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Home My WebLink About99-04263,.. ,?: ',?' ?, •. V .? ROBERT L. HARTMAN 1 Bungalow Road Enola, PA 17025 Plaintiff V. ZAHURUDDIN SIDDIQUI 3512 Ada Drive Mechanicsburg, PA 17055 Defendant TO THE PROTHONOTARY: AN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, :PENNSYLVANIA NO.: 99 - 041dt-3 CIVIL ACTION - LAW JURY TRIAL DEMANDED Co C r /2nl Kindly issue a Writ of Summons in the above-captioned matter. 4( Dated: July 9, 1999 Andrew J. strowski, Esquire I.D. No. 6 420 Suite 201, 2080 Linglestown Road Harrisburg, PA 17110 (717) 540-9170 Attorney for Plaintiff i r r? r wn LL - F.. O d Cl) J Ccn ny Y? f 11W ;171 U J `^J1 0 v ?N_ Commonwealth of Pennsylvania County of Cumberland Robert L. Hartman Zahuruddin Siddiqui 3512 Ada Drive Mechanicsburg, PA 17055 Court of Common Pleas No. ---- 99 _4263_ C3y}?. FIR---------- 19---- Civil Action_ _ I?w ---------------- To ---- Zahnruddin_Siddiqui------------------ You are hereby notified that ------ Robert- L. -Hartman -------------------------------- --------------- the Plaintiff has commenced an action in ------ Civil -Action- =maw-------------------- against you which you are required to defend or a default judgment may be entered against you. (SEAL) --------- rurtis_R._J ong___------- Prothonotary Date --- ----------------- 19-29 Deputy , s s , , H 1 Ui ? + N CN i II , ? 1 i p a x s f 0 i 3 ? g roo a w ? . ^ ro ? i i n f l 1 .i y? G ;NN', O n O N CG7 A b U i , o yp t3) ? ? i i h g n, t 7 0 *1 A o ,e K ?LO NM i >? co ILO p mr i U; V] y N H r_ SHERIFF'S RETURN - REGULAR CASE NO: 1999-04263 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HARTMAN ROBERT L VS. SIDDIQUI ZAHURUDDIN SHANNON SUNDAY Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon SIDDIQUI ZAHURUDDIN the defendant, at 12:27 HOURS, on the 2nd day of August 1959 at 3512 ADA DRIVE MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to SERENA ZAHURUDDIN (ADULT DAUGHTER) a true and attested copy of the WRIT OF SUMMONS and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 8.68 Affidavit .00 2 Surcharge 8.00 R:-Tfifioma?-KTin?S eri bb 8/0 %1999, SCHIFFMAN by Dep`Snerix x Sworn and subscribed before me this &tk- day of xoQ?i&L John A, Statler, Esquire Attorney 1. D. No. 43912 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Strcet P.O. Box 1269 Harrisburg, PA 17109-1268 Telephone:. (717) 2344161 ROBERT L. HARTMAN, Plaintiff V. Attorney for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 99-4263 CIVIL TERM ZAHURUDDIN SIDDIQUI, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter the appearance of John A. Statler, Esquire of Goldberg, Katzman and Shipman, P.C., on behalf of Defendant Zahuruddin Siddiqui in the above-captioned action. GOLDBERG, KATZMAN & SHIPMAN, P.C. By John A. S tier, Esquire Attorney I. D. No. 43812 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 / Attorneys for Defendant DATE: / L ?3 9 34421.1 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage prepaid on the 3 r day of JDlCr-mJ/,/ 1999, addressed to the following: Andrew J. Ostrowski, Esquire Serratelli, Schiffman, Brown & Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110-9670 GOLDBERG, KATZMAN & SHIPMAN, P.C. By John A. tatter, Esquire Attorney I. D. No. 43812 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney for Defendant ;, ?, ? .-: ?.; ??! ^- )• • ? u' - 1 i ? ? _. L _ i.. L .`.` ?;i (.) ?. John A. Stotler, Esquire Attorney 1. D. No. 43812 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234.4161 ROBERT L. HARTMAN, Plaintiff V. Attorney for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4263 CIVIL TERM ZAHURUDDIN SIDDIQUI, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter a Rule upon the Plaintiff, Robert L. Hartman, to file a Complaint within twenty (20) days or suffer a judgment non pros sec . reg. GOLDBERG, KATZMAN & SHIPMAN, P.C. By: 4 qII: John A. S atler, Esquire Attorney I.D. No. 43812 P. O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 DATE: 12-131? 7 Counsel for Defendant RULE TO PLAINTIFF, ROBERT L. HARTMAN: You are hereby directed to file a Complaint in the above-captioned matter within twenty (20) days or judgment non Los will be entered against you. Date, X IGY Z.( Kq A??' _, d /? Prothonotary CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at r 01 Harrisburg, Pennsylvania, with first-class postage prepaid on the 3 day of D4 ca-S., 1??? 1999, addressed to the following: Andrew J. Ostrowski, Esquire Serratelli, Schiffman, Brown & Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110-9670 GOLDBERG, KATZMAN & SHIPMAN, P.C. By: LV John A. S er, Esquire Attorney I. D. No. 43812 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 "telephone: (717) 234-4161 Attorney for Defendant >- L? ` G, (^ ?- Lr ?_ : ..,! (,1 :: _ ???f.. ? ?"' ?I II„I : -i L• 1...:J ? L i! C.' C'1 Cl ?) C.) c Join) A. Statler, Esquire Attorney 1. D. No. 43812 GOLDBERG, KATZMAN a SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 2344161 ROBERT L. HARTMAN, Plaintiff V. ZAHURUDDIN SIDDIQUI, Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 99-4263 CIVIL TERM JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly file of record the attached Certificate of Service of the Prothonotary's Rule to File a Complaint which was issued on December 7, 1999, and served on the date reflected in the attached Certificate of Service. GOLDBERG, KATZMAN & SHIPMAN, P.C. By: \ John A. tier, Esquire Attorney I. D. No. 43812 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Counsel for Defendant DATE: 12,1q/?9 John A. Stutter, Esquire Attorney 1. 1). No. 43812 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 2344161 ROBERT L. HARTMAN, Plaintiff V. ZAHURUDDIN SIDDIQUI, Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LA" :NO. 99-4263 CIVIL TERM JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I HEREBY CERTIFY that 1 have served a certified copy of the Rule to File Complaint issued by the Prothonotary of Cumberland County on December 7, 1999, upon counsel for Plaintiff, by depositing same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage prepaid on the day of De 010'm }Za? , 1999, addressed to the following: Andrew J. Ostrowski, Esquire Serratelli, Schiffman, Brown & Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110-9670 GOLDBERG, KATZMAN & SHIPMAN, P.C. By: _ John A. tier, Esquire Attorney I.D. No. 43812 320 Market Street, P. O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Counsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that t served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage prepaid on the 9 day of QW2" 64? , 1999, addressed to the following: Andrew J. Ostrowski, Esquire Serratelli, Schiffman, Brown & Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110-9670 GOLDBERG, KATZMAN & SHIPMAN, P.C. By: John A. S atler, Esq Attorney 1. D. No. 43812 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney for Defendant Y ?; C LUG-? .- f Y, a l._? C1 j:J C: ' C,l J I 10' ROBERT L. HARTMAN and AN THE COURT OF COMMON PLEAS TERESA HARTMAN, :CUMBERLAND COUNTY, Plaintiffs :PENNSYLVANIA V. : NO.: 99-4263 ZAHURUDDIN SIDDIQUI, : CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint is 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 petition or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Cumberland County Courthouse Carlisle, PA 17013 1 11 ROBERT L. HARTMAN and TERESA HARTMAN, Plaintiffs v. ZAHURUDDIN SIDDIQUI, Defendant AN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, :PENNSYLVANIA : NO., 99-4263 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED COMPLAINT AND NOW, come the Plaintiffs, Robert L. Hartman and Teresa Hartman, by and through their attorney, Andrew J. Ostrowski, Esquire, and the law firm of Serratelli, Schiffman, Brown & Calhoon, PC, and respectfully sets forth and avers as follows: 1. Plaintiffs Robert L. Hartman and Teresa Hartman, his wife, are adult individuals who reside at 1 Bungalow Road, Enola, Cumberland County, Pennsylvania, 17025 2. Defendant is Zahuruddin Siddiqui, an adult individual who resides at 3512 Ada Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. The facts and occurrences hereinafter stated took place shortlybefore noon on August 6, 1997, at the intersection of SR 1015 (Center Street) and Magaro Road, East Pennsboro Township, Cumberland County, Pennsylvania. 4. At the aforesaid time and place, Plaintiff Robert L. Hartman was traveling south on SR 1015. 5. At the aforesaid time and place, Defendant was traveling North on SR 1015. 6. Defendant, recklessly and without warrant, attempted a left-hand turn across the southbound lane of SR 1015 onto Magaro Road, directly in the path of Plaintiff, creating a sudden emergency. Plaintiff, despite using all reasonable means to do so, could not avoid a collision with Defendant's vehicle which had entered into the intersection without yielding to Plaintiff. 8. Defendant failed to yield the right-of-way to Plaintiff and was cited for a motor vehicle violation as a result. COUNTI 9. Plaintiffs incorporate paragraphs 1-8 of their Complaint as if fully rewritten herein. 10. The accident was the sole and proximate result of the negligence and carelessness of the Defendant. 11. Defendant's negligence consisted of, but was not limited to: a. failing to exercise a high degree of care to see what was visible before turning left onto Magaro Road, or proceeding through the intersection; b. failing to use due care for the rights, safety and position of Plaintiff; C. failing to yield the right-of-way to Plaintiff's vehicle; d. failing to drive the vehicle in such a manner that it could be brought to a stop immediately at the first sign of danger; and e. failing to maintain such control over his vehicle as to enable it to be brought to a safe stop within the assured clear distance ahead. 12. As a direct and proximate result of the aforesaid accident, the Plaintiff suffered injuries to his shoulder and cervical spine with the associated mental anguish and tremendous physical pain and discomfort all of which is continuing in nature. 13. As a direct and proximate result of the accident, Plaintiff has undergone in the past and in the future will continue to undergo great pain and suffering. 14. As a further direct and proximate result of the injuries Plaintiff sustained due to the negligence, carelessness, and recklessness of Defendant, Plaintiff underwent shoulder surgery, was given physical therapy and placed on medication for which he was required to pay significant sums of money and which prevented him from engaging in his usual occupation and activities for a long period, causing, and continuing to cause, him to lose income from his employment and the loss of the enjoyment of life. 15. As a direct and proximate result ofthe Defendant's negligence, Plaintiff has incurred medical expenses in order to cure, heal and alleviate his injuries, pain and suffering and may be obligated to incur additional sums in the future. 16. As a direct and proximate result of Defendant's negligence, Plaintiff has sustained a permanent diminution in his ability to enjoy life and life's pleasures. 17. As a direct and proximate result of Defendant's negligence, Plaintiff has sustained a diminution in his future income earning capacity. WHEREFORE, Plaintiff demands judgment of the Defendant in an amount in excess of an amount requiring compulsory arbitration. COUNT II 18. Plaintiffs incorporate paragraphs 1-17 of theirComplaint as if fully rewritten herein. 19. Defendant's actions were wanton and outrageous in reckless disregard of the laws of the Commonwealth of Pennsylvania and the rights, privileges and interest of those, including the Plaintiff, who were lawfully on the highways. 20. As a result of Defendant's reckless, wanton and outrageous conduct, Plaintiff is entitled to an award of punitive damages. WHEREFORE, Plaintiff demands judgment of the Defendant in an amount in excess of an amount requiring compulsory arbitration. COUNT III 21. Plaintiffs incorporate paragraphs 1 through 20 as if fully rewritten herein. 22. As a direct and proximate result of the negligence, carelessness, and recklessness of Defendant, Teresa Hartman, wife of Plaintiff Robert L. Hartman, has incurred expenses for care and treatment of her husband and has been deprived of the services and society of the Plaintiff causing the impairment of her comfort, happiness, and companionship. VERIFICATION I, Robert L. Hartman, hereby state that I am the Plaintiff herein and that I have reviewed the foregoing Complaint and that the facts stated therein are true and correct to the best of my knowledge, information and belief; and, that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Dated: 1,2-6 . 4 ? ,?e L za-, /9' /0 Robert L. Hartman VERIFICATION I, Teresa Hartman, hereby state that I am the Plaintiff herein and that I have reviewed the foregoing Complaint and that the facts stated therein are true and correct to the best of my knowledge, information and belief; and, that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Dated: aiQQ w. ?., _/} Xf/I7 ?L Teresa Hartman WHEREFORE, Plaintiff demands judgment of the Defendant in an amount in excess of an amount requiring compulsory arbitration. Dated: December 22, 1999 L:\HOMMNDY\HARTMAN\COMPLAIN Respectfully submitted SERRATELLI, SCHIFFMAN, BROWN & CALHOON, PC By Andrew J. Ostrows , Esquire I.D. No. 66420 Suite 201, 2080 Linglestown Road Harrisburg, PA 17110 (717) 540-9170 Attorneys for Plaintiff ROBERT L. HARTMAN and :IN THE COURT OF COMMON PLEAS TERESA HARTMAN, :CUMBERLAND COUNTY, Plaintiffs :PENNSYLVANIA V. : NO.: 99-4263 ZAHURUDDIN SIDDIQUI, : CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED STIPULATION AND NOW, come the parties, through their Counsel, and stipulate as follows: Plaintiff has agreed to file an Amended Complaint to eliminate the reference in paragraph 8 to a motor vehicle violation and to withdraw the claim for punitive damages in Count H. The parties agree that Plaintiffs reserve any and all rights they have to introduce evidence of any motor vehicle violations that are relevant and material and/or otherwise admissible at the time of trial, and reserve their right to re-institute their claim for punitive damages by further amendment in accordance with the Pennsylvania Rules, if appropriate. John tatter, Esquire I.D. No. q38/Z320 Market Street Harrisburg, PA 17110 (717) 234-4161 Attorney for Defendant Dated: L. J IOMI'.NNIM1IA R'rMA MSTI I' Andrew J. Ostrowski, Esquire I.D. No. 66420 Suite 201, 2080 Linglestown Road Harrisburg. PA 17110 (717) 540-9170 Attorney for P int'ffs Dated: /oC Ol tr cli O wp M ?? Z = ???.... z 'if, u'7' J3 a- 0 U ROBERT L. HARTMAN and :IN THE COURT OF COMMON PLEAS TERESA HARTMAN, :CUMBERLAND COUNTY, Plaintiffs :PENNSYLVANIA V. : NO.: 994263 ZAHURUDDIN SIDDIQUI, : CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint is 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 petition or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Cumberland County Courthouse Carlisle, PA 17013 ROBERT L. HARTMAN and :IN THE COURT OF COMMON PLEAS TERESA HARTMAN, :CUMBERLAND COUNTY, Plaintiffs :PENNSYLVANIA V. : NO.: 994263 ZAHURUDDIN SIDDIQUI, : CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED AMENDED COMPLAINT AND NOW, come the Plaintiffs, Robert L. Hartman and Teresa Hartman, by and through their attorney, Andrew J. Ostrowski, Esquire, and the law firm of Serratelli, Schiffman, Brown & Calhoon, PC, and respectfully sets forth and avers as follows: Plaintiffs Robert L. Hartman and Teresa Hartman, his wife, are adult individuals who reside at 1 Bungalow Road, Enola, Cumberland County, Pennsylvania, 17025 2. Defendant is Zahuruddin Siddiqui, an adult individual who resides at 3512 Ada Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. The facts and occurrences hereinafter stated took place shortly before noon on August 6,1997, at the intersection of SR 1015 (Center Street) and Magaro Road, East Pennsboro Township, Cumberland County, Pennsylvania. 4. At the aforesaid time and place, Plaintiff Robert L. Hartman was traveling south on SR 1015. 5. At the aforesaid time and place, Defendant was traveling North on SR 1015. 6. Defendant, recklessly and without warrant, attempted a left-hand turn across the southbound lane of SR 1015 onto Magaro Road, directly in the path of Plaintiff, creating a sudden emergency. 7. Plaintiff, despite using all reasonable means to do so, could not avoid a collision with Defendant's vehicle which had entered into the intersection without yielding to Plaintiff. 8. Defendant failed to yield the right-of-way to Plaintiff. COUNTI 9. Plaintiffs incorporate paragraphs 1-8 of their Complaint as if fully rewritten herein. 10. The accident was the sole and proximate result of the negligence and carelessness of the Defendant. 11. Defendant's negligence consisted of, but was not limited to: a. failing to exercise a high degree of care to see what was visible before turning left onto Magaro Road, or proceeding through the intersection; b. failing to use due care for the rights, safety and position of Plaintiff; C. failing to yield the right-of-way to Plaintiff's vehicle; d. failing to drive the vehicle in such a manner that it could be brought to a stop immediately at the first sign of danger; and e. failing to maintain such control over his vehicle as to enable it to be brought to a safe stop within the assured clear distance ahead. 12. As a direct and proximate result of the aforesaid accident, the Plaintiff suffered injuries to his shoulder and cervical spine with the associated mental anguish and tremendous physical pain and discomfort all of which is continuing in nature. 13. As a direct and proximate result of the accident, Plaintiff has undergone in the past and in the future will continue to undergo great pain and suffering. 14. As a further direct and proximate result of the injuries Plaintiff sustained due to the negligence, carelessness, and recklessness of Defendant, Plaintiff underwent shouider surgery, was given physical therapy and placed on medication for which he was required to pay significant sums of money and which prevented him from engaging in his usual occupation and activities for a long period, causing, and continuing to cause, him to lose income from his employment and the loss of the enjoyment of life. 15. As a direct and proximate result of the Defendant's negligence, Plaintiff has incurred medical expenses in order to cure, heal and alleviate his injuries, pain and suffering and may be obligated to incur additional sums in the future. 16. As a direct and proximate result of Defendant's negligence, Plaintiff has sustained a permanent diminution in his ability to enjoy life and life's pleasures. 17. As a direct and proximate result of Defendant's negligence, Plaintiff has sustained a diminution in his future income earning capacity. WHEREFORE, Plaintiff demands judgment of the Defendant in an amount in excess of an amount requiring compulsory arbitration. Y COUNT II 18. Plaintiffs incorporate paragraphs 1 through 17 as if fully rewritten herein. 19. As a direct and proximate result of the negligence, carelessness, and recklessness of Defendant, Teresa Hartman, wife of Plaintiff Robert L. Hartman, has incurred expenses forcare and treatment of her husband and has been deprived of the services and society of the Plaintiff causing the impairment of her comfort, happiness, and companionship. WHEREFORE, Plaintiff demands judgment of the Defendant in an amount in excess of an amount requiring compulsory arbitration. Dated: January 10, 2000 L:IHOM E\ANDYVIARTMANCOMPLAIN.AMD Respectfully submitted SERRATELLI, SCHIFFMAN, BROWN & CALHOON, PC BY 4? - Andrew J. Ostrowski, Esquire I.D. No. 66420 Suite 201, 2080 Linglestown Road Harrisburg, PA 17110 (717) 540-9170 Attorneys for Plaintiff 4 'f CERTIFICATE OF SERVICE I, Beverly Conderman, an employee of Serratelli, Schiffman, Brown & Calhoon, P.C., hereby certify that I have served a true and correct copy of the foregoing document by depositing such in the regular U.S. Mail, addressed as follows: John A. Statler, Esquire 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 SERRATELLI, SCHIFFMAN, BROWN & CALHOON, PC By Beverly C nderman Suite 201, 2080 Linglestown Road Harrisburg, PA 17110 (717) 540-9170 Dated: January 11, 2000 C?j H C- c ' CI c7 ? C)Z T , l ., _ 17_ ti: L,J 1"? CL O C) o 3 U w John A. Statler, Esquire Attorney L D. No. 43812 GOLDBERG, KATZMAN & SHIPMAN, EC. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 2344161 ROBERT L. HARTMAN, Plaintiff V. ZAHURUDDIN SIDDIQUI, Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 99-4263 CIVIL TERM JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant hereby 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 were sought to be served; 2) A copy of the Notice of Intent, including the proposed subpoenas, is :attached to this certificate; 3) No objection to the subpoenas has been received; and 4) The subpoenas to be served identical to the subpoenas attached to the Notice of Intent. By: John A. St r, Esquire Attorney I.D. No. 43812 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 DATE: / bo MO Telephone: (717) 234-4161 35583.1 John A. Statlcr, Esquire Attomey 1. D. No. 43812 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234A161 Attorney for Defendant ROBERT L. HARTMAN, Plaintiff V. ZAHURUDDIN SIDDIQUI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 99-4263 CIVIL TERM JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: ROBERT L. HARTMAN, Plaintiff c/o ANDREW J. OSTROWSKI, ESQUIRE Serratelli, Schiffman, Brown & Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110-9670 PLEASE TAKE NOTICE that Defendant, Zahuruddin Siddiqui, intends to serve subpoenas identical to the ones attached to this notice. You have twenty (20) days from the date listed below in which to file on record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoenas may be served. GOLDBERG, KATZMAN & SHIPMAN, P.C. By: p John A. atler, Esquire Date: 12-1111 / 9 Attorney for Defendant C0114X WEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT L. HARTMAN, Plaintiff CIVIL ACTION - LAW V. • File No. 99-4763 ZAHURUDDIN SIDDIQUI, Defendant SUBPOENA TO PRODUM DDC1.hENTS OR THMS FOR DlcrWERY PURSUANT TO RULE 4009.22 TO: COMMUNITY FAMILY MEDICINE CENTER OF SOUTHPOINT, 1305 Middletown Road , Hummelstown, PA Person or Enti Within twenty (20) days after service of this subpoena produce the , you are ordered by the carat to following doctrnents or things: All medical records, medical reports, x-rays, correspondence test reports, test results and office notes perta g to DOB: 11/13/56 SSN• 198-44-8346. it P.C., 320 Market Street, P.O. (Address) You may deliver or mail legible copies of the docunents or produce things requested by his subpoena, together with the certificate of ompliance, to the party making this 'equest at the address listed above. You have the right to seek in advance the reasonable ost of preparing the copies Or producing the things sought. If you fail to Produce the docunents or things required by this subpoena within twenty 20) days after its service, the party serving this subpoena may seek a court order cawallirg you to ccaply with it. HIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: qpE. JOHN A. STATLER, ESQUIRE 70RESS•Goldberg, Katzman 6 Shipman, C. "8 ,Anrrinh.r _.FA_ 17108 1268 % EPHONE: (717) 734-4161 1PREME OOURT ID # 43812 TORNEY FOR: Defendant TE:_( - A- IyJ• Seal of the Cowl (Eff. 7/97) COMMXMEALTH OF PENNSYLVANIA_ COUNPY OF CUMBERIAND ROBERT L. HARTMAN, Plaintiff : CIVIL ACTION - LAW V. File No. og?ar,3 ZAHURUDDIN SIDDIQUI, Defendant SUBPOENA TO anmv pOMgMS I A3S FOR DISOOVERy 1'lpSl1ANT TO FM E 4009.22 TO: BERT EINSTEIN MEDICAL CENTER, 5501 Old York Road, Philadelphia, PA 19141 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: All medical records, medical reports, x-rays, correespondence test reports, test results and office notes pertain ng to DOB: 11113156 SSN• 198-44-8346. _ at SHIPMAN, P.C., 320 Market Street, P. (Address) YOU may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of oonpIianca 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 way seek a court order =r6elIirg you to ca:ply with it. PHIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLI.OWINO PERSON: WE: JOHN A. STATLER, ESQUIRE 'DDRESS.Coldberg, Katzman rr Shipman, .C. Aa= a_ h_uxr_-YA_ 17108-1268 734-4161 UPREM COURT ID # 43812 .TTORNEY FOR: Defendant -p- L Sea of the Court (Eff. -1/97) OCMNDNWEALTH OF PENNSYLVANIA COUNTY OF aftl R AND ROBERT L. HARTMAN, Plaintiff CIVIL ACTION - LAW V. File No. Qg_4263 ZAHORDDDIN SIDDIQUI,-- Defendant SUBPOENA TO PROOLrE DOaJ ENTS OR THINGS FOR DISOOVERY P1IRV ANT TO RULE 4009,22 70: INSTITUTE OF PENNSYLVANIA, 875 Poplar Church Road, Suite 300, Camp Hill, PA c •e a cr rerson or Entity) "?-- Within twenty (20) days after service of this subpoena, you are ordered by the count to produce the following docunentS Or things: All medical records, medical reports, x-rays, correspondence, test reports, teat results and office notes pertain ng to T'L-B'A "Wo SSN: 198-44-8346. at -GOLDBERG, KATZMAN AND SHIPMAN, P.C., 320 Market Street, P (Address) You may deliver or mail legible copies of the docunents or produce things requested by this subpoena, together with the certificate of om pliance, 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 twenty (20) days after its service, the party serving this subpoena may seek a court order caroalIing you to ca. ly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JOHN A. STATLER, ESQUIRE ADDRESS: Goldberg, Katzman S Shipman, C. . 8 Anrria_ljLrg,_y& 1710817108_1268 TELEPHONE:. 4717) 234-4161 SUPREME COURT ID 1143812 ATTORNEY FOR: Defendant DATE: G. oLd- l 91 Seal of the court (Eff. 7/97) COK43NWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT L. HARTMAN, Plaintiff CIVIL ACTION - LAW V. File No. qq-4 6-4 ZAHURDDDIN SIDDIQOI. Defendant ' SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISODWRY PURSUANT TO RULE 4009.22 TO: COMMUNITY GENERAL OSTEOPATHIC HOSPITAL, 4300 Londonderry Road, Harrisburg, PA 17109 Person or Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: All medical records, medical reports, x-rays, correanondence,_test reports, test results and office notes pertain ng to , DOB: 11/13156 SSN: 198-44-8346. - at _(WLDBERG, KATZMAN AND SHIPMAN, P.C., 320 Market Street, P.O. Box 1268, Narr3sZiuig?71- (Address) You may deliver or moil 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 =rbeliing you to comply with it. [HIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: WE: JOHN A. STATLER, ESQUIRE •DDRESS. Goldberg, Katzman 6 Shipman, P.C- 320 Market . 8 •Anrrt„h,r ._.pA_ 17108-1268 ELEPHONE: (717) 234-4161 UPREM OOURT ID # 43812 1TORNEY FOR: Defendant Seal of tha Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT L. HARTMAN, Plaintiff : CIVIL ACTION - LAW V. File No. Qq-476i ZAHORDDDIN SIDDIQUI, Defendant SUBPOENA TO PROOt DOCLWNTS OR THINr3S FOR OISO VERY PURSUANT TO RULE 4009.22 TO: HEALTHSOOTH SPORTS MEDICINE & REHAB, 450 Powers Avenue, Harrisburg, PA 17109 Person or Within twenty (20) days after service of this subpoena, you are ordered by the court to Produce the following dOttments or things: All medical records, medical reports, x-rays, correspondence, test reports, test results and office notes perta g to , DOB: 11113156 SSN: 198-44-8346. - at _ GOLDBERG. KATZHAH AND SHIPMAN. P.C., 320 Market Street, P.O. Box 1268, Rarr s urg, (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of campliance, to the party making this ^equest at the address listed above. You have the right to seek in advance the reasonable xst 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. (HIS SUBPOENA WAS ISSUED AT THE REQUEST OF 'TILE FOLLOWING PERSON: OM. JOHN A. STATLER, ESQUIRE \DDRESS:Coldberg, Katzman b Shipman, .C. , 8 .warrtabnr _,g_ 17108-1268 ELEPHONE:_(717) 7a4-4161 UPREPE COURT ID tk43812 ,TTORNEY FOR: Defendant 4TE:?f Sea of the Court (Eff. 7/97) COK43NWEALTH OF PENNSYLVANIA COUNTY OF CU?4aER AND ROBERT L. RARTNAN, Plaintiff : CIVIL ACTION - LAW V. File No. .99-4261 ZABORDDDIN SIDDIQOI, Defendant SUBPOENA TO PRODUCE DOCtt•ENTS OR THINGS FOR DISCOVERY m?SUANT TO RULE 4009.22 TO: _SOUTH CENTRAL NEUROLOGIC ASSOCIATES, 805 Sir Thomas Court, Harrisburg, PA 17109 . (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: AU medical records, medical reports, x-rays, to T'L-BB7, correspondence, test reports, test results and office notes pertaining DOB: 11/13156 SSN: 198-44-8346. - at GOLDBERG. KATZMAN AND SHIPMAN, P.C., 320 Market Street, P.O. Box 1268, Barr s urg, (.Address) You may deliver or mail legible copies of the doaments or produce things requested by this subpoena, together with the certificate of ompliance, to the party malting this ^equest at the address listed above. You have the right to seek in advance the reasonable oust of preparing the copies or producing the things sought. If you fail to produce the doaments or things required by this subpoena within twenty ,20) days after its service, the party serving this subpoena may seek a court order =pelIing you to ca, ly with it. oli1S SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: 4RE. JOHN A. STATLER, ESQUIRE ODRESS, Goldberg, Katzman 6 Shipman, .C. , . Sex-1268 11arri_ nbury -y_ 17108-1268 ELEPHONE: (7.17) 244-4161 UPREhE COURT ID it 43812 XTORNEY FOR: Defendant ATE:, ?lllJ? Seal of the Court (Eff. 7/97) O3t2•IONWEALTH OF PEFIIJSYLVAN71{ COUNTY OF C1AMBERLANO ROBERT L. HARTMAN, Plaintiff CIVIL ACTION - LAW V. • ZAApltltnnlN SIDDIQDI, File No. nn-6263 . Defendant S1IBAOEIJA TO PRODt rx WP.PENTS OR THINGS FOR DISOOVERY P( rtareul TO RULE 4009.22 TO: HOLY SPIRIT HOSPITAL, Poplar Church Road, Camp Hill, PA 17011 • lName of Person or Entity) ----- -_ Within twenty (20) days after service of this subpoena, You are ordered by the Court to Produce the following docLnmts or things: All records, medical reports, x-rays, correspondence, test reports, test results and office notes perta n ng to at 198-44-8346. PC., 320 Market Street, P (Address) You may deliver or mail legible copies of the documents or Produce things requested by this subpoena, together with the certificate of ^equest at the address listed above. You have the right to seeek inoadvance the reasonable carPI , the party making this =st of Preparing the copies or Producing the things sought. If you fail to Produce the 20 days after its service, the documents or things required by this subpoena within twenty =Oellirg You to comply with it. Party serving this subpoena may seek a avert order iWIS SUBPOENA WAS ISSUED AT THE REQUEST OF 7W FOt_LCWIN3 PERSON: 1E. JOHN A. STATLER, ESQUIRE E. Goldberg, Katzman 6 Shipman, .C. 8 Aarriah ur -P_ 17108-1268 X94-4761 UPRE7E OOURT ID # 43812 •TTORNEY FOR: Defendant ATE:- 'Zo ! °ll Seal Of the Court (Eff. 7/97) OU44)NWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROBERT L. HARTMAN, Plaintiff CIVIL ACTION - LAW V. File No. gq_4761 ZABURODDIN SIDDIQOI, Defendant SUBPOENA TO PRODLX DOCUMENTS OR THI _ FOR DISOOVERY PURSUANT TO RULE 4009.22 TO: _HOOK-OF-TBE-MONTR-CLUB, 1225 South Market Street Mechanicsburg PA 17055 • (Nana of Person or Entity) - Within twenty (20) days after service of this subpoena, you are ordered by the court to Produce the following doct•rnents or things: All employment records for ROBERT L. HARTMAN, DOB: 11/13/56: SSN: 198-44-8346. at P.C., 320 Market Street, P.O. Box (Address) You may deliver or mail legible copies of the do7ccnploiale ts produce things requested b y this subpoena, together with the certificate of to the party making this request at the address listed above. You have the rtk in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the doalnents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order oosipellirg you to conply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JOHN A. STATLER, ESQUIRE ADDRESS: Goldberg, Katzman 6 Shipman, C. 8 .pATMiwbn o _YA, 17108-1268 TELEPHONE: (712) 994-4161 3UPREPE COURT ID *L43812 ATTORNEY FOR: Defendant ,ATE._ c,- 2L, Seal of the court (Eff. 7/97) COF413NWEALTH OF PENNSYLVANIA OOUMT OF CUMBERLAND ROBERT L. HARTMAN, Plaintiff : CIVIL ACTION - LAW V. File No. J_g_-4763 ZABORDDDIN SIDDIQUI, Defendant SUBPOENA TO PRODUCE DOCLPENTS OR THINGS FOR DIS;0VERY PURSUANT TO RULE 4009.22 TO: ROADWAY EXPRESS INC., 100 Roadway Drive, Carlisle, PA 17013 (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: All employment records for ROBERT L. HARTMAN, DOB: 11/13/56; SSN: 198-44-8346 at GOLDBERG, KATZMAN AND SHIPMAN, P.C., 320 Market Street, (Address) 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 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 doa.ments or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JOHN A. STATLER, ESQUIRE Goldberg, Katzman s Shipman-,-7.C- ADDRESS: 320 MaKket , . . 8 .Harr- ishnr¢._PA 17108-1268 TELEPHONE: (7u) 234-4161 X PREHE OOURT ID # 43812 ATTORNEY FOR: Defendant IATE:_?_ C?` % Z IC Seal of the Court (Eff. 7/97) Ca4CNWEALTH OF* PENNSYLVANIA COUNTY OF CUMBE lUM ROBERT L. HARTMAN, Plaintiff CIVIL ACTION - LAW V. • File No. gg-426-i ZAHURUDDIN SIDDIQHI, Defendant SUBPOENA TO P:1tE DOC1lENTS OR T1 II FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ALLSTATE INSURANCE MUDANY, Catevay Corporate Center, 6345 Flank Drive, Harrisburg, PA 1711 ATTN: LISA TOPACHECR (Name of Person W Entity) --'----- Within twenty (20) days after service of this subpoena Produce the follows you are ordered by the court to n9 docUnents Or things: The first-party PIP file pertaining to 'nBgT- - -L--HA_R'rQWN DOB: 11/13/56, SSN: 198-44-8346 ----- at 320 Market Street, P.O. Box 1268, (Address) Yas may deliver or mail legible this subpoena copies of the doctments or produce things requested by request at , the address together listed the certificate of ca:pliance, to the party making this isted above. You have the right to seek in adv ance the reasonable cost of preparing the copies or Producing the things sought. If you fail to produce the dOcLnents or things required by this subpoena within twenty (20) days after its service, the Party serving this subpoena ney seek a court order canloeliirg you to cOnply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: JOHN A. STATLER, ESQUIRE A6DRESS:w1uberg, Katzman S Shipman, .C. 120-m L .. - 8 .Aarrisbnr -PA- 17108-1268 (717) 236=4161 RIPREIE COURT 10 # 43812 %TTORNEY FOR: Defendant )ATE:- - C y" ?/ Seal of the Lxxj# -f (Eff. 1/97) CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage prepaid on the /011day of J_ br1./ 2000, addressed to the following: Andrew J. Ostrowski, Esquire Serratelli, Schiffman, Brown & Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110-9670 GOLDBERG, KATZMAN & SHIPMAN, P.C. By: John A. S ler, Esquire Attorney I. D. No. 43812 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney for Defendant ., G; c[ N C p - O John A. Statler, Esquire Attorney I. D. No. 43812 GOLDBERG, KATZMAN & SHERMAN, P.C. 320 Markel Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 2344161 Attorney for Defendant ROBERT L. HARTMAN and TERESA HARTMAN, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. :NO. 99-4263 CIVIL TERM ZAHURUDDIN SIDDIQUI, Defendant : JURY TRIAL DEMANDED NOTICE TO PLEAD TO: ROBERT L. HARTMAN and TERESA HARTMAN, Plaintiffs c/o ANDREW L OSTROWSKI, ESQUIRE Serratelli, Schiffinan, Brown & Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110-9670 Attorney for Plaintiff YOU ARE REQUIRED to plead to the within Answer With New Matter within twenty (20) days of service hereof or a default judgment may be entered against you. ZJohnA. RG, KATZMAN & SHIPMAN, P.C. By: t ler, Esquire Attorney I. D. No. 43812 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 DATE: / `Z G Id, d Attorney for Defendant Zahuruddin Siddiqui John A. Statlcr, Esquire Attorney I. D. No. 43812 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234A161 ROBERT L. HARTMAN and TERESA HARTMAN, Plaintiffs V. ZAHURUDDIN SIDDIQUI, Defendant Attomey for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 99-4263 CIVIL TERM JURY TRIAL DEMANDED ANSWER OF DEFENDANT ZAHURUDDIN SIDDIQUI TO PLAINTIFF'S AMENDED COMPLAINT INCLUDING NEW MATTER AND NOW, comes the Defendant, Zahuruddin Siddiqui, by his attorneys, Goldberg, Katzman and Shipman, P.C., who file the following Answer and New Matter in response to the Plaintiffs' Amended Complaint: 1. Denied. After reasonable investigation, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments in this paragraph and, therefore, denies the same and demands strict proof at time of trial if deemed material. 2. Admitted. Admitted. 4. Admitted. Admitted. 6. The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, it is admitted that the accident occurred as Defendant Siddiqui was making a leRhand turn from S.R. 1015 onto Magaro Road. The balance of the averments are denied as conclusions of law. It is admitted that the Plaintiff did not avoid the collision with the Defendant's vehicle. The balance of the averments are denied as conclusions of law. 8. The averment in this paragraph constitutes a conclusion of law to which no response is required. COUNTI 9. Defendant incorporates by reference his answers to the averments in paragraphs 1 through 8 of the Plaintiffs Complaint as if set forth at length. 10. The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, it is denied that the accident was the sole and proximate result of the negligence and carelessness of the Defendant. By way of further answer, it is denied that the Defendant was negligent or careless. 11. The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, it is denied that the Defendant was negligent in: a. failing to exercise a high degree of care to sae what was visible before turning left onto Magaro Road, or proceeding through the intersection; b. failing to use due care for the rights, safety and position of Plaintiff; C. failing to yield the right-of-way to Plaintiffs vehicle; d. failing to drive the vehicle in such a manner that it could be brought to a stop immediately at the first sign of danger; and e. failing to maintain such control over his vehicle as to enable it to be brought to a safe stop within the assured clear distance ahead. 12. The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiffs alleged injuries and damages and, therefore, denies the same and demands strict proof at time of trial if deemed material. 13. The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiff's alleged injuries and damages and, therefore, denies the same and demands strict proof at time of trial if deemed material. 14. The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiff's alleged injuries and damages and, therefore, denies the same and demands strict proof at time of trial if deemed material. 15. The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiff's alleged injuries and damages and, therefore, denies the same and demands strict proof at time of trial if deemed material. 16. The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiffs alleged injuries and damages and, therefore, denies the same and demands strict proof at time of trial if deemed material. 17. The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, Defendant is without information sufficient to form a belief as to the truth or falsity of the averments concerning the Plaintiffs alleged injuries and damages and, therefore, denies the same and demands strict proof at time of trial if deemed material. WHEREFORE, Defendant Zahuruddin Siddiqui respectfully requests that Count I of the Plaintiffs' Amended Complaint be dismissed and that judgment be entered in favor of the Defendant and against the Plaintiffs. COUNT If 18. Defendant incorporates by reference his answers to the averments in paragraphs 1 through 17 of the Plaintiffs' Amended Complaint as if set forth at length. 19. The averments in this paragraph constitute conclusions of law to which no response is required. In the event a response is deemed to be required, it is denied that the Defendant was negligent, careless and reckless and, therefore, denied that the Plaintiff sustained any injuries or damages as a result of any negligence, carelessness or recklessness on the part of the Defendant. WHEREFORE, Defendant Zahurrudin Siddiqui respectfully requests that Count II of the Plaintiffs' Amended Complaint be dismissed and that judgment be entered in favor of the Defendant and against the Plaintiffs. NEW MATTER By way of additional answer and reply, Defendant Zahuruddin Siddiqui raises the following new matters: 20. Some or all of the Plaintiffs' claims are barred in whole or in part by the provisions of the Pennsylvania Comparative Negligence Law and/or by the Doctrine of Comparative Negligence. 21. Some or all of the Plaintiffs' claims are barred and/or are limited by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. §1701, et seq., and especially by §§ 1705 and 1722 of that law. WHEREFORE, Defendant Zahuruddin Siddiqui respectfully requests that the Plaintiffs' Amended Complaint be dismissed and that judgment be entered in favor of Defendant Siddiqui and against the Plaintiffs. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. By: John A. atler, Esquire Attorney I. D. No. 43812 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 DATE: / 12-6100 Attorneys for Defendant Zahuruddin Siddiqui 36046.1 VERIFICATION I, ZAHU4UTN SIDDIQUI, hereby acknowledge that I am the Defendant in this action; that I have read the foregaing document; and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C. S. Section 4904, relating to unswom falsification to authorities. DATE: ?7ANUA9Y 19, -2n6-0 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage prepaid on the z? day of J 2000, addressed to the following: Andrew J. Ostrowski, Esquire Serratelli, Schiffman, Brown & Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110-9670 GOLDBERG, KATZMAN & SHIPMAN, P.C. By: John A. SWTer, Esqul? e., Attorney I. D. No. 43812 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney for Defendant Y to r .J PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHON0TARY OF CUMBERLAND COUNTY Please list the following case: (Check one) ( X ) for JURY trial at the next term of civil court. ( ) for trial without a jury. ----------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (check one) ROBERT L. HARTMAN and TERESA HARTMAN, VS. (Plaintiff) ZAHURUDDIN SIDDIQUI ( X) Civil Action - Law ( ) Appeal from Arbitration (other) The trial list will be called on and OCTOBER 10, 2000 VS. (Defendant) Trials commence on OCTOBER 30, 2000 Pretrials will be held on OCTOBER 18, 200 (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall provide torthwith a copy of the praer_ipe to all counsel, pursuant to local Rule 214.1.) No. 4253 Civil Law 19 99 Indicate the attorney who will try case for the party who files this praecipe: Andrew J. Ostrowski, Esquire Indicate trial counsel for other parties if known: John A. Statler, Esquire - Attorney for Defendant This case is ready for trial. Signed: Print Name: Andrew J. Ostrowski Date: August 2, 2000 Attorney for: Plaintiff ROBERT L. HARTMAN and TERESA HARTMAN, Plaintiffs V. ZAHURUDDIN SIDDIQUI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4263 CIVIL TERM AND NOW, this I I" day of October, 2000, upon relation from John A. Statler, Esq., attorney for Defendant, Defendant's Motion for Trial Continuance and Motion To Compel Vocational Evaluation and Testing is deemed moot. BY THE COURT, Andrew J. Ostrowski, Esq. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110-9670 Attorney for Plaintiffs John A. Statler, Esq. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorney for Defendant J. ?IJ sley Oler, x., J.' moo Cu` oj :rc ?'?' ? i 1 ?. I 4 j 1 John A. Steller, Esquire Attorney I. D. No. 43812 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 2344161 ROBERT L. HARTMAN and TERESA HARTMAN, Plaintiff V. ZAHURUDDIN SIDDIQUI, Defendant AND NOW, this Attorney for Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 99-4263 CIVIL TERM JURY TRIAL DEMANDED ORDER day of 2000, upon Motion of the Defendant, it is hereby ORDERED that this case is continued from the October trial tern. It is further ORDERED that Plaintiff Robert Hartman shall submit to the requested vocational evaluation and testing by Dr. Jasen Walker. BY THE COURT: J. John A. Statler, Esquire Attorney I. D. No. 43812 GOLDBERG, KATZMAN & SHIPMAN. P.C. 320 Market Strect P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 2344161 Attorney for Defendant ROBERT L. HARTMAN and TERESA HARTMAN, Plaintiff V. ZAHURUDDIN SIDDIQUI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 99-4263 CIVIL TERM JURY TRIAL DEMANDED DEFENDANT'S MOTION FOR TRIAL CONTINUANCE AND MOTION TO COMPEL VOCATIONAL EVALUATION AND TESTING AND NOW, comes the Defendant Zahuruddin Siddiqui, by his attorneys, Goldberg, Katzman and Shipman, P.C. who file this Motion for Trial Continuance and Motion to Compel Vocational Evaluation and Testing based on the following: This case arises out of an automobile accident that occurred on August 6, 1997. 2. The Plaintiffs' Amended Complaint was filed in this case on January 11, 2000. 3. On August 2, 2000, the Plaintiffs' attorney listed this case for trial. Thereafter, Plaintiffs' counsel continued to take discovery including the deposition of the Defendant on September 26, 2000. 4. On August 1, 2000, Defendant's counsel was advised by Plaintiffs' counsel that the Plaintiffs will be presenting the testimony of John J. Fritz, an economic expert who will project both the Plaintiffs past lost earnings and impairment of future earning capacity. The Plaintiffs' expert report has not yet been furnished to defense counsel. 5. In anticipation of this expert report, Defendant has requested that the Plaintiff submit to independent vocational evaluation and testing as authorized by Rule 4010.1 of the Pennsylvania Rules of Civil Procedure. (See copy of letter attached as Exhibit "A"). 6. The Defendant's proposed vocational expert, Dr. Jasen Walker, is available to test and interview the Plaintiff on November 1 or November 9, 2000. See copy of letter attached as Exhibit "B"). A copy of Dr. Walker's curriculum vitae is attached hereto as Exhibit "C." The independent vocational evaluation is absolutely necessary to enable the Defendant in this case to properly evaluate and defend against the Plaintiffs' claim of impaired earning capacity. 8. This case is listed for a jury trial for the week of October 30, 2000 in Cumberland County. 9. This is the first time that this case has been listed for trial. 10. Defendant is requesting that the trial be continued to enable the Defendant to obtain the necessary expert vocational evaluation regarding the Plaintiffs' claim of impaired earning capacity. In addition, the Defendant requests a continuance to enable him to obtain and analyze a copy of the Plaintiffs' own expert economic report from Mr. Fritz. 11. Plaintiffs oppose the Defendant's requests for a continuance and for an independent vocational evaluation. WHEREFORE, Defendant Zahuruddin Siddiqui requests this Honorable Court to grant a continuance of this trial and to order the Plaintiff, Robert Hartman, to submit to the requested vocational testing and evaluation by Dr. Jasen Walker. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. B1 v:7 John AStatler, squi Attorney I. D. No. 43812 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant Zahuruddin Siddiqui DATE: C'12iFrl pD 52384.( Exhibit A 0 3211 MARKET STREET • STRAWBERRY SQUARE P.O. BOX 1268 • HARRISBURG, PENNSYLVANIA 17108.1268 717..234.4161 • 717.234.6808 (FAX) JI @GKBLAW.COM (E-MAIL) GOLDBERG. GI?F5 KATZMAN & SHIPMAN, P.C. September 25, 2000 VIA FAX - 540-5481 and FHtST-CLASS MAIL OF COUNSEL F. L86 SHIPMAN Andrew J. Ostrowski> Esquire JOSHUA D. LOCK Serratelli, Schiffman, Brown & Calhoun, P.C. 2080 Linglestown Road ARTHUR L. GOLDBERG Suite 201 (1951-2000) Harrisburg, PA 17110-9670 HARRY B. GOLDBERG (1961-1998) Re: Robert L. Hartman v. Zahuruddin Siddiqui Cumberland County Docket No. 99-4263 Civil Term RONALD M. KATZMAN PAUL J. ESPOSITO Dear Andrew: NEIL HENDERSHOT J. JAY COOPER This letter will confirm our telephone conference this morning concerning THOMAS E. BRENNER my requests for a trial continuance and for vocational testing of Mr. Hartman. It is JOHN A. STATLER my understanding that you are opposing both of these requests. APRIL L. STRAND-KUT'AY GUY H. BROOKS I enclose a copy of a letter from CEC Associates which indicates that Dr. JEFFERSON J. SHIPMAN Jasen Walker would be available on November 1 and November 9, 2000 to JERRY J. Russo conduct the vocational testing and interview of Mr. Hartman. I will be filing a MICHAEL J. CROCENZI Motion with the Court to compel this testing under Rule 4010.1. In the event that THOMAS J. WEBER the Court grants my requests, please check with Mr. Hartman to see whether he ARNOLD B. KOGAN would be available on either proposed date. ROYCE L. MORRIS EVAN J. KLINE, III E. GRUBB lY Yours, JOHN N DELORENZO STEVEN E. CRUBB JOHN R. NINOSKY DAVID M. STECKEL John taller JAS/ch Enclosure cc: Mr. Thomas R. Heim (w/enclosure) (Claim No.: 010170318322;Insuied: Zahuruddin Siddiqui; Date of Loss: 8/06/97) 34923.14 CARLISLE OFFICE: 717.245.0597 • YORK OFFICE: 717.843.7912 Exhibit B ULI LJ VU IIVII IJ - IJ vi.U .. ? v uw „-, „--------- PMB 23 1220 Valley ForgoRoao,unit 9 ASSOCIATES INCORPORATED P.O. Box 911 (610) Forge. PA 19482-0911 (610) 933.7560 / FAX (6 (6110) 935•5550 I•lNJ0-240.9767 E-mail: CECOCECASSOC.COM VIA FACSIMILE September 25, 20oo John A. Stntler, Psquire Gol(lbcrg, Katzman & Shipman P.O. Box 1268 Harrisburg, PA 17108-1268 RF: Robert Haruuan v. Erie Insurance Group Dear Mr. Statler: Jason Walker, td.D., C.R.C., C.C.M. Proslomit Esther V. Weiss. M.A., C.R.C., C.C.M. Vice Prn0junt It is my understanding that you are interested in having Robert Hartman scheduled for a vocational evaluation with Dr. Jasen Walker on behalf of the defendant in the above matter. following are two available dates and times in which we may schedule this evaluation: Wednesday, November 1, 2000-12:30 p.m, Thursday, November 9, 2000 - 9:30 a.m. Please know that this evaluation will take approximately four (4) hours. The interview portion of the evaluation Trill take approximately 1.5 hours. Dr. Walker will spend the remainder of tints conducting vocational testing. I look forward to hearing from you to confirm one of the above dates. In the interim, if you should requite any further assistance, please feel free to contact me directly. truly yours, Associates, Inc. Assistant 'Human Ways to Make the New Technologies Work' Consultants In Disability Management and Prevention Programs HTTP:// W WW.CECASSOC.COM Exhibit C SEP-26-00 TUE 13:15 CEO ASSOC INC FAX NO, 6109355556 CURRI U A VITAE Jasen M. Walker, Ed.D., C.R.C., C.C.M. CEC Associates, Inc. PMB 23 1220 Valley Forge Road, Unit 9 P.O. Box 911 Valley Forge, PA 19482-0911 Telephone: (610) 935-7560 Suite 2106-The Sterling 6767 Collins Avenue Miami Beach, FL 33141 (305) 865-2602 F-PLICAMN B.S. Science, Kutztown State College, 1971 M. Ed. Counseling, Kutztown State College, 1973 Ed-D. Educational Psychology, Temple University, 1982 .FM LQ?YMF,N?' P. 02 3/83 Djf?or of Serv(cq, CEC Associates, Inc., Valley Forge, PA and Present Miami FL. Service Company providing Vocational Consultation and Education to individuals, business and industry. Disability Management Programs; Health and Rehabilitation; Psychometric Evaluation; Life Care Planning; Counseling Services; Management Training; Succession Planning and Career Development; Training Seminars and Workshops. 7181-3/83 4(r_oct?r of Rehabilitation, Crawford Rehabilitation Services, Inc., Bala Cynwyd, PA. Branch office providing Comprehensive Vocational Rehabilitation and Medical Care Coordination Services; Psychometric Evaluation; Employee Assistance Programming. 1979-1981 pirQSiar of Rehabilitation, Crawford Rehabilitation Services, Inc., Kingston, PA. 1976-1979 PIE" or and Chief Consultant, The Center for Creative Change, Allentown, PA. Provision of Organizational Development and Diagnosis to business and Industry. Management Training, Rehabilitation Counselor Training, and Human Relations Training; Seminars and Workshops. SEP-26-00 TUE 13:16 CEO ASSOC INC FAX NO. 6109355556 P,03 Curriculum Vitae of Jasen M. Walker, Ed.(). Page 2 Employment (cont'd) 1976-19%'7 Agt?cy Pr ? Schnecksville, PA Lehigh County Community College, Planning and Development of short term education programs for community agencies dealing with Family Therapy, Alcoholism Treatment, and Vocational Rehabilitation. Grantsmanship for the college. t4r of_ Prev?Rti4t]_ nd Ed ation, Lehigh County 1974-1976 J?Jr-Qg Council on Alcohol and Drug Abuse, Allentown, PA, Comprehensive treatment of chemically related diseases and disabilities. Group and Individual Therapy with poly-drug users. Vocational Evaluation and Job Placement. Primary Prevention and Secondary Intervention to schools and businesses. 1973-1974 D_LttfXA_QUQgU ns tor, North County Life Line, Vista, CA. Provided Counseling Services to youth, young adults, and families in crises; Hotline Telephone Counseling; Prevention Programs to schools, businesses, and industries. P R0oF E U19 NA1__ M_kMft_E R 0 t U American Psychological Association National Rehabilitation Association National Rehabilitation Counselor Association Pennsylvania Rehabilitation Association Pennsylvania Counseling Association American Rehabilitation Association American Rehabilitation Counseling Association American Association for Counseling and Development Greater Philadelphia Pain Society American Association for the Advancement of Science AP.P.QIrNT_mEN'ra,.CERTiFiCATl S ANDLICENSE? Licensed Rehabilitation Counselor for the State of New Jersey, #RCp1568, 1999. Diplomate - The American College of Forensic Examiners, 1996 to present. Sonlor Disability Analyst and Diplomate - American Board of Disability Analysts, 1996 to present. Certified Case Manager (CCM), I.D.#05783, November 1993 to present. SEP-26-00 TUE 1316 CEO ASSOC INC FAX NO. 6109355556 P.04 Curriculum Vitae of Jasen M. Walker, Ed.D. Page 3 Appointments, Certifications and Licenses (cont'd) Rehabilitation Counselor - U.S. Department of Labor, Office of Workers' Compensation Programs, 1985 to 1989 Vocational Expert for Social Security Administration, Bureau of Hearings Appeals, 1979 to present. and Certified Rehabilitation Counselor- Certificate No. 12868, 1978 to present. Teaching Associate - Assigned to the College of Education, Temple University, 1976 to 1978. Instructor •- Villanova University; Graduate School, College of Education and Human Servicos - Rehabilitation Courses, 1992 to 1995. Diplomate - American Board of Vocational Experts, January 1986 to present. Vocational Expert - United States Railroad Retirement Board, Bureau of Hearin Appeals, June 1986 to present. gs and Clinical Associate - American Board of Medical Psychotherapists, November 1986 to prosent. Nominated to Member of National Distinguished Service Registry, Library of Congress, 1987. Certified Managerial Mediation Trainer - Mediation Training Institute (International), Connecticut, USA, March 1988 to present. I icensed Rehabilitation Provider - State of Florida, No. XA0002674, 1988 to 1992 Certified Benchmarks Consultant - Center for Creative Leadership, 1991 to present. Villanova University, College of Nursing - Member of Advisory Committee on Case Management, 1994 to present. DQQT4RAL RUS?A[2CH 'A Study in Exploring the Effects of Communication Skills on Trainers' Attitudes and Dogmatism," 1982. SEP-26-00 TUE 13:17 MEDIA CEO ASSOC INC FAX NO. 6109355556 P. 05 Curriculum Vitae of Jasen M. Walker, Ed,D. Page 4 The Sociological and Psychological Dynamics of Injured Worker Care" - Interview with William Bailey, CPCU, J.D., sponsored by the National Council on Compensation Insurance (NCCI) for the Insurance Broadcast System, New York City, April 27, 1998. Broadcast interview Program: "Perspective" - WpVI Channel S. "The Americans with Disabilities Act," February 1992. "Employment and Disability Management Under the Americans with Disabilities Act," September 1992. PURIS.AWN.$ Associates, Inc., Valley Forge, Pennsylvania (January 1994), i bcm, CEC PAPT.Ra- UTTRN AND PRESENTED "Changing the Organizational Politics of Disability," presented at the 2000 Amerlenn Association of Occupational Health Conference (AOHC), May 18, 2000. "Practice Management - From Vocational Expert to Disability Manager," presented at the American Board of Vocational Experts Fall Conference, October 1, 1999. "Disability Management and the Disability-Prone Employee," presented at the American Board of Vocational Experts Fall Conference, October 2, 1999. "The Disability-Prone Employee: Disability Without Disease," presented at the Pennsylvania Self-Insurers' Association Annual Seminar, June 25, 1999. Submitted for publication, 1999. "A Team Approach to Taking Full Advantage of Act 57," presented at the Pennsylvania Workers' Compensation Law Seminar, April 21, April 22, April 23, 1999. "Understanding Disability: A Lexicon." Published in.Risk Manaoe nent November 1998. "The Right and Benefit of Vocational Examination in Pennsylvania and Federal Courts." co-authored with David Ira Rosenbaum, Esquire. Published October 1998, in the Psnnsy,Imnia.@a_rA%saQClation Ouartjajy. SEP-26-00 TUE 13:17 CEO ASSOC INC FAX NO, 6109355556 P.06 Curriculum vitae of Jasen M. Walker, Ed.0. Pane 5 Papers Written and Presented (cont'd) 'Vocational Testimony in Pennsylvania Workers' Compensation Cases: Pre-Kacfilnski, Post-Kachinski, And Doing It Right Under Act 57." Published in May 1998 for Professional Education Systems, Inc. "Devising Cost-Effective, Reasonable Accommodation Strategies for a Satisfied, Non- Litigious Workplace." Presented at the ADA Update 1997, December 4, 1997, for the Council on Education in Management. "Double Jeopardy: Workers' Comp Act 57 and ADA." Published in Tbg t,Qgpi I.rftIligerLG,wr, Vol. P.3905, June 4, 1997. "The Strengths and Weaknesses of Act 57: What Employers Can Do To Reduce Workers' Compensation." Presented at the Pennsylvania Workers' Compensation Law Seminar, April 8, April 10, April 11, 1997. "What Lawyers Can Do To Control High Cost of Workers' Compensation: A Proactive, Team-Based Solution," published in the Litigation Quarterly, May 13, 1996. "Disability Management: Fixing The Broken Paradigm, published in ??R?YioSH, Winter 1996. "Well-Managed Companies and Their Support of Disability Management Programs," co- authored with Fred Heffner, Ed.D., published in In Tha nnatn¢+re December 1995. "10 Tips for Disability Management Programs," published in 2)is na ant, June 1995. "Workers' Compensation Case Law: A Hidden Opportunity for Pennsylvania Employers," published by Penns Iv ia_,Self-Insurers Asc ciation, March 1995. "In the Blink of An Eye: What Business Leaders Still Do Not Understand About the ADA," co-authored with Fred Heffner, Ed.D., published in in The MWn&)nm, March/April 1995, "The Different Responsibilities of National and Community-Based Advocacy Groups," co-authored with Fred Heffner, Ed.D., published in L January/February 1995. -1? -MpU1S1ftpan,, "Beyond Compliance - On the Road to Controlling Workers' Compensation," published in f3jpk IIl16ftflg0m0nt, October 1994. SEP-26-00 TUE 13:18 CEC ASSOC INC FAX NO, 6109355556 P.07 Curriculum vitae of Jason M. Walker, Fd,t7. Pago e Papers Written and Presented (cont'd) "The Statc-Of-The-Art in Disability Management: Some Considerations for Employers co-authored with Fred Heffner, Ed.D., published In September/October 1994. -Iba_ Mal 6jrg=1 Accommodating Workers Returning from Long-Term Disability," published in pMsln, lrSL3n1, May/June 1994. "Employers, Advocacy Groups, and The ADA," published in March/April 1994. 1lZThgivsttpgnl, "No Work Job Offers Can Run Afoul of The ADA," Published in the June 13, 1994, PeonsylvwLa.!..aw_W , "Unlearning Helplessness," Published in the Fall 1993 Rt;:k@enelltt,LattLnaL 'The Difference Between Disability and Impairment: A Distinction Worth Making," October 1993, published in In The Mainafra? . also in the JQUrnaLQfs2ccupatio I Vol 18, September October 1993, .[l;?-3eh?blli?t{?1r Vol. 3, , No No. 3, 1993. "Job Analysis and Job Accommodation: The Baseline Challenge for Employers in The ADA," co-authored with Fred Heffner, Ed.D., published In lnjhe Malntream, Vol. 18, No.6, November/December 1993. "Increasing Company Profit Through The ADA," co-authored with Fred Heffner, Fd,D., published in )n. ThP?M 'n eam, November 1993. "Workers' Compensation Reform Through Employer Involvement," published in M84ning r4MPIauce Health,-¢gnef?, Summer 1994. "The Future of Disability Management: A Case For Disability Management Programs in The Workplace," co-authored with Fred Heffner, Ed.D., published in 11-Thq. Vol. 18, No.4, July/August 1993. itlstl=7r1, "How to Deal with injured Employees - Meeting Your ADA Obligations," prepared for the Institute of Business Law, Employment Regulations In Pennsylvania, July 13, 14 1993. "The ADA and Conflict Resolution," co-authored with Fred Heffner, Ed.D., publishod in In Th?Ma i s ant, Vol. 18, No.3, May/June 1993. "rhe ADA and The Pennsylvania Workers' Compensation Act: Not Friends in Pennsylvania," published in The Legal Int i r, Vol. 208, No.45, March 9, 1993. SEP-26-00 TUE 13118 CEO ASSOC INC FAX NO, 6109355556 P.08 Curriculum Vitae of Jasen M. Walker, Erf.D. Page 7 Papers Written and Presented (cont'd) "Injured Worker Helplessness: Critical Relationships and Systems Level Approaches for Intervention," published in the Journal, I ?, Vol. 2, No.4, December 1992. "The Americans With Disabilities Act and Workers' Compensation," published in the C.P,Q'cU.JouCnal, September 1992. "The Americans With Disabilities Act and The Rehabilitation Case Manager," publishod in lb.v GB,sp Ntpnac=, September 1992. 'The Impact of The ADA on Vocational Rehabilitation of Industrially-Injured Workors Under Workers' Compensation," adapted from In The Mai , January/February 1992. "Recent Court Rulings Fan Tensions Between Injured Workers and Employers," Vol. XIV, No.22, Pg.4, published in the Peg0s0yania Law Journal) Reop,Qe , June 10, 1991. "Vocational and Physical Rehabilitation of Heart Attack Victims Under the Longshore and Harbor Workers' Compensation Act," published in ,9tmaa. Heart .Qa(dQ.ya$r,U)ar_Djgease in aG Arisingtnrter the Lonashrrp and HarbQr_' A kS.„fsl?d GOruP(, ;r1,6(zt: (The Work Stress Institute, Philadelphia, PA April 1990)). Y1141k9rS_ "Disabler: A Game Rehabilitation Professionals Play," Vol. 3, No.3 and 4, December 1988, published in ,journal of Priivate Sector Rehabilitation "Risk Management: Dealing with Criticism," published in the j31 k lyanagoitOLAarw;tl, the Underwriter Printinc and Publishing Company, April 1988. "Criticism in Our Personal and Work Lives," presented to National Risk Management Insurance Agents, January 13, 1988. "Assessing the Loss or Occupational Injury and Disease: Other Perspectives for the Risk Manager," published in the Risk a .gggment nnuaj, the Underwriter Printing and Publishing Company, April 1987. "Psychological Impact of Injury on the Worker," presented to Industrial Medicine Seminar, Good Shepherd Rehabilitation Hospital, Allentown, Pennsylvania, October 1986. "Workers' Compensation and the Learned Helplessness Paradigm," February 1985, presented to the Industrial Medicine Seminar, Good Shepherd Rehabilitation Hospital, Allentown, Pennsylvania, October 1988. Revised in July 1991 and published in the .Ce.PQQ J.gurnal, June 1992. SEP-26-00 TUE 13 19 CEO ASSOC INC FAX NO. 6109355556 P.09 Curriculum Vitae of Jasen M. Walker, Ed.D. Page 8 Papers Written and Presented (cont'd) "Rehabilitation of the Reactively Depressed Injured Worker - A Case Study," presented to the Psychiatric Staff of the Pennsylvania Hospital, January 1985. "Psychology of Retraining," published in L[Opital Insurance Newc_ T? Pall 1985. "Use of The Job Analysis in Private Rehabilitation," 1993. "The Altributional Styles of The Urban Employed," Temple University, 1978. the Development of A Human Services Training Consortium," presented to the National Urban Education Conference, Philadelphia, Pennsylvania, November 1978. "The Prevention of Substance Abuse in Lehigh County, Pennsylvania," obtainable from the Lehigh County Commission on Alcohol and Drug Abuse, Allentown, Pennsylvania, 1976. E1Q MONAI.-W8,511=NCE Consultant - to numerous organizations, manufacturers' associations, and business groups regarding the Americans With Disabilities Act, Family and Medical Leave, and Disability Management. Instructor- Villanova School of Nursing, 1996 to present. Instructor - Villanova University, Department of Counselor Education, 1992 to present. Instructor - Pennsylvania Sate University, Department of Counselor Education, 1975 to present, Instructor - Temple University, Department of Psychoeducational Processes, 1976 to 1992. Consultant - L ehigh County Human Services Training Consortium, 1975 to 1981. Trainer - Theoretical and practical aspects of rehabilitation in the private sector. Vocational diagnosis and assessment of residual employability, counseling, job analysis, job modification, job placernent, medical approaches to disability - Philadelphia, Pennsylvania, 1982. Consultant - U81ion_21sk Mana en , Return to Work Program, 1985 to 1989. SEP-26-00 TUE 13;19 CEO ASSOC INC Additional Experionce (cont'd) FAX NO. dIU93bbbbb N, l u Curriculum Vitae of Jasen M. Walker, Ed.D, Pago 9 Chief Editor - "The New Worker" - a quarterly bulletin for those concerned with human factors In the work environment. Editorial Committee Member and co-author of Pennsylvania Workers'moepsati?p Caijide, published by the Pennsylvania Chamber of Business and Industry, 1993 to present. &QNTJNYIRQ.F,D ATIDN (partial listing) Drug Abuse Prevention, San Diego State University; 6 weeks, 1973. Gestalt Thorapy Techniques, Vista, California; 12 weeks, 1974. Group Psychotherapy Training, Allentown, Pennsylvania; 24 weeks, 1974-1975. Family'rherapy Practicum, Allentown State Hospital; 18 weeks, 1975. Alcoholism and Treatment, Eagleville Hospital; 50 hours, 1975. Psychosynthesis and Values Exploration, Madison, Connecticut; 60 hours, 1976. Reevaluation Counseling Training, Temple University; 32 weeks, 1977-1978. Social Security Disability Analysis, Social Security Administration, Pittsburgh, Pennsylvania, 1978. Dealing with Stress in Organizations, Temple University; 18 hours, 1979. Management of Rehabilitation Nursing Services, Atlanta, Georgia; 18 hours, 1980. Vocational Diagnosis and Assessment of Residual Employability, Atlanta, Georgia, 1981. Fmployoe Assistance Programs, Atlanta, Georgia, 30 hours, 1982. Luria.-Nebraska Neuropsychological Battery, Pennsylvania Psychological Association, Harrisburg, Pennsylvania; 7 hours, 1984. Rohabllitation Counseling Processes and Procedures, U.S. Department of Labor; Philadelphia, Pennsylvania; 16 hours, 1985. Social Security Disability, Dickinson School of Law; 8 hours, November 14, 1986. SLP-26-UU IUL I.i:N ULU R55UU INU Continuing Education (cont'd) rnn Nu. otudaooooo r.II Curriculum Vitae of Jasen M. Walker, Ed.D. Page 10 Managerial Mediation Training, Mediation Training Institute; 16 hours, February/March 1988. 1988 American Board of Vocational Experts Annual Conference, American College of Vocational Experts; Tampa, Florida; 14 hours, March 1988. Returning The Difficult Patient to Work: Comparative Program Perspectives, Good Shepherd Rohabllitatlon Hospital Industrial Medicine Seminar, Allentown, PA: 11 hours, October 1988. The 16 Personality Factor Questionnaire, Cleveland State University; 6 hours, March 1990. Donchrnarks Feedback Training, Center for Creative Leadership; Greensboro, North Carolina; 18 hours, September 1991. Managing Your Workers' Compensation Costs; Pennsylvania Chamber of Business and Industry, Harrisburg, Pennsylvania, 1993, Structuring an Effective Light Duty Program; Pennsylvania Self-Insurer's Assoclatlort; 1995. Pain Management - Practice and Performance; American Pain Society; 1995. Workers' Compensation 303: The Latest Information and Techniques for Workers' Compensation Professionals; Pennsylvania Chamber of Business and Industry, Harrisburg, Pennsylvania, September 1997. Advanced Understanding to Protect your Company; Workers' Compensation Professionals Conference, Pennsylvania Chamber of Business and Industry, Harrisburg, Pennsylvania, September 1998, Practice Management - From Vocational Expert to Disability Manager/Disability Management and the Disability-Prone Employee; presented at the American Board of Vocational Experts Fall Conference, Pittsburgh, Pennsylvania, October 1999. Disability Proneness: What Employers, Claims Handlers, Case Managers, and Defense Lawyers Can Do To Reduce the Losses; 13th Annual Pennsylvania Workers' Compensation I.aw Seminars, April 2000. Non-Medical Examination under the Pennsylvania Rules of Civil Procedure; eo- prosenter at the 7'h Annual Personal Injury Institute, April 2000. Labor and Employment Law Seminar; Americans with Disabilities Act: "Reasonable Accommodations" and "Interactive Process"; June 2000. StN-'b-UU WE ld:Lu ULU hbbUU INU Continuing Education (cont'd) rHA NU. blUyubbbbb r. le Curriculum Vitae of Jasen M. Walker, Ed.D, Page 11 How To Effectively Represent Your Client in a Vocational Assessment Case; co- presonter at the Bucks County Bar Association; August 2000. CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all parties or counsel of record by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage prepaid on the Z 6 day of , ' 2000, addressed to the following: Andrew J. Ostrowski, Esquire Serratelli, Schiffman, Brown & Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110-9670 GOLDBERG, KATZMAN & SHIPMAN, P.C. By: -- - John A. $tatler, Esqui Attorney I. D. No. 43812 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorney for Defendant C' r C. G_ .L ROBERT L. HARTMAN and TERESA HARTMAN Plaintiffs V. ZAHURUDDIN SIDDIQUI, Defendant :IN THE. COURT OF COMMON PLEAS :CUMBERLAND COUNTY, :PENNSYLVANIA : NO.: 99-4263 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly mark the above matter settled, discontinued and ended, with prejudice. SERRATELLI, SCHIFFMAN, BROWN & CALHOOIy PC Andrew J. trowski, Esgb& -- I.D. No.: 624422'0 Suite 201, 2080 Linglestown Road Harrisburg, PA 17110 (717) 540-9170 Attorney for Plaintiffs Dated: October 31, 2000 L:?=..sW IARTMANT.mpe.dis.dm CERTIFICATE OF SERVICE 1, Beverly Conderman, an employee of Senatelli, Schiffman, Brown & Calhoon, P.C., hereby certify that I have served a true and correct copy of the foregoing document by depositing such in the regular U.S. Mail, addressed as follows: John A. Statler, Esquire 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 SERRATELLI, SCHIFFMAN, BROWN & CALHOON, PC By " l yt dz&' ? Beverly Conderman Suite 201, 2080 Linglestown Road Harrisburg, PA 17110 (717) 540-9170 Dated: November 1, 2000 LLl _ I. I RC cf) ? .? X71 v "C