaster, PA 17601 TELEPHONEr_(717) 290-7971 SUPREtE RT ID # 27740 OOU ATTORNEY FOR: Defendant BY THE COURT: DATE: Prothonotary/Clerk. Civil Division Seal of the Court Deputy (Eff. 7/97) COI4CNMM TH OF PENNSYLVANIA CXNPY OF CUMBFRIAND ANDREA M. HOCH, Plaintiff VS. DENNIS G. BARBAGELLO, Defendant File No. -_99-4023 SUBPOENA TO PRODUCE DOOI P -MM I W3S FOR DISCOVERY PURSUANT TO RULE 40 9 22 TO: 2575 Interstate Drive (Wane of Person or Entity) 1 Within twenty (20) days after service of this subpoena, you are ordered by the court to Produce the following docmments or thin reports, etc. and any other information pertainingntoaPlaintiff Andrea M. Hach (SSN: 180-54-6461) (DOB: 1/74/651 at 1347 Fruitville Pike, Lancaster, Pennsylvania, 17601. (Address) You may deliver or mail legible copies of the donments or produce things requested b% this subpoena, together with the certificate of canpliance, to the party making thi: 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 twentl (20) clays after its service, the party serving this s mmnelling you to carply with it. ubPoena May seek a court order THIS "'CENA WAS ISSUED AT THE REGUEST OF THE FOLLOWING PERSON: NAME: George H. Eager Esquire Eager, Reinaker S Spinello ADDRESS: 1347 Fruitville Pike Lancaster PA 17601 TELEPICNE' (717) 290-7971 SUPREME COURT ID # 27740 ATTORNEY FOR' Defendant BY TFE COURT: DATE: Prothonotary/Clerk, Civil Division Seal of the Court Deputy (Eff. 7/97) CERTIFICATE OF SERVICE I HEREBY CERTIFY that I am this day served a true and correct of the foregoing Notice of Intent to Serve a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 upon the persons and in the manner indicated below. Service by First Class Mail, addressed as follows: Bryan E. Barbin, Esquire Edward P. Seeber, Esquire Gleason & Barbin, P.C. 123 State Street Harrisburg, PA 17101 (Attorneys for Plaintiff) EAGER, REINAKER & SPINELLO BY: George H. ager, quire Attorney for D ndant I.D. No. 2774 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 Dated: l0//,? 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 upon the personS set forth below and in the manner indicated: First class mail, postage pre-paid: Bryan E.Barbin, Esquire Edward P. Seeber, Esquire Gleason & Barbin, P.C. 123 State Street Harrisburg, PA 17101 (Attorneys for Plaintiff) DATE: d // A.? EAGER, REINAKER & SPINELLO BY: / George H. -age Esquire Attorney for efendants I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 ?- C.1 C- 1 _° - L ?. l_?r ? _ .. (,_, . .- t ?`? I ?... ' , C, ,_. .. Bryan E. Barbin, Esquire Edward P. Secber, Esquire Ci LEASON & BARHIN, P.C. 1 23 State Street I larrisburg, PA 17 101 (717) 232-9200 ANDREA M. HOCH Plaintiff V. DENNIS G. BARBAGELLO Defendant Attorneys rot Andrea M. Hoch IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 99-4023 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Andrea M. Hoch, Plaintiff, 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 (20) days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. GLEASON & BARBIN, P.C. DATED: 3- j t) 60 rd P. Scc er i Et A . I.D. #76084 123 Stale Street Harrisburg, PA 17101 (717) 232-9200 Attorneys for Plaintiff Andrea M. Hoch Bryan E. Harbin, Esquire Edward P. Seeber, Esquire GLEASON& BARREN, P.C. 123 State Street Harrisburg, PA 17101 (717) 232-9210 ANDREA M. HOCH Plaintiff V. Attorneys for Andrea M. Hoch IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 99-4023 DENNIS G. BARBAGELLO Defendant CERTIFICATE OF SERVICE I, Edward P. Seeber, hereby certify that on the date indicated below, I served a true and correct copy of the foregoing CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 by having the foregoing document served by United States, first class mail, postage prepaid addressed to the following: George H. Eager, Esquire Eager, Reinaker & Spinello 1347 Fruitville Pike Lancaster, PA 17601 L and P. Seeber DATED: - Bryan E. Barbin, Esquire Edward P. Seeber, Esquire GLEASON & BARBw, P.C. 123 State Street Harrisburg, PA 17101 (717) 232-9200 ANDREA M. HOCH Plaintiff V. DENNIS G. BARBAGELLO Defendant Attorneys for Andrea M. Hoch IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 99-4023 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Plaintiff, Andrea M. Hoch, 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. GLEASON & BARBIN, P.C. C iA - 'I. . Mward P. Seeber L Atty. I.D. #76084 123 State Street Harrisburg, PA 17101 (717) 232-9200 Attorneys for Plaintiff Andrea M. Hoch DATED: )",21-oo Bryan E. Barbin, Esquire Edward P. Seeber, Esquire GLEASON & BAEErN, P.C. 123 State Street Harrisburg, PA 17101 (717) 232.9200 ANDREA M. HOCH Plaintiff V. DENNIS G. BARBAGELLO Defendant Attorneys for Andrea M. Hoch IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 99-4023 CERTIFICATE OF SERVICE I, Edward P. Seeber, hereby certify that on the date indicated below, I served a true and correct copy of the foregoing NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 by having the foregoing document served by United States, first class mail, postage prepaid addressed to the following: George H. Eager, Esquire Eager, Reinaker & Spinello 1347 Fruitville Pike Lancaster, PA 17601 ward P. eeber DATED: )-d j-06 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDREA M. HOai DENNIS G. BARBAGELLA V. File No. ge-an2s Defendant SUBPOENATO PRODUCE DOCUMENTS ORTHINGS FOR DISCOVERY PURSUANTTO RULE 4009.22 State Farm Mutual Automobile Insurance Company, c/o Jackie Ravenel TO: 115 Limekiln Road, P.O. Box 257, New Gtunberland, PA 17070-0257 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all writings, rremoranda, reports, statements and records, etc., including, but not limited to, settlement documents, with regard to Defendant, Dennis G. Barbagello's, motor vehicle accident which occurred in or about the surnner of 1996 at the nffirnag of rIPagon r Rarhin P_C 121 States St. Harriahiirq, Pn 171nl (Address) You may deliver or mall legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above.You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENAWAS ISSUED ATTHE REQUEST OFTHE FOLLOWING PERSON: Name Edward P. Seeber, Esquire earson zn, P.C. Address: 123 State Street Harrisburg, PA 17101 Telephone: 717/232-9200 Supreme Court ID If 76084 Attorney For: Plaintiff BY THE COURT: Prothonotary/Clerk, Civil Division Date: Seal of the Court Plaintiff Deputy (Eff.7/97) 1. ?? ?? ?` ?..? ? ?.? ??) i t. ?1_ ?? .:.?.`: . (-•? 1 ' ? 1 . I ?-, ; l' P: ' f Ii ll .. V. 1.?) _ ? ? C.J CJ IN THE COURT OF COMMON ANDREA M. HOCH Plaintiff v. DENNIS G. BARBAGELLO Defendant PLEAS OF CUMBERLAND CIVIL ACTION - LAW COUNTY, PENNSYLVANIA No. 99_4023 CERTIFICATE PREREQUISITE TO SERVICE OF A S NA PURSUANT Tp g E 4009.22 things UBPOE As a prerequisite to service pursuant to Rule 4009.22 certifies of a Subpoena for documents that Defendant, Dennis G. Barba and Bello, Of the Subpoei a Notice of Intent to serve party at least- twettached thereto was ma letdhe Subpoena with a copy is sought to y days prior to or delivered be served; the date on which the to each Subpoena Proposed Sub) a copy of the Notice of poena, is attached to this Intent, includin (3) Certificate; g the no objection to the Subpoena has been (4) received, and the Subpoena which will be served is identical Subpoenaoena which is attached to the Notice of to Intent to serve the EAGER, REINAKER c. SPINELLO Dated: June 13, 2000 By: GEOR E GER, Attor ey or Defendant 1. D. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ANDREA M. HOCH Plaintiff No. 99-4023 V. DENNIS G. BARBAGELLO Defendant NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant, Dennis G. Barbagello, intends to serve a Subpoena 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 may be served. EAGER, REINAKER & SPINELLO By: GEORGE H. EAGER, Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 Dated: May 18, 2000 COtNL'VIONWEALTH OF PENNSYLVANIA COUNTYOF CUMBERLAND ANDREA M. HOCH V. File No. 99-4023 DENNIS G. BARBAGELLC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Dr. William M. Bird, 4300 Londonberry Road, Harrisburg, PA 17105 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all first consultation reports, office notes, S, CT and x-ray alms and reports, test results, p ysica t.erapy reports, nurses notes and d Avr octors orders, along with any and all other medical records and reports concerning Plaintiff `ZZ7"fi"4T iG C _ (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE, REQUEST OF THE FOLLOWING PERSON: George H. Eager, Esquire NAA(JE: Eager, Reinaker & Spinello ADDRESS: 1347 Fruitville Pike Lancaster, PA 17601 TELEPHONE: (717) 290-7971 SUPREME COURT ID # 27740 ATTORNEY FOR: reFe„da„r DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy CONINIONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANDREA M. HOCH V. File No. 99-4023 DENNIS G. BAREAGELLO - SUBPOENA TO PRODUCE DOCUNIENTS OR THING FOR DISCOVERY PURSUANT TO RULE 4009.22 Leonard R. Jones, 213 State Street, Harrisburg, PA 17101 Within twenty (20) days after service of this subpoena, you are ordered by the court to MR,, Produce the following documents or things: Any and all first consultationsreports, office notes T and x-ray films and reports, test resu ts, py p sica t era docto report, nurses notes and at 1347 Fruitville Pike Lancaster PA 17601 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: George H. Eager, Esquire NAM: Eager, Reinaker & Spinello ADDRESS: 1347 Fruit jilp pike Lancaster, PA 17601 TELEPHONE:(717) 290-7971 SUPREME COURT ID k 27740 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I HEREBY CERTIFY that I am this day serving a copy of the foregoing Notice of Intent to Serve a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 upon the person and in the manner indicated below. Service by first class mail, addressed as follows: Bryan E. Barbin, Esquire Edward P. Seeber, Esquire Gleason & Barbin, P.C. 123 State Street Harrisburg, PA 17101 EAGER, REINAKER & SPINELLO By: GEORGE H. EAG , Attorney fo efendant I.D. No. 40 1347 Frui ville Pike Lancaster, PA 17601 (717) 290-7971 Dated: May 18, 2000 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I am this day serving a copy of the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22, upon the person and in the manner indicated below. Service by first class mail, addressed as follows: Bryan E. Barbin, Esquire Edward P. Seeber, Esquire Gleason & Barbin, P.C. 123 State Street Harrisburg, PA 17101 EAGER, REINAKER & SPINELLO By: GEORGE H. EAG , Attorney fo Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 Dated: June 13, 2000 -? - _, ':.; '? i; ?_> Andrew W. Barbin, Esquire GLGASON & BARBIN, P.C. 123 Slate Street 11arrisburg, PA 17101 (117)232.9200 ANDREA M.HOCH Plaintiff V. DENNIS G. BARBAGELLO Defendant Attorneys for Andrea M. Hoch IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 99-4023 PRAECIPE TO DISCONTINUE TO: CURT LONG, Prothonotary Plaintiff, Andrew M. Hoch, by and through her counsel, request that the above referenced case be marked settlement, discontinued, and ended. GLEASON & BARBIN, P.C. ? n rew W. Barbin At y. I.D. #43571 123 State Street Harrisburg, PA 17101 (717) 232-9200 Attorney for Plaintiff Andrea M. Hoch 0 DATED: May 10, 2001 Andrew W. Durbin, Esquire GLEASON & aARBIN, P.C. 123 State Street Harrisburg, PA 17101 (717)232.9200 ANDREA M. HOCH Plaintiff V. DENNIS G. BARBAGELLO Defendant Attorneys for Andrea M. Hoch IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 99-4023 CERTIFICATE OF SERVICE 1, Andrew W. Barbin, hereby certify that on the date indicated below, 1 served a true and correct copy of the foregoing PRAECIPE To DISCONTINUE by having the foregoing document served by United States, first class mail, postage prepaid addressed to the following: George H. Eager, Esquire Eager, Reinaker & Spinello 1347 Fruitville Pike Lancaster, PA 17601 DATED: May 10, 2001 ,. ,,, _ -- - ?_ °'i._ , ; _.. -- , =:'? , ?, _`. § _, ?'