HomeMy WebLinkAbout03-3108HELEN BRIDGES, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY, PENNA.
V. /?.
NO: 03 -.3/Op
GLENN S. LEHMAN,
Defendant CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE TO DEFEND
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 request
by the plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlise, PA 17013-3387
Telephone No. (717) 249-3166
NOTICIA
Le han demandado a usted en la corte. Si usted quiere defenderse de estas
demandas expuestas en las paginas siguientes, usted tiene viente (20) dias do plazo
al partir de la fecha de la demanda y la notificacion. Usted debe presentar una
apariencia
escrita o en persona o por abogado y archivar en la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de sus persona. Sea avisado
que si usted no se defiende, la corte tomara medidas y puede entrar una orden
contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es
pedido en la peticion de demanda. Listed puede perder dinero o sus propiedades o
otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGER TAIL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlise, PA 17013-3387
Telephone No. (717) 249-3166
Dated: 6- %-03
Respectfully Submitted,
DIVEGLIA & YLOR, P.C.
By: V - 1
Archie V. iveglia, Esquire
Attorney I.D. #17140
Two Lincoln Way West
New Oxford, PA 17350
(717) 624-2500 /
Attorney for Plaintiff
HELEN BRIDGES, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY, PENNA.
V.
NO: 03 (2t c i l
GLENN S. LEHMAN,
Defendant CIVIL ACTION - LAW
JURY TRIAL DEMANDED
COMPLAINT
AND NOW, this _ day of June, 2003, comes the Plaintiff by and through
her attorneys Diveglia & Kaylor, P.C., who file the following action on her behalf and
aver as follows:
1. Plaintiff, Helen Bridges, is an adult individual who resides at 2306 North Fourth
Street, Harrisburg, Pennsylvania 17110.
2. Defendant, Glenn S. Lehman, is an adult individual who resides at 253 Salem
Church Road, Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. On or about August 31, 2001, Plaintiff was a passenger in a vehicle with the
vehicle being driven East on Trindle Road near its intersection with Simpson Ferry
Road, Cumberland County, Pennsylvania.
4. The above said time and place, the Defendant was on the same road and in
the same direction of the vehicle in which Plaintiff was a passenger when he, without
reason or justification, struck the rear of Plaintiff's vehicle and thereby caused injury to
the Plaintiff.
5. As a result of the above described collision, the injuries Plaintiff incurred were
neck and shoulder pain and was eventually diagnosed as a protrusion of her disc at
C6-7.
6. As a result of the above described collision and injury, Plaintiff required
extensive treatment continues to receive medical treatment for her injuries.
7. As a result of the injuries received, Plaintiff has incurred loss of employment,
thereby incurred wage loss.
8. As a result of the above described collision and injuries, Plaintiff has incurred
medical expenses above the limits of her insurance company.
9. As a result of the above described collision and injuries, Plaintiff has incurred
great pain and mental distress and continues to suffer the same.
10. Although Plaintiff's condition has improved, it is uncertain as to whether or not
her conditions will be permanent and thereby a claim for possible permanent injuries
is being made.
11. The above described accident and injuries as a result of negligence of the
Defendant whose negligence consist of the following:
a) He failed to observe where he was going.
b) He was following to closely to the vehicle to which Plaintiff was a passenger
c) He was driving at an excessive rate of speed under the circumstances.
d) He was inattentative in his driving.
WHEREFORE, Plaintiff demands judgement against Defendant for a sum in
excessive of $35,000 together with interest and costs.
Respectfully Submitted,
Dated: 6 '3o.?)
DIVEGLIA & KAYLOR, P.C.
By: Ll\
Archie iveglia, Es
Attorney I.D. #17140
Two Lincoln Way West C
New Oxford, PA 17350
(717) 624-2500
Attorney for Plaintiff
VERIFICATION
The foregoing COMPLAINT IS based upon the information which has been
gathered by my counsel in the preparation of the lawsuit. I have read the
COMPLAINT and to the extent that it is based upon information which I have given to
my counsel, it is true and correct to the best of my knowledge, information and belief.
To the extent that the content is that of counsel, I have relied upon counsel in making
this verification. This statement and verification are made subject to the penalties of
Pa. C.S. §4904 relating to unsworn falsification to authorities, which provides that if I
make knowingly false averments, I may be subject to criminal penalties.
Date
Helen Bridges
CD
be-_ ? ?.m
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2003-03108 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BRIDGES HELEN
VS
LEHMAN GLENN S
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
LEHMAN GLENN S
but was unable to locate Him
deputized the sheriff of PERRY
in his bailiwick. He therefore
serve the within COMPLAINT & NOTICE
County, Pennsylvania, to
On August 5th , 2003 , this office was in receipt of the
attached return from PERRY
Sheriff's Costs:
Docketing 18.00
Out of County 9.00
Surcharge 10.00
Mileage 6.90
Dep Perry County 35.60
79.50
08/05/2003
DIVEGLIA & KAYLOR
So answer
R. Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this .21. '% day of n`rlr
.2uV 3 A. D.
l
PrI'othonotnota?a2 R ,
' / Pr'y / '
In The Court of Common Pleas of Cumberland County, Pennsylvania
Helen Bridges
VS.
Glenn S. Lekunan
SERVE: same No. 03-3108 civil
Now, July 24, 2003 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Perry County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
within
, 20 , at o'clock M. served the
upon
at
by handing to
a
and made known to
copy of the original
the contents thereof.
So answers,
Sheriff of County, PA
Sworn and subscribed before
me this _ day of 120
_
COSTS
SERVICE $
MILEAGE
AFFIDAVIT
SHERIFF'S RETURN
In the Court of Common Pleas
Of the 41" Judicial District
of Pennsylvania-Perry County Branch
Helen Bridges NO. 2003-3108
V5
Glenn S. Lehman
54 Glutzhole Rd.
Duncannon, PA 17020
Carl E. Nace, Sheriff, who being duly sworn according to law, says that he made a
diligent search and inquiry for the within named Defendant(s) to wit Glenn S.L ehman,
but was unable to locate him/her in his bailiwick. He therefore returns the within,
Complaint, to the above named Defendant(s) Glenn S. Lehman, at 54 Glutzhole Rd.
Duncannon, Pa. 17020NOT FOUND. We feel that this is a good address. No one has
been home at any of our attempts.
Sworn and subscribed to before me
this ?J?1 day of /?UrQ5-f- , 2003.
/O
/A?
WENeac ?j/
Sheriff
of Perry County
NOTARIAL SEAL
MARGARET F. FLICKINGER, NOTARY PUBLIC
BLOOMFIELD BORO., PERRY COUNTY
MY COMMISSION EXPIRES FEB. 16,'1004
HELEN BRIDGES, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY, PENNA.
V.
NO: 03-3108 Civil Term
GLENN S. LEHMAN,
Defendant
PREACIPE
TO THE PROTHONOTARY:
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
Please re-instate the Complaint in the above captioned matter.
Respectfully Submitted,
DIVEGLIA & KAYLOR,
?
Dated: /6-9-9
By:
Archie iveglia, Es
Attorney I.D. #17140
Two Lincoln Way West
New Oxford, PA 17350
(717) 624-2500
Attorney for Plaintiff
c w Q
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Y C` N a
F" :)7
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2003-03108 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BRIDGES HELEN
VS
LEHMAN GLENN S
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
LEHMAN GLENN S
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of PERRY County, Pennsylvania, to
serve the within COMPLAINT & NOTICE
On November 12th , 2003 , this office was in receipt of the
attached return from PERRY
Sheriff's Costs:
Docketing 18.00
Out of County 9.00
Surcharge 10.00
Dep Perry County 29.00
.00
66.00
11/12/2003
DIVEGLIA & KAYLOR
Sworn and subscribed to before me
this / y w day of 72o-ucn
2u A. D.
(:?, Q
Prothonotary
So answer a`
R.? Thomas Kline -
Sheriff of Cumberland County
In The Court of Common Pleas of Cumberland County, Pennsylvania
Helen Bridges
VS.
Glenn S. Lehman
SERVE: David Lehman on behalf of Glenn Lehman No. 03-3108 civil
Now October 17, 2003 , I; SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Perry County to execute this Writ; this
deputation being made at the request and risk of the Plaintiff.
.i
Sheriff of Cumberland County, PA
Affidavit of Service
Now Nov..5,
, 20 0 3 , at 5: 3 7 o'clock P M. served the
within Complaint
upon David Lehman
at 54 Glutzholde Rd. Duncannon, ( Wheatfield Twp), PA. 17020
by handing to David Lehman
a True & Attested copy of the original complaint
and made known to Him the contents thereof.
Deputy
Sworn and subscribed before
me this ?A day of All . 206,3
NOTARJ?L SEAL
MARGARETF.FLC NGER NOTARY PUBLIC
BLOOMFlELOBORO.,PERRY000NTY I
MY COMMISSION EXPIRES FEB. 16, 2004
So answers,
me C. Wilson
eriffof Perry
COSTS
SERVICE $
MILEAGE
AFFIDAVIT
$
County, PA
HELEN BRIDGES, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
NO. 03-3108 Civil Term
GLENN S. LEHMAN,
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
ENTRY OF APPEARANCE
TO: PROTHONOTARY
Please enter the appearance of Jeffrey B. Rettig, Esquire, and Hartman, Osborne &
Rettig, P.C., on behalf of Defendant, Glenn S. Lehman, in regard to the above-captioned action.
Respectfully submitted,
HARTMAN, OSBO" & RETTIG, P.C.
Bgeffriey B. Rettig, quire
Supreme Ct. #19616
126-128 Walnut Street
Harrisburg, PA 17101
(717) 232-3046
Dated: / vl/_"j Attorney for Defendant
CERTIFICATE OF SERVICE
I, Jeffrey B. Rettig, Esquire, hereby certify that I am this day serving a copy of the foregoing
document upon the person(s) and in the manner indicated below, which service satisfies the
HARTMAN, OSBORNE & RETTIG, P.C.
requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the
United States mail, first-class postage prepaid, as follows:
Archie V. Diveglia, Esquire
Diveglia & Kaylor, P.C.
Two Lincoln Way West
New Oxford, PA 17350
(Counsel for Plaintiff)
Dated: By: }
Ief y B. Rettig, Esqu e
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IN"ME'COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
BRIDGES
Vs.
NO. 033108
LEHMAN
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena(s) for documents and things
pursuant to Rule 4009.22 JEFFREY RETTIG, ESQUIRE certifies that:
1. A Notice of Intent to Serve the Subpoena(s) with a copy of
the subpoena(s) attached thereto was :mailed or delivered to
each party at least twenty days prior to the date on which
the subpoena(s) is sought to be served,
2. A copy of the Notice of Intent, including the proposed
subpoena(s) is attached to this certificate,
3. No objection to the subpoena(s) has been received, and
4. The subpoena(s) which will be served is identical to
the subpoena(s) which is attached to the Notice of Intent
to Serve the Subpoena(s).
Date: 01/02/04
JEFFREY RETTIG, ESQUIRE
126-128 WALNUT ST
HARRISBURG, PA 17101
717-232-3046
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA PA 19135
(215) 335-3581
By: Aisha Hodge
File #: M306161
IN'T IE'COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
BRIDGES
Vs.
NO. 033108
LEHMAN
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena(s) for documents and things
pursuant to Rule 4009.22 JEFFREY RETTIG, ESQUIRE certifies that:
1. A Notice of Intent to Serve the Subpoena(s) with a copy of
the subpoena(s) attached thereto was mailed or delivered to
each party at least twenty days prior to the date on which
the subpoena(s) is sought to be served,
2. A copy of the Notice of Intent, including the proposed
subpoena(s) is attached to this certificate,
3. No objection to the subpoena(s) has been received, and
4. The subpoena(s) which will be served is identical to
the subpoena(s) which is attached to the Notice of Intent
to Serve the Subpoena(s).
Date: 01/02/04
JEFFREY RETTIG, ESQUIRE
126-128 WALNUT ST
HARRISBURG, PA 17101
717-232-3046
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA PA 19135
(215) 335-3581
File #: M306161
By: Aisha Hodge
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
BRIDGES
Vs.
LEHMAN No. 033108
TO: ARCHIE DIVEGLIA, ESQ (PLAINTIFF)
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
DEFENDANT intends to serve a subpoena(s) identical to
the one(s) attached to this notice. You have twenty (20) days
from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is
made the subpoena may be served.
Date: 12/09/03 JEFFREY RETTIG, ESQUIRE
126-128 WALNUT ST
HARRISBURG, PA 17101
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA, PA 19135
(215) 335-3581
By: Aisha Hodge
Enc(s): Copy of subpoena(s)
Counsel return card
File #: M306161
COMMONWEALTH OF PENNSYLVANIA_
COUNTY OF CUMIBEPJAM
BRIDGES
Vs. File No. _ 03308
LEHMAN
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
DELTA DENTAL, ONE DELTA DR, MECHANICSBURG PA 17055
TO: ATTN- PFRSONNF.T. T)RPARTMF.NT
Person or Ent
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following doaments or things:
SEE AT ?- ED---AD ---_
at
MEDICAL LEGAL REPRODUCTIONSEAcWzs?940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things requested t,>
this subpoena, together with the certificate of connliance, to the party making thin
request at the address listed above. You have the right to seek in advance the rea.onable
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 thi^ subpoena may seek a court ordel-
crnpelling you to ca. ly with it.
THIS SUBPOENA WAS ISSUED AT THE REOUEST OF THE FOLLOWING PERSON:
rvw-c: TP.FEREy RF.TTT(-, ESQ
ADDRESS. _t ST
TELEPHONE: HARRISBURG, PA 17101
SUPREME OOURT ID # 215-335-3212
ATTORNEY FOR:
DEFENDANT
M306161-01
DATE: _!WI',>p,lK, . 4 d-v _
Seal of the Court
BY THE COURT:
Protho/nootary/tl rk8 , Civil Division
Deputy
(Eff. 7/97)
BRIDGES
Vs.
LEHMAN
ADDENDUM TO SUBPOENA
No. 033108
CUSTODIAN OF RECORDS FOR: DELTA DENTAL
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: HELEN D BRIDGES
ADDRESS: 2306 N 4TH ST HARRISBURG PA
DATE OF BIRTH: 12/19/64
SSAN: 189545171
ALL RECORDS FORM 1/1/97 TO THE PRESENT, INCLUDING BUT NOT LIMITED
TO EMPLOYMENT APPLICATION, FIRST REPORT OF ANY WORK-RELATED
INJURIES, MEDICAL RECORDS AND WAGE INFORMATION.
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS ARE ATTACHED HERETO.I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date Authorized signature or
DELTA DENTAL
CUMBERLAND
M306161-01
* * * SIGN AND RETURN THIS PAGE * * *
COMM]NWFALTH'OF PENNSYLVANIA-
COUNTY OF CUMBERLAND
c
BRIDGES
Vs. File Na=y-:
033108
LEHMAN _ --- - -----
SUBPOENA TO PRODUCE DOak ENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
KLINE FAMIY PRACTICE, 2601 N THIRD ST, HARRISBURG PA 17110
TO. _
?_ (Name of Person or Entity)
Within twenty (20) gays after service of this subpoena, you are ordered by the court to
produce the following docunant.or things:--
SEE
at --
MEDICAL LEGAL REPRODUCTIONSfA-tWgss?94A,,DISSTOM ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things requested t,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 preoaring the copies or--producing the-things sougtit.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving this, s
compelling you to ca, ly with it. subpoena Y seek a court orde•
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME:- EFFREY RETTIG, ESQ
ADDRESS:
- '426 3:28-WALNU-T ST
TELEPHONE: 17101
SUPREME COURT ID # 215 - 33:.3212
ATTORNEY FOR:
DEFENDANT
BY THE COURT:
M306161-02
DATE:
jiao Il, a
f?
3 Prothonotary/ 1? dtk, Civil
? Division
.
,
__
Seal of the Court
Deputy
(Eff..T/97)
ADDENDUM
TO SUBPOENA
BRIDGES
Vs.
LEHMAN No. 033108
CUSTODIAN OF RECORDS FOR: KLINE FAMIY PRACTICE
ANY AND ALL RECORDS FROM 111196 TO THE PRESENT.
PERTAINING TO:
NAME: HELEN D BRIDGES
ADDRESS: 2306 N 4TH ST HARRISBURG PA
DATE OF BIRTH: 12/19/64
SSAN: 189545171 -
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
---------------------------------------
RECORD CUSTODIAN - COMPLETE AND RETURN
[ l RECORDS AREATTACHED HERETO. I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTSAVAILABLE• I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS
/ XRAYS have been destroyed
Date
KLINE FAMIY
CUMBERLAND
M306161-02
* * * SIGN AND RETURN THIS PAGE * * *
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HELEN BRIDGES, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
NO. 03-3108 Civil Term
GLENN S. LEHMAN,
Defendant
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE TO PLEAD
TO: Helen Bridges, Plaintiff
c/o Archie V. Diveglia, Esquire
Diveglia & Kaylor, P.C.
Two Lincoln Way West
New Oxford, PA 17350
(Counsel for Plaintiff)
You are hereby notified to file a written response to the enclosed Defendant's Answer
with New Matter within twenty (20) days from service hereof or a judgment may be entered
against you.
Respectfully submitted,
HARTMAN, OSBORNE & RETTIG, P.C.
Jeffrey B. Rettig, Esqu
preme Ct. #19616
126-128 Walnut Street
Harrisburg, PA 17101
(717) 232-3046
Dated: Yl2 ?/ 0 lam/ Attorney for Defendant
HELEN BRIDGES,
V.
GLENN S. LEHMAN,
"N
AND NOW comes the Defendant, by his attorneys, Hartman, Osborne & Rettig, P.C. and
answers Plaintiffs Complaint as follows:
1. It is admitted that the Plaintiff is who she says she is. As to the balance of the
allegations of this paragraph, after reasonable investigation, Defendant is without knowledge or
information sufficient to form a belief as to the truth thereof and proof is demanded.
2. It is admitted that the Defendant, Glenn S. Lehman is an adult individual. He no
longer resides at the address as alleged.
3. Denied. After reasonable investigation, Defendant is without knowledge or
information sufficient to form a belief as to the truth thereof and proof is demanded.
4. Denied. After reasonable investigation, Defendant is without knowledge or
information sufficient to form a belief as to the truth thereof and proof is demanded.
5-10. Denied. After reasonable investigation, Defendant is without knowledge or
information sufficient to form a belief as to the truth thereof and proof is demanded.
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 03-3108 Civil Term
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
11. Denied pursuant to Pa.R.C.P. 1029.
WHEREFORE, Defendant request that Plaintiff's Complaint be dismissed without cost to
him.
NEW MATTER
12. Plaintiff's claims are subject to the provisions of the Pennsylvania Motor Vehicle
Financial Responsibility Act, the limitations of which are incorporated herein by reference thereto.
13. Plaintiff has received some payment by or on behalf ofthe Defendant for claimed lost
wages which is alleged to be a set off against any award to Plaintiff in this case.
14. Plaintiff has or may have failed to mitigate her damages.
15. Plaintiff's claims may be barred by the statute of limitations.
WHEREFORE, Defendant requests that Plaintiffs Complaint be dismissed without cost to
him.
Respectfully submitted,
HARTMAN, OSBORNE & RETTIG, P.C.
Jeffrey B. Rettig, EsgWre
preme Ct. I.D. #19616
126-128 Walnut Street
Harrisburg, PA 17101
(717) 232-3046
Attorneys for Defendant
VERIFICATION
I, Jeffrey B. Rettig, Esquire, Attorney for the Defendant, Glenn S. Lehman, hereby verify
and state that the facts set forth in the foregoing ANSWER OF DEFENDANT TO PLAINTIFF'S
COMPLAINT WITH NEW MATTER are true and correct to the best of my information,
knowledge and belief. I understand that false statements herein are made subject to the penalties of
18 Pa. C.S.A. Section 4904 relating to unworn verification to authorities.
Dated: 4(h J ? UI
Je Yev ettig,Esquir
A for Defendant, lenn S. Lehman
CERTIFICATE OF SERVICE
I, Jeffrey B. Rettig, Esquire, hereby certify that I am this day serving a copy of the foregoing
document upon the person(s) and in the manner indicated below, which service satisfies the
requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the
United States mail, first-class postage prepaid, as follows:
Archie V. Diveglia, Esquire
Diveglia & Kaylor, P.C.
Two Lincoln Way West
New Oxford, PA 17350
(Counsel for Plaintiff
Dated: q
7- 7
HARTMAN, OSBORNE & RETTIG, P.C.
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HELEN BRIDGES, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
NO. 03-3108 Civil Term
GLENN S. LEHMAN,
Defendant CIVIL ACTION- LAW
JURY TRIAL DEMANDED
PLAINTIFFS' REPLY TO NEW MATTER
AND NOW, this l5 day of May, 2004, comes the plaintiff, by her
attorney, Archie V. Diveglia, Esquire, who file the following Reply to New Matter
and in support thereof avers as follows:
12-13. Denied as a conclusion law as to which no further response is
required.
14. Denied. Plaintiff has made every effort to mitigate her damages.
15. Denied as a conclusion law as to which no further response is
required.
Respectfully
KAYL(DR, P
Date: 5--1-01
By:
Ardhie V. JDivegli E,,
Attorney 1.D. #17 40
Two Lincoln Way We;
New Oxford, PA 1735
(717) 1524-2500
Attorney for Plaintiff
CERTIFICATE OF SERVICE
AND NOW, this -?6tday of May, 2004, I, Tammy J. Laughman, for
DIVEGLIA & KAYLOR, P.C., hereby certify that a copy of the foregoing
PLAINTIFFS' REPLY TO NEW MATTER was served by first class mail, postage
pre-paid and addressed to the following:
Jeffrey B. Rettig, Esquire
Hartman, Osborne & Rettig, P.C.
126-128 Walnut Street
Harrisburg, Pennsylvania 17101
DIVEGLIA & KAYLOR, P.C.
Tammy J. g an
Legal Secretary for Diveglia & Kaylor, P.C.
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HELEN BRIDGES,
V.
GLENN S. LEHMAN,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 03-3108 Civil Term
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
DEFENDANT, GLENN S. LEHMAN MOTION TO COMPEL DISCOVERY
AND NOW comes the Defendant, by his attorneys, Hartman, Osborne & Rettig, P.C. and
brings the following Motion to Compel Discovery:
1. On or about December 4, 2003, Defendant forwarded to Plaintiffs' counsel,
Interrogatories and a Request for Production of Documents. A copy of the transmittal letter
forwarding the Interrogatories and Request for Production of Documents is attached hereto, made
a part hereof, and marked as Exhibit "A".
2. On January 28, 2004, Defendant forwarded correspondence to Plaintiffs' counsel
requesting responses to Defendant discovery requests which were forwarded to him on or about
December 4, 2003. A copy of said correspondence is attached hereto, made apart hereof and marked
as Exhibit "B".
3. On March 22, 2004, Defendant again wrote to Plaintiff's counsel requesting
outstanding discovery responses. A copy of said correspondence is attached hereto, and made a part
hereof and marked as Exhibit "C".
4. To date, counsel for Plaintiff has neither answered this discovery nor filed any
objection to it.
5. The Plaintiff's failure to respond to written discovery requests are in violation of the
Pennsylvania Rules of Civil Procedure and are delaying the progress of this case.
6. Defendant is severely prejudiced in defending this action in light of Plaintiff s failure
to appropriately respond to Defendant's Interrogatories and Request for Production of Documents.
Plaintiff is represented in this matter by Archie V. Diveglia, Esquire, Diveglia &
Kaylor, P.C., Two Lincoln Way West, New Oxford, PA 17350, telephone (717) 624-2500.
8. Defendant is represented in this matter by Jeffrey B. Rettig, Esquire, Hartman,
Osborne & Rettig, P.C., 126-128 Walnut Street, Harrisburg, PA 17101, telephone (717) 232-3046.
WHEREFORE, Defendant respectfully requests this Honorable Court to enter an Order
compelling Plaintiff to answer Interrogatories and provide all discoverable documents in response
to the Interrogatories and Request for Production of Documents of Defendants.
Respectfully submitted,
HARTMAN, OSBORNE & RETTIG, P.C.
e ey B Rettig, Esq
j p eme Ct. I.D. #19616
'By
126-128 Walnut Street
Harrisburg, PA 1.7101
(717) 232-3046
Attorneys for Defendant
HARTMAN, OSBORNE & RETTIG, P.C.
ATTORNEYS AT LAW
125128 WALNUT STREET, HARRISBURG, PA 17101 • TELEPHONE (717) 232-3046 • FACSIMILE (717) 232-3538
JACK M. HARTMAN
KEVIN E OSBORNE
JEFFREY B. RETTIG
MATTHEW E. HAML N*
CINDY L. NICHOLSON
WADE D. MANLEY
also admitled in New York
Archie V. Diveglia, Esquire
Two Lincoln Way West
New Oxford, PA 17350
December 4, 2003
Re: Helen Bridges v. Glenn S. Lehman
Dear Att iveglia:
WRITER'S EXTENSION: 106
WRITER'S E-MAIL ADDRESS:
jrettig@hoslawpa.com
Enclosed please find Defendant's Interrogatories and Request for Production of Documents
addressed to Plaintiff in the above-referenced matter.
Very truly yours,
JBR/jrs
Enclosures
HARTMAN,-OSBORNE & RETTIG, P.C. ATTORNEYS AT LAW
126-128 WAINUT STREET, HARRISBURG, PA 17101 • TELEPHONE (717) 232-3046 • FACS..E (717) 232-3538
WRITER'S EXTENSION: 106
WRITER'S E-MAIL ADDRESS:
jrd ig@h0S1awpa.00m
January 28, 2004
Archie V. Diveglia, Esquire
Two Lincoln Way West
New Oxford, PA 17350
Re: Helen Bridges v. Glenn S. Lehman
Dear Archie:
We forwarded Discovery to you for Answer by your client in correspondence dated
December 4, 2003. Kindly advise when we can expect receipt Of the Answers and Production of
Documents from Plaintiff.
Thank you.
Very truly yours,
J Rettig`
JBR/jrs i
HARTMAN, OSBORNE & RETTIG, P.C. ATTORNEYS AT LAW
126-128 WALNUT STREEr, HARRISBURG, PA 17101 • TELEPHONE (717)232-3046 • FACSNff E (717) 232-3538
JEFFREY B. RETTIG, ESQUIRE
March 22, 2004
Archie V. Diveglia, Esquire
Two Lincoln Way West
New Oxford, PA 17350
Re: Helen Bridges v. Glenn S. Lehman
Dear Archie:
WRITER'S EXTENSION: 106
WRITER'S E-MAIL ADDRESS:
irettie a),hoslawoacom
As you know, I served discovery on you in December of last year. I still do not have Answers
to the discovery. I understand that may have something to do with some difficulty in securing
information or an affidavit from your client.
In any event, I have been instructed to file a Motion to Compel in 10 days of the date of this
letter ifwe have not received the Answers to discoveryby that time. I look forward to receiving your
answers within that time frame. Best regards.
truly yours,
JBR/sje
CERTIFICATE OF SERVICE
I, Jeffrey B. Rettig, Esquire, hereby certify that I am this day serving a copy of the foregoing
document upon the person(s) and in the manner indicated below, which service satisfies the
requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the
United States mail, first-class postage prepaid, as follows:
Archie V. Diveglia, Esquire
Diveglia & Kaylor, P.C.
Two Lincoln Way West
New Oxford, PA 17350
(Counsel for Plaintiffi
HARTMAN, OS13ORNE & RETTIG, P.C.
Dated: By: Peey ?
Rettig, E ire
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MAY 1 2 2004 P
HELEN BRIDGES,
V.
GLENN S. LEHMAN,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 03-3108 Civil Term
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
ORDER
AND NOW, this /9?'day of M.,J 91 , 2004, after consideration of
Defendant's Motion to Compel Plaintiff to Provide Complete Discovery Responses,
it is hereby ORDERED that Defendant's Motion it GRANTED. Plaintiff must provide
s91
Defendant with complete Discovery responses within :2 0 days ofAthis Order. The failure
of Plaintiff to provide these responses will result in the imposition of sanctions pursuant to
Pa. R.C.P. 4019.
Q
L 1 -.8 ! l'l 01 IV14 h99Z
?bt"tC71d ?H1C7'?o ?Hl a0
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
BRIDGES
Vs.
NO. 0:33108
LEHMAN
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena(s) for documents and things
pursuant to Rule 4009.22 JEFFREY RETTIG, ESQUIRE certifies that:
1. A Notice of Intent to Serve the Subpoena(s) with a copy of
the subpoena(s) attached thereto was mailed or delivered to
each party at least twenty days prior to the date on which
the subpoena(s) is sought to be served,
2. A copy of the Notice of Intent, including the proposed
subpoena(s) is attached to this certificate,
3. No objection to the subpoena(s) has been received, and
4. The subpoena(s) which will be served is identical to
the subpoena(s) which is attached to the Notice of Intent
to Serve the Subpoena(s).
Date: 07/02/04
JEFFREY RETTIG, ESQUIRE
126-128 WALNUT ST
HARRISBURG, PA 17101
717-232-3046
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA PA 19135
(215) 335-3581
File #: M311861
By: Patti. Martin
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
BRIDGES
Vs.
LEHMAN No. 033108
TO: ARCHIE DIVEGLIA, ESQ (PLAINTIFF)
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND TEIINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
DEFENDANT intends to serve a subpoena(s) identical to
the one(s) attached to this notice. You have twenty (20) days
from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is
made the subpoena may be served.
Date: 06/11/04 JEFFREY RETTIG, ESQUIRE
126-128 WALNUT ST
HARRISBURG, PA 17101
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA, PA 19135
(215) 335--3581
By: Patti Martin
Enc(s): Copy of subpoena(s)
Counsel return card
File #: N311861
COMMMWEALTH OF PENNSYLVANIA
ayurY OF CuKBERLAND
BRIDGES
Vs.
LEHMAN
File No. 033108
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
DR MUMMA, 175 LANCASTER BLVD, MECHANICSBURG PA 17055
TO:
Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following.doamants things:
SEE T'rMEMTVAD
at
MEDICAL LEGAL REPRODUCTIONS(A&KSst940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things requested t
this subpoena, together with the certificate of ampliance, to the party making thi<_
request at the address listed above.- You have the right to seek in advance the rea.onable
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 thin, subpoena may seek a court orde+-
Lrnpelling you to oaMly with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: JEFFREY RETTIG, ESQ
ADDRESS: _ 126 1:28 WA13NUT ST
TELEPHONE: -,A 17101
SUPREME OOURT ID # 215-335-3212
,ATTORNEY FOR
DEFENDANT
M311861-01
DATE:,_._
S i of. the Court_
BY THE COURT :
Prothcxiotar / erk, Civil Division
Deputy
(Eff. 7/9T)
ADDENDUM TO SUBPOENA
BRIDGES
Vs.
No. 033108
LEHMAN
CUSTODIAN OF RECORDS FOR: DR MUMMA
ENTIRE MEDICAL FILE INCLUDING BUT NOT LIMITED TO ANY AND ALL
CORRESPONDENCE, OFFICE NOTES, CHART NOTES, COMPUTER NOTES, TESTING
RESULTS AND ANY OTHER DOCUMENT WHATSOEVER CONTAINED IN THE MEDICAL
CHART FROM 1/1/00 TO THE PRESENT.
PERTAINING TO:
NAME: HELEN D BRIDGES
ADDRESS: 2306 N 4TH ST HARRISBURG PA
DATE OF BIRTH: 12/19/64
SSAN: 189545171
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS ARE ATTACHED HERETO.I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date Authorized signature or
DR MUMMA
CUMBERLAND
M311861-01
* * * SIGN AND RETURN THIS PAGE * * *
OOMM3NNFALTH OF PENNSYLVA141A
OOUNry or C AND
BRIDGES
Vs.
LEHMAN
file INo. 033108
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
DR JAMES MILLER, 1711 N FRONT ST, HARRISBURG PA 17102
(Name of Person or Ent
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following documents or things:
SEE ATTAICBED-AD
at
MEDICAL LEGAL REPRODUCTIONStAdTCV9sst940 DISSTON ST., PHILA., PA
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 thia
request at the address listed above. You have the right to seek in advance the rea.onablc-
cost of preoaring 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 thin subpoena may seek a court orde+-
campelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: JEFFREY RETTIG, ESQ
ADDRESS: _ X26 , .moo ,kU,T ST
TELEPHONE: 7PA 17101
SUPREME COURT ID # 215-335-3212
ATTORNEY FOR:
DEFENDANT
M311861-02
_
DATE: ?t(- 2071
Sail of the'Court
BY TFIE COURT :
Pr?o?thonotary/Clerk, ivil Division -
-2_?h Deputy
(Eff. 7/97)
ADDENDUM
TO SUBPOENA
BRIDGES
Vs.
No. 033108
LEHMAN
CUSTODIAN OF RECORDS FOR: DR JAMES MILLER
ENTIRE MEDICAL FILE INCLUDING BUT NOT LIMITED TO ANY AND ALL
CORRESPONDENCE, OFFICE NOTES, CHART NOTES, COMPUTER NOTES, TESTING
RESULTS AND ANY OTHER DOCUMENT WHATSOEVER CONTAINED IN THE MEDICAL
CHART FROM 1/1/00 TO THE PRESENT.
PERTAINING TO:
NAME: HELEN D BRIDGES
ADDRESS: 2306 N 4TH ST HARRISBURG PA
DATE OF BIRTH: 12/19/64
SSAN: 189545171
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date Authorized signature or
DR JAMES MILLER
CUMBERLAND
M311861-02
* * * SIGN AND RETURN THIS PAGE * * *
CU44XMEALTE OF PENNSYLVANIA
OpUNff OF CUNIDERIAIID
BRIDGES
Vs.
LEHMAN
File No. 0g-41 na
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULIE 4009.22
HAMILTON HEALTH CTR, 1821 FULTON ST, HARRISBURG PA 17102
TO:
(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 SEE ATTACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONS4A3dA(7ass4940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things requested t?
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 documents or things required by this subpoena within twenty
(20) days after its service, the party serving this, subpoena may seek a court orde:-
cxxpelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REOUEST OF THE FOLLOWING PERSON:
NAME: TF----Y RFTT1 , ESQ
ADDRESS: _ 126-128 WAtNUT ST
HARRISBURG, PA 17101
TELEPHONE: _
SUPREM COURT ID #____215-335-3212
ATTORNEY FOR:
DEFENDANT
M311861-03
DATE:
S al of the Court
BY TFE OOLJRT:
Protflerk, Civil Division
L° Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
BRIDGES
Vs. I No. 033108
LEHMAN
CUSTODIAN OF RECORDS FOR: HAMILTON HEALTH CTR
ENTIRE MEDICAL FILE INCLUDING BUT NOT LIMITED TO ANY AND ALL
THE MEDICAL
, NOTES, RESULTSOAND ANY OTHEREDOCCUMENT CHART WHATSOEVER CONTAINED IN NOTES, TESTING
CHART FROM 1/1/00 TO THE PRESENT.
PERTAINING TO:
NAME: HELEN D BRIDGES
ADDRESS: 2306 N 4TH ST HARRISBURG PA
DATE OF BIRTH: 12/19/64
SSAN: 189545171
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge:, information and
belief all documents or things above mentioned have been produced.
been made and AVAILABLE: I hereby certify that thorough search
[ ] has DOCUMENTS
been located (CHECK THE APPROPRIATE BOX):.
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date Authorizea signauur
HAMILTON HEALTH CTR
CUMBERLAND
M311861-03
* * * SIGN AND RETURN THIS PAGE * * *
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
BRIDGES
Vs.
NO. 033108
LEHMAN
CERTIFICATE
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena(s) for documents and things
pursuant to Rule 4009.22 JEFFREY RETTIG, ESQUIRE certifies that:
1. A Notice of Intent to Serve the Subpoena(s) with a copy of
the subpoena(s) attached thereto was mailed or delivered to
each party at least twenty days prior to the date on which
the subpoena(s) is sought to be served,
2. A copy of the Notice of Intent, including the proposed
subpoena(s) is attached to this certificate,
3. No objection to the subpoena(s) has been received, and
4. The subpoena(s) which will be served is identical to
the subpoena(s) which is attached to the Notice of Intent
to Serve the Subpoena(s).
Date: 09/01/04
JEFFREY RETTIG, ESQUIRE
126-128 WALNUT ST
HARRISBURG, PA 17101
717-232-3046
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA PA 19135
(215) 335-3581
File #: M313624
By: Patti Martin
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
BRIDGES
Vs.
LEHMAN I No. 033108
TO: ARCHIE DIVEGLIA, ESQ (PLAINTIFF)
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
DEFENDANT intends to serve a subpoena(s) identical to
the one(s) attached to this notice. You have twenty (20) days
from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is
made the subpoena may be served.
Date: 08/11/04
JEFFREY RETTIG, ESQUIRE
126-128 WALNUT ST
HARRISBURG, PA 17101
ATTORNEY FOR DEFENDANT
INQUXRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA, PA 19135
(215) 335-3581
By: Patti Martin
Enc(s): Copy of subpoena(s)
Counsel return card
File #: M313624
OaptuNwFALTH OF PENNSYLVANIA
COUNTY OF C)?fiWRLAND
BRIDGES
Vs. File No. n3310A _,__
LEHMAN
SUBPOENA TO PRODUCE DOaJ-9NTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
T0 DR MALEK MOMIN, 2025 TECHNOLOGY PKWY #201, MECHANICSBURG PA 17050
:
(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:
SEE ATTACHED ADDENDUM
at
MEDICAL LEGAL REPRODUCTIONSFAAWSSA940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the docunents or produce things requested by
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 documents or things required by this subpoena within twenty
(20) days after its service, the party serving thin subpoena may seek a court ordet-
c,:npelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLCWING PERSON-
NAME,.-- TRPRRRY RRTTIG, ESQ
ADDRESS'- 126-128 WALNUT ST
TELEPHONE: HARRISBURG, PA 17101
SUPREW COURT ID t215-335-3212
ATTORNEY FOR:
DEFENDANT
M313624-01
DATE:_--_ ?f Ib
Seal ???fff thpl Court
BY THE OOURT: v ?
tar ---1 y/Clerk; Civ' Division -----
(. ---
Q Deputy -
(Eff.- 7/97)
_ ADDENDUM TO SUBPOENA
BRIDGES
Vs.
LEHMAN
No. 033108
CUSTODIAN OF RECORDS FOR: DR MALEK MOMIN
ENTIRE MEDICAL FILE INCLUDING BUT NOT LIMITED TO ANY AND ALL
CORRESPONDENCE, OFFICE NOTES, CHART NOTES, COMPUTER NOTES, TEST
RESULTS AND ANY OTHER DOCUMENT WHATSOEVER CONTAINED IN THE MEDICAL
CHART SPCIFICALLY***LIMITED***FROM 1/1/00 TO PRESENT
PERTAINING TO:
NAME: HELEN D BRIDGES
ADDRESS: 2306 N 4TH ST HARRISBURG PA
DATE OF BIRTH: 12/19/64
SSAN: 189545171
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
( ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date Authorized signature for
DR MALEK MOMIN
CUMBERLAND
M313624-01
* * * SIGN AND RETURN THIS PAGE * * *
HELEN BRIDGES, IN THE COUR:P OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
NO. 03-3108 Civil Term
GLENN S. LEHMAN,
Defendant CIVIL ACTION - LAW
JURY TRIAL DEMANDED
CERTIFICATE OF DISCONTINUANCE
TO THE PROTHONOTARY:
Please discontinue the above captioned matter. All claims in the
Complaint have been satisfied in full.
Respectfully Submitted,
8v KAYI(gR, P.C.
Date: to-?d-6y
By:
Archie V. Divegl
Attorney I. D. #1
Two Lincoln Wa
New Oxford, PA
(717) 624-2500
Attorney for Plaintiff
Curtis R. Long
Prothonotary
Office of the Protbonotarp
Cumberlaub Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
3 - 31 d CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573