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Home My WebLink About99-04672UPW .. 17 Hoffer BRENDA K. BRYNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. 99-4672 CIVIL TERM IAN F. HEVERLY, CIVIL ACTION - LAW Defendant IN RE: PRETRIAL CONFERENCE A pretrial conference was held on Wednesday, October 18, 2000, before the Honorable George E. Hoffer, President Judge. In this auto accident case, Richard A. Sadlock, Esquire, represents the plaintiff, and Jefferson J. Shipman, Esquire, represents the defendant. Plaintiff was a passenger in a vehicle driven by a friend. Defendant was on the public roadway driving in the opposite direction and at an icy point in the road, defendant lost control of his car crossing the center line striking the vehicle in which plaintiff was a passenger. Nevertheless, defendant claims that the accident was unavoidable because of the road conditions and will be requesting a charge to that effect. The Court directs that any charge along those lines be prepared and furnished to the trial court and defense counsel by October 25, 2000, so that plaintiff's counsel can respond at the outset of the trial. 99-4672 Civil Term Pretrial Conference Page 2 Plaintiff's medical testimony is already on videotape to be presented at trial and the defense will be taking medical testimony in the very near future, also to be presented by videotape. Each party has examined the witness list and exhibit list of the other party as contained in the pretrial memorandum and no objections have been raised to the Court. Is it estimated the case will take a day and a half at the most to try with four challenges each, and the Court directs that Richard Sadlock be attached for this trial, and we request the Court Administrator to list this case first in Courtroom Number Three or in any other courtroom should scheduling changes be made. By the Court, AIAA G of er, P.J. Richard A. Sadlock, Esquire For the Plaintiff Court Administrator Jefferson J. Shipman, Esquire P.O. Box 1268 Prothonotary Harrisburg, Pa. 17108-1268 For the Defendant :mtf ?. . r .i ? , BRENDA K. BRYNER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 9 IAN F. HEVERLY, Defendant 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 judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE 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 Carlisle, PA 17013 (717) 249-3166 1 BRENDA K. BRYNER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. IAN F. HEVERLY, Defendant JURY TRIAL DEMANDED NOTICIA Le ban demandado a usted en la cone. Si usted quiere defenderse de estas demandas expuestas en las paginas sugnuientes, usted tiene viente (20) dias de 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 cone en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la cone 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. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEPFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 BRENDA K. BRYNER, Plaintiff V. IAN F. HEVERLY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-yG7.zC? Tr-- JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Brenda K. Bryner is an adult individual and a citizen of the Commonwealth of Pennsylvania who resides at 215 Second Street, West Fairview, Cumberland County, Pennsylvania. 2. Defendant Ian F. Heverly is an adult individual and a citizen of the Commonwealth of Pennsylvania who resides at 73 Sharon Road, Enola, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or about December 31, 1997, at approximately 4:15 p.m. on Center Street, East Pennsboro Township, Cumberland County, Pennsylvania. 4. At that time and place, Plaintiff Brenda K. Bryner was a passenger in a 1986 Ford Bronco being driven by Michael J. Paul. 5. At that time and place, the Paul vehicle was travelling in a northerly direction on Center Street, Cumberland County, Pennsylvania. 6. At that time and place, Defendant Ian F. Heverly was operating a 1989 Honda Civic in southerly direction on Center Street. 151860/LC2 7. At that time and place, Defendant Ian F. Heverly, while attempting to drive around a right curve, lost control of his vehicle, crossed the center line, and violently struck the left side of the Paul vehicle, in which Plaintiff Bryner was a passenger. 7. As a result of the violent impact, the Paul vehicle was forced down the embankment on the right side of Center Street, and Plaintiff was violently thrown back and forth impacting sharply on the right side of the vehicle. 8. As a result of the violent impact, Plaintiff Brenda K. Bryner sustained serious injuries set forth hereinafter. 9. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff Brenda K. Bryner are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant Ian F. Heverly operated his motor vehicle as follows: (a) failure to drive his vehicle in its proper lane of travel and crossing over the center dividing line of the highway into oncoming traffic; (b) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (c) failure to stay within his lane of travel; (d) failure to apply his brakes in sufficient time to avoid striking the Paul vehicle head-on; (e) failure to travel at a safe speed; (f) failure to keep a proper watch for traffic on the highway; 2 (g) failure to drive his vehicle with due regard for the highway and traffic conditions which were existing and of which he was or should have been aware; (h) failure to keep proper and adequate control over his vehicle; and (i) driving his vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 10. Plaintiff Brenda K. Bryner sustained painful and severe injuries which include but are not limited to cervical spine strain/sprain, right shoulder strain, right cervical radiculitis, occipital neuralgia, and traumatic synovitis of the right acromioclavicular joint. 10. By reason of the aforesaid injuries sustained by Plaintiff Brenda K. Bryner, she was forced to incur liability for medical treatment, medications, hospitalizations and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 11. Because of the nature of her injuries, Plaintiff Brenda K. Bryner has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 12. As a result of the aforementioned injuries, Plaintiff Brenda K. Bryner has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 3 13. As a result of the aforesaid injuries, Plaintiff Brenda K. Bryner has been and in the future will be subject to great humiliation and embarrassment, and claim is made therefor. 14. As a result of the aforementioned injuries, Plaintiff Brenda K. Bryner has sustained uncompensated work loss, loss of opportunity and a permanent diminution of her earning power and capacity, and claim is made therefor. 15. Plaintiff Brenda K. Bryner continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefor. WHEREFORE, Plaintiff Brenda K. Bryner demands judgment against Defendant Ian F. Heverly in an amount in excess of Twenty-Five Thousand Dollars ($25,000.00), exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. ANGINO & ROVNER, P.C. Date: August 2, 1999 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff VERIFICATION 1, BRENDA K. BRYNER, Plaintiff, have read the foregoing PLAINTIFF'S COMPLAINT and do swear or affirm that the facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief. 1 understand that this Verification is made subject to the penalties of 18 Pa.C.S.A., Section 4904, relating to unsworn falsification to authorities. Wit Brenda K. Bryner Date:,, f ? I 151958/MLB LL L? r_• 4- ?' v 0 `?% q SHERIFF'S RETURN - REGULAR CASE NO: 1999-04672 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BRYNER BRENDA K VS. HEVERLY IAN F DAWN KELL , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT was served upon HEVERLY IAN F the defendant, at 14:52 HOURS, on the 4th day of August 1999 at 73 SHARON ROAD ENOLA, PA 17025 CUMBERLAND County, Pennsylvania, by handing to CAROL HEVERLY (MOTHER) a true and attested copy of the NOTICE AND COMPLAINT_ and at the same time directing His attention to the contents thereof Sheriff's Costs: So answeGr Docketing 18.00 Service 9.30 Affidavit .00 Surcharge 8.00 omas ine, eri -08%05%19g90VNER by Dpuy 4f- Sworn and subscribed to before me this S5day of _ 19A.D. rocnonorer Jefferson J.Shipman, Esquire I.D. M: 51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendant BRENDA K. BRYNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO 99-4672 CIVIL TERM IAN F. HEVERLY, Defendant JURY TRIAL DEMANDED TO THE PROTHONOTARY: PLEASE ENTER the appearance of the undersigned on behalf of the Defendant in the above-captioned matter. GOLDBERG, KATZMAN & SHIPMAN, P.C. f rson J. Ship an, Esquire 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant DATE: q 9 28114.1 28114.1 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been duly served upon the following counsel of record by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, on August 17, 1999: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiffs GOLDBERG, KATZMAN & SHIPMAN, P.C. ..1W ,' V • Jlllj./?14611, LI ?IYLL 320 ar et Street/ Har isburg, PA 17108 Attorneys for Defendant Telephone: (717) 234-4161 Identification No.: 51785 28115.1 L ., ?- ct u_ ON =j ON CJ Jefferson J.Shipman, Esquire I.D. M: 51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendant BRENDA K. BRYNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. IAN F. HEVERLY, Defendant TO THE PLAINTIFF: NO 99-4672 CIVIL TERM JURY TRIAL DEMANDED You are hereby notified to plead to the enclosed New Matter within twenty (20) days from the date of service hereof, or a default judgment may be entered against you. DATE:?2ti 28101.1 {{{ GOLDBERG, KATZMAN & SHIPMAN, P.C. Jeff rs J. Shipman, Esquire 320 arket Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant 28101.1 Jefferson J.Shipman, Esquire I.D. /: 51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendant BRENDA K. BRYNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. IAN F. HEVERLY, Defendant ANSWER AND AND NOW, comes the Defendan his counsel, Goldberg, Katzman & following Answer and New Matter: NO 99-4572 CIVIL TERM JURY TRIAL DEMANDED NEW MATTER _, Ian F. Heverly, by and through Shipman, P.C., and files the 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 4 and the same are, therefore, denied and strict proof demanded at the time of trial. 5. Admitted. 6. Admitted. 7. Admitted in part, denied in part. it is admitted only that the Heverly vehicle struck the left side of the Paul vehicle. The remaining averments of Paragraph 7 are conclusions of law to which no response is required. If a response is deemed to be required, the averments contained therein are denied. 7. (sic) Denied. After reasonable investigation, Mr. Heverly is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 7 and the same are, therefore, denied and strict proof demanded at the time of trial. 8. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 8 and the same are, therefore, denied and strict proof demanded at the time of trial. 9. Denied. The averments contained in Paragraph 9, subparagraphs (a) through (i) are conclusions of law to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied as stated and strict proof thereof is demanded at the time of trial. 10. Denied. After reasonable investigation, Mr. Heverly is without sufficient knowledge or information to form a belief 2 as to the truth of the averments contained in Paragraph 10 and the same are, therefore, denied and strict proof demanded at the time of trial. 10. (sic) Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 10 and the same are, therefore, denied and strict proof demanded at the time of trial. 11. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 11 and the same are, therefore, denied and strict proof demanded at the time of trial. 12. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 12 and the same are, therefore, denied and strict proof demanded at the time of trial. 13. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 13 and the same are, therefore, denied and strict proof demanded at the time of trial. 3 14. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 14 and the same are, therefore, denied and strict proof demanded at the time of trial. 15. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 15 and the same are, therefore, denied and strict proof demanded at the time of trial. WHEREFORE, Defendant, Ian F. Heverly, respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. NEW MATTER By way of additional answer and response, Defendant, Ian Heverly, interposes the following New Matters: 16. That this action is subject to the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa C.S.A. §1701, et seq. 17. That Plaintiff's claims may be limited or barred by the "Limited Tort" option pursuant to 75 Pa. C.S.A. §1705, et seq. 4 18. That the accident and any injuries sustained by Plaintiff may have been caused in whole or in part by the negligence of third persons or entities not presently involved in this action. 19. That if it should be found that there was any negligence on the part of Defendant Heverly, which negligence is expressly denied, any such negligence was not a proximate cause of any damages to the Plaintiff. 20. That the accident and any resulting injuries were caused in whole or in part by an Act of God or by forces beyond the control of Defendant Heverly. 21. That the accident was unavoidable. 22. That the accident may have been caused by a Sudden Emergency. 23. That if the Plaintiff suffered the injuries alleged in her Complaint, those injuries were caused in whole or in part by the negligence of the Plaintiff and to recover in this action is barred or diminished in accordance with the Pennsylvania Comparative Negligence Act. 29. That the Plaintiff may have assumed the risk of injuries allegedly sustained by her. 5 WHEREFORE, Defendant, Ian F. Heverly, respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. 28099.1 Respectfully submitted, G4eo OLDBERG, KATZMAN & SHIPMAN, P.C. n JShip ma Esquire 1785 P.O. Box 1268 Harrisburg, PA 17108 Attorneys for Defendant Telephone: (717) 234-4161 6 VERIFICATION I, Ian F. Heverly, have read the foregoing Answer and New Matter and hereby affirm that it is true and correct to the best of my personal knowledge, or information and belief. This Verification and statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities; I verify that all the statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa. C.S. §4904. 14n F. Heverly DATE: CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been duly served upon the following counsel of record by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, on August 20, 1999: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiffs GOLDBERG, KATZMAN & SHIPMAN, P.C. Je fe n J. Shipman, Esquire 32 Market Street Harrisburg, PA 17108 Attorneys for Defendant Telephone: (717) 234-4161 Identification No.: 51785 28115.1 >, «> ?- ?,, ?., r. ?, ? ==? ? ?_,. ,,, ?)?::, ? j - r.-? ; ' i!7 C_l .. N ?; Fi: L. _:iiJ 1.11 i U C c? ORIGINAL BRENDA K. BRYNER, Plaintiff V. IAN F. HEVERLY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4672 Civil Term JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO NEW MATTER AND NOW comes the Plaintiff, by and through her attorneys, Angino & Rovner, P.C., and hereby enter the following Reply to the New Matter of Defendant as follows: 16. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, all of Plaintiff's injuries and damages are recoverable in the instant action. The Pennsylvania Motor Vehicle Financial Responsibility Law in no way limits the damages Plaintiff may recover herein. 17. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, the Plaintiff selected the full tort option on her policy and is, therefore, entitled to maintain an action for non-economic losses. Further, Plaintiff did suffer a serious injury. Plaintiff's Declaration Page is attached hereto as Exhibit A. 18. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Defendant's averment lacks the specificity required by the Pennsylvania 1 54423/MLB Rules of Civil Procedure. Further, all of Plaintiff's injuries and damages were caused solely and directly as a result of the negligence, carelessness, wantonness and recklessness of the instant Defendant. 19. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. All of Plaintiff's injuries and damages were caused solely and directly as a result of the negligence, carelessness, wantonness and recklessness of the instant Defendant. 20. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiff's injuries were caused solely and directly as a result of the negligence, carelessness and recklessness of the instant Defendant and not by an Act of God or any other force. 21. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, this accident was not unavoidable. All of Plaintiff's injuries and damages were caused solely and directly as a result of the negligence, carelessness, wantonness and recklessness of the instant Defendant. 22. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiff's injuries were caused solely and directly as a result of the 2 negligence, carelessness and recklessness of the instant Defendant and not by a Sudden Emergency. 23. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiff was not negligent in any way. Therefore, the Pennsylvania Comparative Negligence Act does not apply to the instant action. Further, all of Plaintiff's injuries and damages are recoverable in the instant action and are in no way reduced. 24. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiff did not assume the risk of her injuries. Further, as previously stated herein, Plaintiff was not negligent or careless. All of Plaintiff's injuries and damages are recoverable in the instant action. WHEREFORE, Plaintiff respectfully requests this Honorable Court to dismiss Defendant's Answer and New Matter and enter judgment in her favor against the Defendant. ANGINO & Richard-A. Sadlock, Esquire I.D. No. 47281 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff Date:September 9, 1999 j EXHIBIT A H.S.H. EKG DEPT. Fax: '1 763-3016 Mar 2' '98 11'2' P.03 r Allstate' Insurance Company Allslatee . .. 1All'La W apoi teeede. RENEWAL Auto Policy Decl arations ; Summary . N NAMED INSURED(S) YOUR ALLSTATE AGENT IS YOUR BILL Brenda K Bryner C Jeffrey Conant vAll arrive approftatelY % 189 Ashford Or (717) 258.4554 2 weekt before the polity Enola PA 17025.2303 period begins. 781 E Ffiph Street Su Carlisle PA 17013 POLICY NUMBER POLICY PERIOD 0 77 155551 10/16 Apr. 16. 1998 to Oct 16,1998 at 12:01 a.m. standard lime DRIVER(S) LISTED DRIVER(S) EXCLUDED Brenda None VEHICLES COVERED VEHICLE ID NUMBER LIENHOLDER 1. 88 ClleWBeratte 1G1LV14W4JY667183 None 1 Total Premium (Year bill will be meted separately.) . Premium for 88 Chevy Beretta $312.50 TOTAL 5912.50 ? YwrloMlpremium relleegeeamelrnllgcounr a/J70.T0 Your Polity[DseA're Date Is Apr. 10, IOU NI ACCORDANCE WITH SECTION 1715 OFTHE MOTOR VEHICLE FINANCIAL RESPONsulam LAW, To i A RENTAL VEHICLE WILL III COVERED IF: r)THE RENTAL VEHICLE D A FOUR WHEEL PRIVATE PASSENG1 a) AT LEAST ONE PREMIUM FOR AVID COLLISION COVERAGE APPEARS ON YOUR FOLEY DECLARATCI DEDUCTISLESARO TO POLICY TEAMS AND CONDITIONS. INCLUONC ANY APPLICAILE ENDORSEMENTS . WTD •OIOD01rM0.71emmf01u07' ••? .::, ?:.: :::= IYIYIIIIIIIYIIIIIIIliYVIli1111111161fIlYlll911111111 ?;?;; Page 1 H.S.H. EKG DEPT. Fax:717-763-3016 Mar 21 '98 17:27 P.04 Allstate ',surance Company Paley Number: 0 77 165501 10/le VaurAaenU C Jeffrey Donal (7tH asa•ase Polley EIIWWe Dole: All, 15,10110 COVERAGE FOR VEHICLE IF 1 1988 Chevy Beretta COVERAGE LIMITS DEDLIMUE PREMIUM Automobile Liability Insurance -• Full Tort e Bodily Injury $300,000 each person Not Applicable 563.00 $300,000 each occurrence e Property Damage $700,000 each occurrence Not Applicable $57.00 Medial Expenses s10,000 each person NotAppNable 527.00 Funeral Expenses $2,500 each person Not Applicable 50.10 Income Loss Each person up to $5.000 maximum benefit Not Applicable $6.00 Subject to $1,000 monthly maximum • . ,,. ;-•+a.'=q Uninsured Motorists Insurance $300,000 each person Not Applicable $23.20 Full Tort/ No sucking- $300,000 each accident single vehicle policy Underinsured Motorists Insurance $300.000 each person Not Applicable $17.10 Full Tort / No slacking- $300,000 each accident single vehicle policy Auto Collision Insurance Actual Cash Value $250 $60.00 Auto Comprehensive Insurance Actual Cash Value $50 $27,00 Rental Reimbursement Coverage up to $20 per day for Nol Applicable $11.50 a maximum of 30 days total Premium for BS Chevy Beretta $$12.5$ DISCOUNTS Your premium for this vehicle renects the following discounts: Automatic Seat Belts $5.10 Premier Plus $65.00 ;• ;: RATING INFORMATION ' This vehicle Is driven aver 7,500 miles per year, 3.9 miles to workhchocl, with no unmarried drive r under 25, good driver rate Pigs 2 rwwe VERIFICATION 1, BRENDA K. BRYNER, Plaintiff, have read the foregoing PLAINTIFF'S REPLY TO NEW MATTER and do swear or affirm that the facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the penalties of 18 Pa.C.S.A., Section 4904, relating to unsworn falsification Brenda K. Bryner Date: 151958/MLB CERTIFICATE OF SERVICE I, Marcy L. Brymesser, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFF'S REPLY TO NEW MATTER on the following via postage prepaid, first class United States mail, requested addressed as follows: Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 4 0 obpl 4t?n?e _ Mary L. Brymesser Date: September 9, 1999 ?S1 ?`. u ?_.'. p C. ? ?.. l l/ - t ?? l? ! l.• n CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER TERM, 0000 -VS- CASE NO: 99-4672 IAN F. BEVERLY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10105/99 JE 1FERSON J.. SHIPGRE Attorney for DEFENDANT DE11-133925 0 8 0 2 7- L 0-L COMMONWEALTH OF PENNSI'LV.{-:.NTA COUNTY O EP C UMB E RLAN D IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER VS- IAN F. HEVERLY TERM, 0000 CASE NO: 99-4672 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS DR. BRUCE GOODMAN, NEUROLOGY CENTER HEALTH CARE 24 HOLY SPIRIT HOSPITAL HEALTH SOUTH REHAB REHAB WORKS MEDICAL & BILLING MEDICAL 6 BILLING MEDICAL & BILLING MEDICAL 6 BILLING MEDICAL & BILLING MEDICAL 6 BILLING TO: RICHARD A. SADLOCK, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 9/15/99 MCS on behalf of CC: JEFFERSON J. SHIPMAN. ESQUIRE - 22740800 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP, INC. 1601 MARKET STREET /800 PHILADELPHIA PA 19103 (215) 246-0900 DE02-102100 0 8 0 2 7- C O 1 amenamums Or PROISUVAM cunfrlc oe ar+?TaleiD BRENDA K. BRYNER File No. VS IAN F. HEVERLY MAPOENA TOP rs con wa?rre ro t,., FOR DISOOVERY PURSLUINT TO M2 E 4009 211 TO: CUTODTANN OF RECORDS FOR: DR. BRUCE GOODMAN (Name of Person or Ent Within twenty (20) days after service of this subpoena, you are ordered by the Court produce the following docunsnts or things: SEE ATTACHED at (Address) PA 19103 _ You may deliver or mail legible copies of the dOcLvw is or produce things requested this subpoena, together with the certificate of ooapliance, to the party making th request at the address listed above. You have the right to seek in advance the reasarab cost of preparing the copies or producing the things sought. If you fail to produce the doannnts or things required by this subpoena within twen (20) days after its service, the party serving this subpoena may seek a cart Ord ompelIIng you to camly with it. THIS SUBPOENA WAS ISSN AT Tiff REQUEST OF THE FCLLONINO PERSON: NA!'E:JE FERSON S. SHIPMAN. ESQUIRE ADDRESS: 320 MARKET STREET, P.O. BOX 1268 HARRISBURG PA 17108 TELgplOW: (215) 246-0900 SUPREM COURT ID N ATTORNEY FOR: THE DEFENDANT BY TH?E/ COURT: ,p DATE: Q,75&Z - /., /9 PrOrronorar Y? 1 of the 0o rt prime, ,G ?'. EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. BRUCE GOODMAN, 1515 N. FRONT STREET HARRISBURG, PA 17102 RE: 08027 BRENDA K. BRYNER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : BRENDA K. BRYNER 215 SECOND ST., ENOI.A, PA 17025 Social Security #: 210.44-7359 Date of Birth: 08-20-53 SU10-210786 043027-IOM CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER TERM, 0000 -VS- CASE NO: 99-4672 IAN F. HEVERLY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN. ESQUIRE defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/05/99 JEFFERSON J. SHIPMAN. ESQUIRE Attorney for DEFENDANT DE11-133926 0802-7-1.02 COMMONWEALTH OEr PMNNSYLV'ANZA y 'I COUNT Y O F7 CUMB M RLAN D IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER TERM, 0000 _VS_ IAN F. HEVERLY CASE NO: 99-4672 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS DR. BRUCE GOODMAN, NEUROLOGY CENTER HEALTH CARE 24 HOLY SPIRIT HOSPITAL HEALTH SOUTH REHAB REHAB WORKS MEDICAL & BILLING MEDICAL & BILLING MEDICAL & BILLING MEDICAL & BILLING MEDICAL & BILLING MEDICAL & BILLING TO: RICHARD A. SADLOCK, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN. ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 9115199 CC: JEFFERSON J. SHIPMAN, ESQUIRE - 22740800 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP, INC. 1601 MARKET STREET 1800 PHILADELPHIA PA 19103 (215) 246-0900 DE02-102100 08027-C01 COMMO WRIkWO OF PENNS1fLMAMR o COIa+Trlr OP CUMBEKAW BRENDA K. BRYNER VS IAN F. HEVERLY File No. 99-4672 OENA TO PROOIIrF nrv? ?s+rrc ro ..? . FOR D I S X VERY Pt %Mr TO d L F 4009,22 TO: NEUROLOGY CENTER of Person or e9i Within twenty (20) days after service of this subpoena, you are ordered by the court Produce the following doCUnents or things; SEE ATTACHED at (Address) PHILADELPHIA PA 19103 You rosy deliver or mail legible copies of the documents or prodtxa things requested this subpoena, together with the certificate of omolian e, to the party making th request at the addrcas listed above. You have the right to seep in advance the reasanab cost of preparing the copies or producing the things sought. If you fail to prod ca the documents or things required by this subpoena within (20) days after its service, the party serving this subpoena may seek a cow t come] Iing you to comply with it. THIS SUBPOENA WAS ISSIR? AT Tw REQUEST OF THE FOLLOININO PERSON: NAME: JEFFERSON J. SHIPMAN, ESQUIRE ADDRESS: 320 MARKET STREET, P.O. BOX 1268 HARRISBURG PA 17108 •ELEpHOW: (215) 246-0900 SIPRE!•E COURT I D M ATTORNEY FOR: THE DEFENDANT BY THE OD R1T: DATE: 13 /OW Sail of the Court ?P/Gi r4 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NEUROLOGY CENTER 897 POPLAR CHURCH RD. CAMP HILL, PA 17011 RE: 08027 BRENDA K. BRYNER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : BRENDA K. BRYNER 215 SECOND ST., ENOLA, PA 17025 Social Security #: 210-44-7359 Date of Birth: 08-20-53 SU10-210788 O B 0 2 7- L 0 2 .,.. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER TERM, 0000 -VS- CASE NO: 99-4672 IAN F. HEVERLY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN. ESQUIRE defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/05/99 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DE11-133927 08027-1-03 CPMM0NWEALTH OF PENNSYLVAN=A COUNTY OF CLTMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER TERM, 0000 -VS- CASE NO: 99-4672 IAN F. HEVERLY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS DR. BRUCE GOODMAN, NEUROLOGY CENTER HEALTH CARE 24 HOLY SPIRIT HOSPITAL HEALTH SOUTH REHAB REHAB WORKS MEDICAL & BILLING MEDICAL & BILLING MEDICAL & BILLING MEDICAL & BILLING MEDICAL & BILLING MEDICAL & BILLING TO: RICHARD A. SADLOCK, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 9115199 MCS on behalf of CC: JEFFERSON J. SHIPMAN, ESQUIRE - 22740800 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP, INC. 1601 MARKET STREET 1800 PHILADELPHIA PA 19103 (215) 246-0900 DE02-102100 0 8 0 2- 7- C O J- COMMMaaMM OF PENNSYLYAMM COUM OF CUMBEFM 1ND BRENDA K. BRYNER File No. 99-4672 VS IAN F. HEVERLY SUBPOENA TO P5NQQ E pm aourc OR THINS FOR D I SO NERY Pdlia ?eur ern RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HEALTH CARE 24 (Name of Person or Within twenty (20) days after service of this subpoena. You are Ordered by the court Produce the following doa.ments or things: -SEE ATTACHED at PHILADELPHIA PA 19103 (Address) You may deliver or mail legible copies of the docments or produce things requested this subpoena, together with the certificate of carpliance, to the party making b request at the address listed above. You have the right to seek in advance the reasortil cost of preparing the copies or Producing the things sought. If you fail to produce the documents or things required by this subpoena within two (20) days after its swine, the party serving this subpoena may sank a court or came] ling you to omply with it. THIS SUBPOENA WAS ISSI AT THE REGLEST OF THE FOLUXINO PERSON: NAM: JEFFERSON J. SHIPMAN, ESQUIRE ADMSS: 320 MARKET STREET, P.O. BOX 1268 HARRISBURG PA 17108 TELEPHONE: (215) 246-0900 SUPRQ£ COI.RT 10 0 ATTORNEY FOR: THE DEFENDANT BY THE OOIRT: GATE: cSo? '12 /9 ProCnOnOLary/c:arx, Sail of the Cart AK EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTH CARE 24 503 N. 21ST STREET CAMP HILL, PA 17011 RE: 08027 BRENDA K. BRYNER Any and all records, correspondence, tiles and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : BRENDA K. BRYNER 215 SECOND ST., ENOLA, PA 17025 Social Security #: 210.44-7359 Date of Birth: 08-20-53 SU10-210790 08027-1,03 .. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER TERM, 0000 -VS- CASE NO: 99-4672 IAN F. BEVERLY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/05/99 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DE11-133928 08027-1,04 C OMMO NWEAL T H O Y P E NN S YLVAN TAi COUNTY O Y CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER -VS- IAN F. HEVERLY TERM, 0000 CASE NO: 99-4672 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS DR. BRUCE GOODMAN, NEUROLOGY CENTER HEALTH CARE 24 HOLY SPIRIT HOSPITAL HEALTH SOUTH REHAB REHAB WORKS MEDICAL & BILLING MEDICAL & BILLING MEDICAL & BILLING MEDICAL & BILLING MEDICAL & BILLING MEDICAL & BILLING TO: RICHARD A. SADLOCK, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN. ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: )/15/99 MCS on behalf of CC: JEFFERSON J. SHIPMAN, ESQUIRE - 22740800 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP, INC. 1601 MARKET STREET 1800 PHILADELPHIA PA 19103 (215) 246-0900 DE02-102100 0 8 0 2 7- C O 1 aDkcmMRLTEl OF PEWSUVAHM =jm of ammmAm BRENDA K. BRYNER File No. VS IAN F. HEVERLY SUBPOENA TOP mn ecvrc ro TH I N? FOR OISOOVERY pUSausrT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITALIPHYSICAL THERAPY DEPARTMENT (Name of Parson or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court Pr'ocluce the following documents or things: GEE ATTACHED at (Address) PA 19103 You may deliver or mail legible copies of the doeunents or produce things requested this subpoena, together with the certificate of osrplianee, to the party making th request at the address listed above. You have the right to seek in advance the reasaneb cost of prepring the copies or producing the things sought. I f you fai 1 to Wvdxe the docurents or things required by this suibpoem within twen (20) days after its service, the party serving this subpoena may seek a court Ord ccn"l l ir;g you to arrply with it. THIS SUBPOENA WAS ISOSD AT THE RECLEST OF THE FOLLOWING PERSON: NAPE: JEFFERSON J. SHIPMAN, ESQUIRE ,ADDRESS: 320 MARKET STREET, P.O. BOX 1268 HARRISBURG PA 17108 TELEpPONE: (215) 246-0900 %PREI E OOIIYT I D # ATTORNEY FOR: THE DEFENDANT BY THE OOIITT: ?? ProurorrocerY/c OATE• QJJn-J / . / ? /mow Seal of the Oort ii .- EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL PHYSICAL THERAPY DEPT. 105 GATEWAY DR. MECHANICSBURG, PA 17055 RE: 08027 BRENDA K. BRYNER Any and all records, correspondence, tiles and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : BRENDA K. BRYNER 215 SECOND ST., ENOLA, PA 17025 Social Security A 210-44-7359 Date of Birth: 08.20.53 SU10-210792 08027-L 04 CERTIFICATE b PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA R. BRYNER TERM, 0000 -VS- CASE NO: 99-4672 IAN F. HEVERLY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/05/99 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DE11-133929 0 8 0 2 7- 1,0 5 +COMNiONWEALTH OF PENNSYLVANIA COUNT Y O F CUMBERLAND IN THE MATTER OF: BRENDA K. BRYNER -VS- IAN F. HEVERLY COURT OF COMMON PLEAS TERM. 0000 CASE NO: 99-4672 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS DR. BRUCE GOODMAN, MEDICAL & BILLING NEUROLOGY CENTER MEDICAL & BILLING HEALTH CARE 24 MEDICAL & BILLING HOLY SPIRIT HOSPITAL MEDICAL & BILLING HEALTH SOUTH REHAB MEDICAL & BILLING REHAB WORKS MEDICAL & BILLING TO: RICHARD A. SADLOCK, ESQUIPW MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Pules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 9/15/99 MCS on behalf of CC: JEFFERSON J. SHIPMAN, ESQUIRE - 22740800 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP, INC. 1601 MARKET STREET 1800 PHILADELPHIA PA 19103 (215) 246-0900 DE02-102100 0 8 0 2 7- C 0 3- i C@ ICHMM M or Pal671Tm m? COUM OF OUNSMI[AND BRENDA K. BRYNER File No. VS IAN F. HEVERLY TO PRODUCE arm ncurc ro ,s, SUBPOENA, FOR DI SONM PURSLWlT TO wa F amo 22 TO: CUSTODIAN OF RECORDS FOR: HEALTH SOUTH REHABILITATION AND DR. MALIK MOMIN (Naps of Person or Entity) Within twenty (20) days after service of this subpoena, You are ordered by the cart to produce the following documents or things: SFE ATTACHED at SUITE 800 PHILADELPHIA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested h this subpoena, together with the certificate of carplianee, to the party making thi request at the address listed above. You have the right to seek in advance the reasonabl cost of preparing the copies or producing the things sought. If you .fail to produce the documents or things required by this subpoena within tweet (20) days after its service, the party serving this 3UbP0er1& may seek a cart orde carpel IIng you to comply with it. THIS SUBPOENA WAS ISOJFD AT THE RE+CUEST OF THE FMAMINO PERSON: NAM: JEFFERSON J. SHIPMAN, ESQUIRE ADORESS: 320 MARKET STREET, P.O. BOX 1268 HARRISBURG PA 17108 TELEPHONE: (215) 246-0900 SIJ RE E COURT I D ii ATTORNEY FOR: THE DEFENDANT BY THE COURT: _? DATE: of the court Z.% EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTH SOUTH REHAB 175 LANCASTER BLVD. MECHANICSBURG, PA 17055 RE: 08027 BRENDA K.BRYNER INCLUDING ANY AND ALL RECORDS FROM DR. MALIK MOMIN. Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : BRENDA K. BRYNER 215 SECOND ST., ENOLA, PA 17025 Social Security #: 210-44.7359 Date of Birth: 08-20-53 SU10-210794 08027-1-05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA R. BRYNER TERM, 0000 -VS- CASE NO: 99-4672 IAN F. HEVERLY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/05/99 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DE11-133930 0 8 0 2 7- L 0 6 COMMONWEALTH OFyPENNSYLVAN2A COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER TERM, 0000 -VS- CASE NO: 99-4672 !AN F. HEVERLY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS DR. BRUCE GOODMAN, NEUROLOGY CENTER HEALTH CARE 24 HOLY SPIRIT HOSPITAL HEALTH SOUTH REHAB REHAB WORKS MEDICAL S BILLING MEDICAL & BILLING MEDICAL S BILLING MEDICAL 6 BILLING MEDICAL 6 BILLING MEDICAL 6 BILLING TO: RICHARD A. SADLOCK, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN. ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil. Procedure 4009.24. Complete copies of any reproduced records may be ordered at your eXDense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 9/15/99 MCS on behalf of CC: JEFFERSON J. SH7DMAN, ESQUIRE - 22740800 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP, INC. 1601 MARKET STREET 0800 PHILADELPHIA PA 19103 (215) 246-0900 DE02-102100 0 8 0 2 7- C 0 1 COMl30SUM OF PEN 1IZA1ARM cogurif or apmt[AND BRENDA K. BRYNER File No. VS IAN F. HEVERLY SUBPOENA TO PROMM p0( PWS OR TH Iux FOR 01SOOVERY "SUANT TO RILE 4009.22 TO: CUSTODIAN OF RECORDS FOR: REHAB WORKS of Person or Within twenty (20) days after service of this subpoena, you are ordered by the court produce the following documents or things: SEE ATTACHED at MCS GROUP INC. _ SUITE 800 1601 MARKET STREET PHILADELPHIA PA 19103_; (Address) You may deliver or mail legible copies of the docunmts or produce things requested b this subpoena, together with the certificate of carpliance, to the party making thi request at the addrcas listed above. You have the right to seek in advance the reasonabl cost of preparing the copies or producing the things sought. If you fail to produce the doaments or things required by this subpoena within (20) days after its service, the party serving this s?6poana may seek a mart =rpellirg you to carply with it. THIS SUBPOENA WAS ISSISD AT THE REMAST OF THE FOLLOWING PERSON: NAPE: JEFFERSON J. SHIPMAN, ESQUIRE ADMSS: 320 MARKET STREET, P.O. BOX 1268 HARRISBURG PA 17108 TELEPHONE: (215) 246-0900 SIPRFIE O= T 10 K ATTORNEY FOR: THE DEFENDANT BY THE COIRT: r, ?„r ww OATE: Seal of the Court ?? EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: REHAB WORKS 1515 N. FRONT STREET HARRISBURG, PA 17102 RE: 08027 BRENDA K.BRYNER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : BRENDA K. BRYNER 215 SECOND ST., ENOLA, PA 17025 Social Security N: 210-44-7359 Date of Birth: 08-20-53 SU10-210796 0802-7-L 06 ?- ri >- o : ? _" ' ' Ec .i ?. V. I. ??": ?.. ? ! - F- ilJ i..' C.` L ?? ?1 I.. V l1l U? U CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER TERM, 0000 -vs_ CASE NO: 99-4672 IAN F. HEVERLY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10121/99 4LV-4 IPMA Attorney for DEFENDANT DE11-137185 08027-L.07 C OM IO NWEAL T H OF P E N N S YL VAN = A COUNTY OF CLIMB E RLAN D IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER -VS- IAN F. HEVERLY TERM, 0000 CASE NO: 99-4672 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS KEYSTONE SPINE CENTER ALLSTATE INSURANCE HOLY SPIRIT HOSPITAL AMRICAN LEGION MEDICAL 6 BILLING INSURANCE EMPLOYMENT EMPLOYMENT TO: RICHARD A. SADLOCK, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN. ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/01/99 MCS on behalf of CC: JEFFERSON J. SHIPMAN, ESQUIRE - 22740800 JEFFERSON J. SHIPMAN. ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP, INC. 1601 MARKET STREET 1800 PHILADELPHIA PA 19103 (215) 246-0900 DE02-103364 0 8 0 2 7- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRENDA K. BRYNER File No, 0 99-4672 VS. IAN F. HEVERLY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: KEYSTONE SPINE CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at THE MCS GROUP, INC., 1601 MARKET STREET SUITE# 800 PHILADELPHIA, PA. 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within 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: JEFFERSON SHIPMAN, ESQUIRE ADDRESS: 32U MARKET STREET P.O. BOX 126 HARRISBURG,PA. 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID#: ATTORNEY FOR: THE DEFENDANT BY THE COI1g,T:z DATE: d p l 02.9 1999 /t'. Prothanotary/ er Civil Division -r-(z L 72t..??. r Deputy Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: KEYSTONE SPINE CENTER 175 LANCASTER BLVD. MECHANICSBURG, PA 17055 RE: 08027 BRENDA K. BRYNER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : BRENDA K. BRYNER 215 SECOND ST., ENOLA, PA 17025 Social Security k: 210-44.7359 Date of Birth: 08-20.53 SU10-213334 0802-7-L.07 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER TERM, 0000 -vS- CASE NO: 99-4672 IAN F. HEVERLY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21199 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DE11-137186 0802-7-L.08 C: OMMO NWEA L T H O Ir P E N N S YL VAN T A COUNT 'Y' OP C UMB E RI AN D IN THE VIATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER -VS- IAN F. HEVERLY TERM, 0000 CASE NO: 99-4672 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS KEYSTONE SPINE CENTER MEDICAL 6 BILLING ALLSTATE INSURANCE INSURANCE HOLY SPIRIT HOSPITAL EMPLOYMENT AMRICAN LEGION EMPLOYMENT TO: RICHARD A. SADLOCK, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Pules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/01/99 CC: JEFFERSON J. SHIP-MAN, ESQUIRE _ 22740800 Any questions regarding this matter, contact MCS on behalf of JEFFERSON J. SHIPMAN ESQUIRE Attorney for DEFENDANT THE MCS GROUP, INC. 1601 MARKET STREET :800 PHILADELPHIA PA 19103 (215) 246-0900 DE02-103364 0 8 0 2 7- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRENDA K. BRYNER File No. # 99-4672 VS. IAN F. HEVERLY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ALLSTATE INSURANCE COMPANY (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: 5E ATTACHED at THE MCS GROUP, INC., 1601 MARKET STREET SUITE# 800 PHILADELPHIA, PA. 19103 )Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within 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: JEFFERSON SHIPMAN, ESQUIRE ADDRESS: HARRISBURG,PA. 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: THE DhkENDANT BY THE COURT: DATE: .2 ?/ / 9 cI 5 ^?I f rothoonno?tary/CCl rrkk, Civil Division -? Deputy Seal of the Court (Eff.7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALLSTATEINSURANCE 6345 FLANK DRIVE SUITE #1000 HARRISBURG, PA 17112 RE: 08027 BRENDA K. BRYNER INCLUDING FIRST PARTY FILE MATERIAL RE: POLICY #077155551 10/16. Any and all claims files. Dates Requested: up to and including the present. Subject : BRENDA K. BRYNER 215 SECOND ST., ENOLA, PA 17025 Social Security!!: 210-44.7359 Date of Birth: 08-20-53 Date of Loss: 12-31-97 SU10-213336 08027-1,08 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER TERM, 0000 -VS- CASE NO: 99-4672 IAN F. HEVERLY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN ESQUIRE defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21/99 JEFFERSON J. SHIPMAN. ESQUIRE Attorney for DEFENDANT DEII-137187 0 8 0 2 7- L 0 9 C OMMO NWEAI-T H O Fr P E N N S YL VAN T A COUNTY OP CUMB E RLAN D Iii THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER VS- IAN F. HEVERLY TERM, 0000 CASE NO: 99-4672 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS KEYSTONE SPINE CENTER ALLSTATE INSURANCE HOLY SPIRIT HOSPITAL AMRICAN LEGION MEDICAL 6 BILLING INSURANCE EMPLOYMENT EMPLOYMENT TO: RICHARD A. SADLOCK, ESQUIRE MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Pules of Civil Procedure 4009.24. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/01/99 MCS on behalf of CC: JEFFERSON J. SHIPMAN, ESQUIRE - 22740800 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP, INC. 1601 MARKET STREET Ca00 PHILADELPHIA PA 19103 (215) 246-0900 DE02-103364 0 8 0 2 7- C O 7- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRENDA K. BRYNER File No. () 99-4672 VS. IAN F. HEVERLY SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL (Name of Penton 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 at THE MCS GROUP, INC., 1601 MARKET STREET SUITE# 800 PHILADELPHIA, PA. 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within 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: JEFFERSON SHIPMAN, ESQUIRE ADDRESS: 320 MARKET STREET P.O. - BOX 1268 HARRISBURG,PA. 17108 TELEPHONE: (215) 246-0900 SUPREME COURT ID ii: ATTORNEY FOR: THE DEFENDANT BY THE COUR DATE: .l/in.67- J . , c29 999 Cwt .t 1 . / Proth/non?otary/CI k, Coil Division /17 Deputy Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 N. 21ST STREET CAMP HILL, PA 17011 RE: 08027 BRENDA K.BRYNER TO INCLUDE ANY WORKER'S COMP FILE MATERIALS. Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject : BRENDA K. BRYNER 215 SECOND ST., ENOLA, PA 17025 Social Security #: 210-44-7359 Date of Birth: 08-20.53 SU10-213338 0802-7-L.09 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS BRENDA K. BRYNER TERM, 0000 -VS- CASE NO: 99-4672 IAN F. HEVERLY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE defendant certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to the certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 10/21199 JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT DE11-137188 08 02 7- I-1-0 C OMMO NWE AL T H O F' P E N N S YLVAN I A COUNTY O F7 C UM B E KLAN D IN THE MATTER. OF: COURT OF COMMON PLEAS BRENDA K. BRYNER -VS- IAN F. HEVERLY TERM, 0000 CASE NO: 99-4672 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS KEYSTONE SPINE CENTER ALLSTATE INSURANCE HOLY SPIRIT HOSPITAL AMRICAN LEGION MEDICAL 6 BILLING INSURANCE EMPLOYMENT EMPLOYMENT TO: RICHARD A. SADLOCK, ESQUIRE MCS on behalf of JEFFERSON J. SHI?MAN, ESQUIP.E intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. Complete copies of ar.y reproduced records may be ordered at your expense by comDleting the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10101199 CC: JEFFERSON J. SH7PKkN, ESQUiR.E - 22740800 MCS on behalf of JEFFERSON J. SHIPMAN, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact 11HE 601MCS GROUP, NC MARKET STREET BBOO PHILADELPHIA PA 19103 (215) 246-0900 DE02-103364 08027-C03- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND BRENDA K. BRYNER VS. IAN F. HEVERLY File No. # 99-4672 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: AMERICAN LEGION (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 at rtt>; MUS GROUP, INC., 1601 MARKET STREET SUITE# 800 PHILADELPHIA, PA. 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within 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: JEFFERSON SHIPMAN, ESQUIRE ADDRESS: 320 MARKET STREET P.O. BOX HARRISBURG,PA. 17108 TELEPHONE: BLS) 246-0900 SUPREME COURT ID ff: ATTORNEY FUR: THE DEFENDANT BY THE COURT: DATE: --LL-/, 1 V-Q lei % Prothonnotary/Cle Ci V it Division 0 ?.,.,,e.c? (_.L 779 i /.•'F v r Deputy Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: AMRICAN LEGION 295 SHADY LANE ENOLA, PA 17025 RE: 08027 BRENDA K. BRYNER TO INCLUDE ALL WORKER'S COMP CLAIMS, MEDICAL BILLS, INCIDENT REPORTS, WAGES, ABSENCES, ETC. Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject : BRENDA K. BRYNER 215 SECOND ST., ENOLA, PA 17025 Social Security#: 210-44-7359 Date of Birth: 08-20-53 SU10-213340 08027-I---LO Y pi y. l uJC) N .J _T C J t i - f I' ' F , 1 L Ul ( v pi U BRENDA K. BRYNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW BY THE COURT, IAN F. HEVERLY, Defendant NO. 99-4672 CIVIL TERM AND NOW, thisZjay of June, 2000, upon consideration of Plaintiffs Motion to Compel Discovery Responses, a discovery conference/hearing is scheduled for Wednesday, August 2, 2000, at 3:00 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. Richard A. Sadlock, Esq. 4503 N. Front Street Harrisburg, PA 17110 Attorney for Plaintiff Jefferson J. Shipman, Esq. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorney for Defendant :rc esley Oler, Jr., J. Op IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRENDA K. BRYNER, I CIVIL ACTION - LAW Plaintiff '161GIL V. NO. 99-4592 CI VIL TERM IAN F. HEVERLY, Defendant I JURY TRIAL DEMANDED ORDER AND NOW, this day of , 2000, it is hereby Ordered and Decreed Defendant's Objections to Plaintiffs Interrogatories are DISMISSED. Defendant is directed to answer all Interrogatories within days of the date of this Order or face further sanctions. BY THE COURT: J. 215032. MAMILB /I r .t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRENDA K. BRYNER, Plaintiff V. IAN F. HEVERLY, Defendant CIVIL ACTION - LAW NO. 99-4572 CIVIL TERM JURY TRIAL DEMANDED PLAINTIFF'S MOTION TO COMPEL DISCOVERY RESPONSES Plaintiff, by and through her attorneys, Angino & Rovner, P.C., respectfully moves this Honorable Court to compel Defendant Ian F. Heverly to file full and complete responses to Plaintiffs Second Set of Interrogatories for the following reasons: 1. The instant action was commenced by the filing of a Complaint on August 3, 1999. 2. Plaintiff forwarded to Defendant Ian F. Heverly, Plaintiffs Second Set of Interrogatories pertaining to Defendant's expert witness, Perry A. Eagle, M.D. A copy of the Interrogatories is attached hereto as Exhibit A. 3. On June 7, 2000, counsel for Defendant Ian F. Heverly forwarded to Plaintiffs counsel, Objections to Plaintiffs Interrogatories. A copy of Defendant's Objections are attached hereto as Exhibit B. 4. Defendant's Objections to Plaintiffs Interrogatories are without merit. 5. Defendant Ian F. Heverly objected on the grounds that the Interrogatories were sought in bad faith and/or would cause an unreasonable annoyance, oppression, burden or expense and/or would require the making of an unreasonable investigation. 213031MAS\MLn 4 6. All discovery sought by Plaintiff through the Interrogatories is relevant to the instant action. The discovery is relevant to the bias of Dr. Eagle and to his credibility. 7. Recently, Plaintiffs counsel filed a Motion to Compel Discovery in a similar case and on April 7, 2000, The Honorable Richard A. Lewis signed an Order requiring Defendants to provide Plaintiffs with a list of all cases in which Perry A. Eagle, M.D. performed an independent medical examination for that defense lawyer and for the tortfeasors' insurer. 8. Attached as Exhibit C is a copy of Plaintiffs Interrogatories to Defendant in the S2riffin v. Strauser case. 9. Attached as Exhibit D is a copy of The Honorable Richard A. Lewis' Order of April 7,2000. 10. Our Rules of Civil Procedure provide for liberal granting of discovery. 11. Defendant Ian F. Heverly has failed to comply with the discovery as required by the Pa.RC.P. 4005 and 4006. 12. Defendant Ian F. Heverly has had more than ample time to respond to Plaintiffs Interrogatories. 13. Pa.R.C.P. 4019 provides that upon motion of a party, the Court can make an appropriate order when a party "fails to make discovery." Pa.R.C.P. 4019(a)(viii) 14. Plaintiff, therefore, believes that answering all of Plaintiffs Interrogatories requests would not burden or oppress Defendant Ian F. Heverly. 15. Plaintiff is represented by Richard A. Sadlock, Esquire of the firm of Angino & Rovner, P.C., 4503 North Front Street, Harrisburg, PA 17110, (717) 238-6791. 215032.1\RAWJLB 16. Defendant Ian F. Heverly is represented by Jefferson J. Shipman, Esquire of Goldberg, Katzman & Shipman, P.C., 320 Market Street, P.O. Box 1268, Harrisburg, PA 17108- 1268. WHEREFORE, Plaintiff respectfully requests that this Honorable Court order Defendant Ian F. Heverly to respond to Plaintiffs Interrogatories. Plaintiff further requests that should Defendant fails to comply with the Court Order, then Defendant should be prohibited from presenting any testimony at the trial of this matter, precluded from entering defenses to Plaintiffs claims at trial, required to pay Plaintiff's attorney fees and costs associated with the instant Motion and such other sanctions as the Court deems appropriate. ANGINO & I.D. Nb. 47281_,,- 4503 N-FrTn't Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff Date: June 14, 2000 215052.IUMAS\MLB A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRENDA K. BRYNER, Plaintiff V. IAN F. BEVERLY, Defendant CIVIL ACTION - LAW NO. 99-4572 CIVIL TERM JURY TRIAL DEMANDED PLAINTIFF'S SECOND SET OF INTERROGATORIES DIRECTED TO DEFENDANT TO: Ian F. Heverly and his attorney, Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Date: June 14, 2000 2I3167.1WASWLB 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff 29. Please list all cases in which Perry A. Eagle, M.D. has performed an Independent Medical Examination for the law firm of Goldberg, Katzman & Shipman. ANSWER 215163.IMASWLB 30. Please list all cases in which Perry A. Eagle, M.D. has written a report for the law firm of Goldberg Katzman & Shipman. ANSWER r: 215163.1\RAS\MLB 31. Please list all cases in which Perry A. Eagle, M.D. testified in person, by deposition, etc. for the law firm of Goldberg, Katzman & Shipman. ANSWER 215163ATI SN1,11 32. Please list all sums paid to Perry A. Eagle, M.D. by Goldberg, Katzman & Shipman for the years 1994 to the present. ANSWER 713163.BRAS%ILB 33. Please list all cases in which Perry A. Eagle has performed an Independent Medical Examination for Erie Insurance Company. ANSWER 215163.IWASWLB 34. Please list all cases in which Perry A. Eagle, M.D. has written a report for an Erie insured. ANSWER 117163.1UtAS\MLa 35. Please list all cases in which Perry A. Eagle, M.D. testified in person, by deposition, etc. on behalf of an Erie insured. ANSWER 215161BRAS\MLB 36. Please list all sums paid to Perry A. Eagle, M.D. for the years 1994 to the present by Erie Insurance Company. ANSWER 2I5163.MRASWLB These Interrogatories shall be deemed to be continuing. If between the time of your answers to theses Interrogatories and the time of trial of this case, you or anyone acting on your behalf learn the identity and whereabouts of any other witness(es) not identified in your answers, or if you obtain or become aware of additional requested information not supplied in your answers, you shall promptly furnish same to the undersigned by supplemental answers. ANGINO & No. 47281 4503 N. ront Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff Date: June 14, 2000 215161nRA&MLB CERTIFICATE OF SERVICE I, Marcy L. Brymesser, an employee of the law firm ofAngino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFFS' SECOND SET OF INTERROGATORIES DIRECTED TO DEFENDANT on the following via postage prepaid, first class United States mail, requested addressed as follows: Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman, P.C. 320 Market Street P.O.Box1268 Harrisburg, PA 17108-1268 Mar L. ryme er Date: June 14, 2000 21316IRRAS\AILa i?'? Jefferson J.Shipman, Esquire Y.D. M: 51785 GOLDBERG, KATZMAN 6 SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendant BRENDA K. BRYNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO 99-4572 CIVIL TERM IAN F. HEVERLY, Defendant JURY TRIAL DEMANDED ANSWERS, WITH OBJECTIONS, TO PLAINTIFF'S SECOND SET OF INTERROGATORIES DIRECTED TO THE DEFENDANT 29. Objection. Pursuant to Pennsylvania Rule of Civil Procedure 4011, the discovery is sought in bad faith and/or would cause an unreasonable annoyance, oppression, burden or expense and/or would require the making of an unreasonable investigation. 30. Objection. Pursuant to Pennsylvania Rule of Civil Procedure 4011, the discovery is sought in bad faith and/or would cause an unreasonable annoyance, oppression, burden or expense and/or would require the making of an unreasonable investigation. 31. Objection. Pursuant to Pennsylvania Rule of Civil Procedure 4011, the discovery is sought in bad faith and/or would cause an unreasonable annoyance, oppression, burden or expense and/or would require the making of an unreasonable investigation. 32. Objection. Pursuant to Pennsylvania Rule of Civil Procedure 4011, the discovery is sought in bad faith and/or would cause an unreasonable annoyance, oppression, burden or expense and/or would require the making of an unreasonable investigation. 33. Objection. Pursuant to Pennsylvania Rule of Civil Procedure 4011, the discovery is sought in bad faith and/or would cause an unreasonable annoyance, oppression, burden or expense and/or would require the making of an unreasonable investigation. 34. Objection. Pursuant to Pennsylvania Rule of Civil Procedure 4011, the discovery is sought in bad faith and/or would cause an unreasonable annoyance, oppression, burden or expense and/or would require the making of an unreasonable investigation. 35. Objection. Pursuant to Pennsylvania Rule of Civil Procedure 4011, the discovery is sought in bad faith and/or would cause an unreasonable annoyance, oppression, burden or expense and/or would require the making of an unreasonable investigation. 36. Objection. Pursuant to Pennsylvania Rule of Civil Procedure 4011, the discovery is sought in bad faith and/or would 2 cause an unreasonable annoyance, oppression, burden or expense and/or would require the making of an unreasonable investigation. KATZMAN & SHIPMAN, P.C. da o DATE : (01-71 28101.1 Jef eMbU J. Shipman, Esquire 32 Market Street P.Q. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant 3 CERTIFICATE OE' SERVICE I hereby certify that a copy of the foregoing document has been duly served upon the following counsel of record by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, on June 7, 2000: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiffs GOLDBERG, KATZMAN & SHIPMAN, P.C. a V0 Market Streef rrisburg, PA 17108 Attorneys for Defendant Telephone: (717) 234-4161 Identification No.: 51785 28115.1 EXHIBIT C '', MARISOL R. GRIFFIN, ERIC GRIFFIN, her husband, and ERICA M. GRIFFIN, a minor, by and through her parents and natural guardians, MARISOL R- GRIFFIN and ERIC GRIFFIN, Plaintiffs V. BENJAMIN STRAUSER, and PRO CABLE SERVICES, Defendants IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1378-S-99 JURY TRIAL DEMANDED PLAINTIFF'S SECOND SET OF INTERROGATORIES DIRECTED TO DEFENDANT TO: Benjamin Strauser and Pro Cable Services and their attorney, Edward E. Knauss, IV, Esquire Metzger, Wickersham, Knauss & Erb 3211 North Front Street Harrisburg, PA 17110 A. Date: February 4, 2000 I.D. No. 4728 4503 Front Street Efff-isbure.PA 17110 (717) 238-6791 Counsel for Plaintiffs 207422AVALMLAM 29. Please list all cases in which Perry A. Eagle, M.D. has performed an Independent Medical Examination for the law firm of Metzger, Wickersham, Knauss & Erb. ANSWER 207422.1\MLe\LAH 30. Please list all cases in which Perry A. Eagle, M.D. has written a report for the law firm of Metzger, Wickersham, Knauss & Erb. N WER 207422.1\MLB\LAM 31. Please list all cases in which Perry A. Eagle, M.D. testified in person, by deposition, etc. for the law firm of Metzger, Wickersham, Knauss & Erb. ANSWER 207422.1NILB1LANI 32. Please list all sums paid to Perry A. Eagle, M.D. by Metzger, Wickersham, Knauss bt Erb for the years 1994 to the present. ANSWER 207422.IWLB%LAA1 33. Please list all cases in which Perry A. Eagle has performed an Independent Medical Examination for Crum & Foster Insurance Company. ANSWER 207422.IIMLa1LAM 34. Please list gl{ cases in which Perry A. Eagle, M.D. has written a report for a Crum & Foster insured. ANSWER 207422AVOLMLAM 35. Please list all cases in which perry A. Eagle, M.D. testified in person, by deposition, etc. on behalf of a Crum & Foster insured. N WER 707432.1\MLB1LAM 36. Please list all sums paid to Perry A. Eagle, M.D. for the years 1994 to the present by Crum & Foster Insurance Company. NSWER 407421MILMLAM .. '. M F 1yH'. EXHIBIT D J -1. MARISOL R. GRIFFIN, ERIC GRIFFIN Her husband and ERICA M. GRIFFIN, a minor, by and through her parents and Natural guardians, MARISOL R. GRIFFIN and ERIC GRIFFIN Plaintiffs VS. BENJAMIN STRAUSER and PRO CABLE SERVICES Defendants - J? IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 1378 S 1999 ORDER AND NOW, 3<6day day of April, 2000, following a conference in chambers on Plaintiffs' Motion to Compel Discovery Responses, it is hereby ordered that Defendants shall provide a list of all cases in which Perry A. Eagle, M.D. has performed an independent medical exam for the law firm of Metzger, Wickersham, Knauss & Erb and/or Crum & Foster Insurance Company from the date of the accident in this matter to the present. Defendants shall also provide a copy of said reports. Distribution: Richard A. Sadlock, Esq., 4503 N ., PA 17110 Edward E. Knauss, IV, Esq., POB 5300, 211 N. Front Street, Hog., PA file. 17110-0300 r• N. 4: CERTIFICATE OF SERVICE I, Marcy L. Brymesser, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFF'S MOTION TO COMPEL DISCOVERY RESPONSES on the following via postage prepaid, first class United States mail, requested addressed as follows: Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 I M y L. rym ss r Date: June 14, 2000 2I5032.1\RAS\MLB 1.. .? \. ? t 1 } ? ( 1. I l -) L) LAW OFFICES GOLDBERG, KATZMAN & SHIPMAN, P.C. 020 NARxRT STRICT STRAWBERRY SQUARE P. O. Box IYSB HARRISBURG, PENNSYLVANIA I7I08-1233 Jefferson J.Shipman, Esquire I.D. M: 51785 GOLDBERG, KATZMAN S SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendant BRENDA K. BRYNER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO 99-454e-CIVIL TERM IAN F. HEVERLY, Defendant JURY TRIAL DEMANDED ANSWER TO PLAINTIFF'S MOTION TO COMPEL DISCOVERY RESPONSES AND NOW, comes the Defendant, Ian F. Heverly, by and through his counsel, Goldberg, Katzman & Shipman, P.C., who files this Answer to Plaintiff's Motion to Compel Discovery Responses, by respectfully stating the following: 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. Defendant's objections were appropriate in that Plaintiff's Interrogatories requested information outside the scope of discovery. 5. Admitted. 6. Denied. The averments contained in Paragraph 6 are conclusions of law and fact to which no response is required. 7. Denied. The Order of Judge Lewis required Defendant to provide a list of cases in which Dr. Eagle had performed independent medical examinations for the defense firm and/or the insurance company from the date of the accident. 8. Admitted. 9. Admitted. By way of further response, Plaintiff in the Griffin v. Strausser case had requested all reports authored by Dr. Eagle. Judge Lewis specifically restricted the amount of material which was produced. The Order limits the material to be produced to since the date of the accident, and the order does not compel an answer to the Interrogatory requesting information as to the sums paid to Dr. Eagle from the years 1994 to present by the insurance company. 10. Denied. The averments contained in Paragraph 10 are conclusions of law and fact to which no response is required. 11. Denied. The averments contained in Paragraph 11 are conclusions of law and fact to which no response is required. 12. Denied. The averments contained in Paragraph 12 are conclusions of law and fact to which no response is required. 13. Admitted in part, denied in part. It is admitted as to the "Pa. R.C.P. 40019". It is denied that Defendant has failed to make discovery within the Rules of Civil Procedure. 2 14. Denied. The averments contained in Paragraph 14 are conclusions of law and fact to which no response is required. 15. Admitted. 16. Admitted. WHEREFORE, Defendant respectfully requests that Plaintiff's Motion to Compel Discovery Responses be denied. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. B 4Jeerson J. Shipma , Esquire 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant DATE : I 'yZ 12 46910.1 3 VERIFICATION PURSUANT TO PA. R.C.P. NO. 1024(c) JEFFERSON J. SHIPMAN, ESQUIRE, states that he is the attorney for Ian F. Heverly, the party filing this Answer; that he makes this affidavit as an attorney, because the party he represents lacks sufficient knowledge or information upon which to make a verification and/or because he has greater personal knowledge of the information and belief than that of the party for whom he makes this affidavit; and that he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. l Jef fer on J. Shipman DATE: 64A00 39950.1 BRENDA K. BRYNER, Plaintiff V. IAN F. HEVERi_Y, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-4672 CIVIL TERM AND NOW, this 3151 day of July, 2000, upon consideration of the attached letter from Richard A. Sadlock, Esq., attomey for Plaintiff, the discovery conference/hearing previously scheduled for August 2, 2000, is cancelled. BY THE COURT, Richard A. Sadlock, Esq. 4503 N. Front Street Harrisburg, PA 17110 Attorney for Plaintiff Jefferson J. Shipman, Esq. 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorney for Defendant :rc 'I-iI-O(]:IO:J5oM: nlii.i Nf1 nN[t F(1VNEF ;23H 2169 tt 2/ 2 ANGINO & ROVNER, P.C. j 4503 NORTH FRONTSMSEr RICHARD C. ANOIND DAVID S. VAMESIO lARRISBURO. FA 171 L0470H NEIL]. ROVNER NUOLE C. OMN JOSEPH M. MELILLO MICHAEL). NAVI'ISRY 7 17/238 47 91 TERRY S. HYMAN J REPH M. DORIA FAX 717/238.5610 DAVID L. LU Z DUANE S. BARIUM MIClIAEL P. KDRR JAMES DEONn W W W,ANO W 6ROVNER.COM RICHARD A. SADLOM &MAIL, RRADLGMRANDWD,RDVNEn.COEI July 31, 2000 VIA FAX: 240-6462 The Honorable J. Wesley Oler, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Re: Brenda K. Bruner v. Ian F. Heverly No.: 99-4572 Civil Term Dear Judge Oler: Defense counsel has now agreed to respond to Plaintiffs Second Set of Interrogatories in the above- captioned action. Therefore, there will be no need for the hearing currently scheduled for August 2, 2000. Please do not hesitate to contact me should you have any questions. Very A. Sadlock RAS/mlb cc: Jefferson J. Shipman, Esquire (via fax: 234-6810) 217499.1UtASkML3 V?L 3 1 ft PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) ( X ) for JURY trial at the next term of civil court. ( ) for trial without a jury. CAPTION OF CASE (entire caption must be stated in full) (check one) ( ) Assumpsit ( ) Trespass (X ) Trespass (Motor Vehicle) BRENDA K. BRYNER VS. (Plaintiff) (other) The trial list will be called on egg IAN F. HEVERLY VS. (Defendant) and Trials commence on October 30, 2000 Pretrials will be held on October 18, 2000 (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No. 4679 _ Civil 19 99- .. Indicate the attorney who will try case for the party who files this praecipe: Jefferson J. Shipman Indicate trial counsel for other parties if known: Richard A._Sadlock_- This case is ready for trial. Date: SeR{- ----- Signe Print Name: Jefferson J. Shipman Attorney for: Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been duly served upon the following counsel of record by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, on September 11, 2000: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiffs GOLDBERG, KATZMAN & SHIPMAN, P.C. Je e on J. Shipman, Esquire 320 Market Street Harrisburg, PA 17108 Attorneys for Defendant 'telephone: (717) 234-4161 Identification No.: 51785 28115.1 J V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRENDA K. BRYNER, Plaintiff V. IAN F. HEVERLY, Defendant TO THE PROTHONOTARY: CIVIL ACTION - LAW NO. 99-4672 CIVIL TERM JURY TRIAL DEMANDED PRAECIPE Please mark the above-captioned action as settled, satisfied, and discontinued and issue a Certificate of Settlement. 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff Date: November 8, 2000 222702.IIRASIMI.n I.D. No. 47281 CERTIFICATE OF SERVICE I, Marcy L. Brymesser, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFF'S PRAECIPE TO DISCONTINUE on the following via postage prepaid, first class United States mail, requested addressed as follows: Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Marcy L. Brymessrr? Date: November 8, 2000 222702.1\RAS\MLn .:, i:'. E? ,, r c: ?. ?., i- - ,._ ?.i !; ? r : ? :(?i -_ !? - ] ?? J U ._ r_7