The URL can be used to link to this page

Home My WebLink About99-05513 Q?.I S( 1 i 1A M1 Y ){ i y- C4f? y V *Fv ? y ??'21e fo Y ;I F , ?'Y , t f l 5 #v w rv ` 1 , j"v m 4 G ?^ Kv??n }f r c41t° 4 ^ L i5 dp F t. YC `C vi tf p I Qr Y K f I ?. l /? 1 u . , ?y A SHERIFF'S RETURN - REGULAR CASE NO: 1999-05513 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WHITTEN JOHN M ET AL VS. YEN VANSCYOC JEUNG BRIAN BARRICK Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon VANSCYOC JEUNG YEN the defendant, at 18:00 HOURS, on the 22nd day of September 1999 at 161 SPRINGFIELD ROAD SHIPPENSBURG PA 17257 CUMBERLAND County, Pennsylvania, by handing to JEUNG YEN VANSCYOC a true and attested copy of the WRIT OF SUMMONS and at the same time directing His attention to the contents thereof. Sheriff's Coats: So answers- Docketing 18.00 Service 13.02 Affidavit Surcharge 8.00 ? I? RBI' m u 1 Sail-0-- 9 RY L.9gILLER 23/19 by u y Sworn and subscribed o before me this -23.+..'- day of Ad? 19 99 A.D..? Q ? '-s- L( GOU I 0 4 -?-Er non?e?y 99HB600122 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number. (717) 731-0988 Attornevs fnr nefendsnt JOHN M. AND TE m L. WHTITEN, SHAYNE IN THE COURT OF COMMON PLEAS C. WRITTEN, A MINOR, BY AND THROUGH CUMBERLAND COUNTY, PENNSYLVANIA HIS PARENTS, JOHN M. AND TE W L. WM EN, PLAWnFFS No. 99-5513 CmL TERM VS. JEUNG YEN VANSCYOC, CIVIL ACTION - LAW DEFENDANT JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendant, Jeung Yen Vanscyoc. Respectfully submitted, LAW OFFICES OF JACOBS & SABA Donald R. Dorer, Esquire Attorney for Defendant Identification No. 39126 Date: October 12. 1999 99HR-00122 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 JOHNM. AND TERM L. WRITTEN, SHAYNE C. WBTTTEN, A MINOR, BY AND THROUGH HIS PARENTS, JOHN M. AND TERM L. WHTTTEN, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JEUNG YEN VANSCYOC, DEFENDANT No. 99-5513 CIVIL TERM CTVH, ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Entry of Appearance to be served by regular first class mail upon: Marla K. Miller, Esquire Miller & Miller, P.C. 1423 State Road, P.O. Box 40 Duncannon, PA 17020 Date: October 12. 1999 I- Al -"- Donald R. Dorer, Esquire Attorney for Defendant w`?? c?; ?'•r _ is-. ?. i-- ? _• c, "7a m i e? o m ip ? ? ao a C ®? ? n n ?e0'?v'ixFC J U y a N U 4. 99HB-00122 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number. (717) 731-0988 IN THE COURT OF COMMON PLEAS JOHN M. AND TERRI L. WE=N, SHAYNE CUMBERLAND COUNTY, PENNSYLVANIA C. WHITPEN, A MINOR, BY AND THROUGH ms PARENTS, JOHN M. AND TERRI L. WWrrEN, PLAILPIIFFS No. 99-5513 CIVIL TERM VS. JEUNG YEN VANSCYOC, CmLACTION - LAW DEFENDANT II JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please enter a RULE upon plaintiffs to file the entry of a Judgment of Non Pros. I Date: October 12. 1999 Donald R. Dorer, Esquire Attorney for Defendant or suffer RULE To FILE CoMPLA1Nf AND NOW, this /; +"y of entered upon the Plaintiffs to file a Comp suffer the entry of a Judgment of Non Pros. Z.+ "A/ 1999 a RULE is hereby herein within 20 days after service hereof or ??CI PROTHONOTARY U GaF 99BB-00122 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number. (717) 731-0988 JOHN M. AND TERRI L. Wmr EN, SHAYNE 11 IN THE COURT OF COMMON PLEAS C. WHTTTEN, A MINOR, BY AND THROUGH CUMBERLAND COUNTY, PENNSYLVANIA HIS PARENTS, JOHN M. AND TERRI L. WHTITEN, PLAINTIFFS VS. No. 99-5513 CIVIL TERM JEUNG YEN VANSCYOC, DEFENDANT CIVIL ACTION - LAW JURY TRW DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecipe for Rule to File gMgWnt to be served by ragular first class mail upon: Marla K. Miller, Esquire Miller & Miller, P.C. 1423 State Road, P.O. Box 40 Duncannon, PA 17020 Date: October 12. 1999 Attorney for Defendant F-' J Li I V L ... 4? H r m a ' .?ao 4au uv?a= a W? m (n 0 y S f .,j I? l? i 61 Z j wy " W tiN U r w LARRY L. MILLER, ESQUIRE Pa. Supreme Court I.D. No MARLA K. MILLER, ESQUIRE Pa. Supreme Court I.D. No P.O. Box 40 Duncannon, PA 17020 Telephone: [717]957-2828 Fax: [717]957-4843 28122 47433 Attorneys for Plaintiffs JOHN M. and TERRI L. WHITTEN IN THE COURT OF COMMON PLEAS 630 Conodoquinet Avenue OF PENNSYLVANIA Carlisle, PA 17013 CUMBERLAND COUNTY and SHAYNE C. WHITTEN, a minor, t by and through his parents, DOCKET NO: t7 G - .SJ i 3 l John M. and Terri L. Whitten 630 Conodoquinet Avenue Carlisle, PA 17013 Plaintiffs: V. JEUNG YEN VANSCYOC 161 Springfield Road Shippensburg, PA 17257 Defendant TO: PROTHONOTARY OF SAID COURT: Please issue a Writ of Summons to the above-named Defendant and forward it to the Cumberland County Sheriff for service at 161 Springfield Road, Shippensburg, PA 17257. DATE: September 8, 1999 By: MARLA K. MILLER L.. r_ C•1 .::?i? 1l: - .. V_? ?ltl. O t. ? V I r W O •ro - Commonwealth of Pennsylvania County of Cumberland John M. and Terri L. Whitten, Shayne C. Whitten, a minor, by and through his parents, John M. and Terri L. Whitten Court of Connnon Pleas va Jeung Yen Vanscyoc No. ....... 19____ 161 Springfield Road In ---- Ci_v_il_Agtign_ __Law Shippensburg PA 17257 To --_,Jeung•_Yao_ Van&cyac________________ You are hereby notified that John M. & Terri L. Whitten, Shavne C. Whitten, minor, b- and through his parentsl__John_M. & Terri_I,_ W)yi ?------- the Plaintif8 hive commenced an action in ------- SUMMQD,3_ __LiYil__&ata.OIL____LAW against you which you are required to defend or a default judgment may be entered against you. (SEAL) .-_ ___ _CAUBMIR_R.1ODiCt_____---- Date ________ September 9 , 19___99 By El FI ri U M , Ln N N of 0% A -r. 4)N N4) 4) OYN a+ G C 4J 4J -H 4) -H E WA sma - E0.4 a O -H .H 4J x 'u N 4J N C 7 N F 3 N F .a y" .a U a+ x > 0x O S. >, O h In 10h d U U m C 47 C 4) N 01 G a n ?l a r O •rl 4J Q i H .rq I >I U N !4 ?O a .. LARRY L. MILLER, ESQUIRE Pa. Supreme Court I.D. No. 28122 MARLA K. MILLER, ESQUIRE Pa. Supreme Court I.D. No. 47433 P.O. Box 40 Duncannon, PA 17020 Telephone: [717]957-2828 Attorneys for Plaintiffs Fax: [717]957-4843 JOHN M. WHITTEN, IN THE COURT OF COMMON PLEAS TERRI L. WHITTEN, and IN PENNSYLVANIA SHAYNE C. WHITTEN, a minor CUMBERLAND COUNTY by and through his parents John M. and Terri L. Whitten DOCKET NO: 99-5513 Civil Term Plaintiffs: V. JEUNG YEN VANSCYOC Defendant : YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 717-240-6200 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viento (20) dias de plazo al partir de le fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la Corte en forma escrita sus defensas o sus objectiones a las demandas en contra de su persona. Sea advisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo adviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demands. Usted puede perder dinero o es propiedades o otros derechos importantes para usted. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 717-240-6200 1 ? DATE: Novemher 9, 1999 By: --MAR-LA K. M LL ER LARRY L. MILLER, ESQUIRE Pa. Supreme Court I.D. No. 28122 MARLA K. MILLER, ESQUIRE Pa. Supreme Court I.D. No. 47433 P.O. Box 40 Duncannon, PA 17020 Telephone: [717]957-2828 Attorneys for Plaintiffs Fax: [717]957-4843 JOHN M. WHITTEN, IN THE COURT OF COMMON PLEAS TERRI L. WHITTEN, and IN PENNSYLVANIA SHAYNE C. WHITTEN, a minor CUMBERLAND COUNTY by and through his parents John M. and Terri L. Whitten DOCKET NO: 99-5513 Civil Term Plaintiffs: V. JEUNG YEN VANSCYOC Defendant 1. Plaintiffs, Terri L. Whitten ("Mrs. Whitten") and John M. Whitten ("Mr. Whitten"), were at all times mentioned and are now husband and wife, and reside at 630 Conodoquinet Avenue, Carlisle, Cumberland County, Pennsylvania. 2. Plaintiff, Shayne C. Whitten ("Shayne"), is a minor child of Mrs. Whitten and Mr. Whitten, and at all times mentioned and now resides at 630 Conodoquinet Avenue, Carlisle, Cumberland County, Pennsylvania. fi? 3. Jeung Yen Vanscyoc ("Defendant") was at all times mentioned and is now a resident at 161 Springfield Road, Shippensburg, Cumberland County, Pennsylvania. 4, At all times relevant hereto, Mrs. Whitten was the owner of a 1987 Dodge Caravan, license number PAC-779. 5. , At all times relevant hereto, Defendant was the owner of a 1994 Toyota Canary, license number SCYOC. 6. Ritner Highway, running east and west, and Allen Road, running north and south, were and are intersecting public streets and highways located in Cumberland County, Pennsylvania. 7. On September 27, 1998, at approximately 2:34 p.m., Mrs. Whitten was traveling north on Allen Road and Shayne was a passenger in her vehicle. 8. At such time and place, the signal displayed for traffic proceeding north on Allen Road a green light and the signal displayed for traffic proceeding westerly on Ritner Highway a red light. 9. Mrs. Whitten entered the intersection and proceeded across Ritner Highway with the green light for traffic proceeding in her direction. 10. Defendant, traveling west on Ritner Highway, entered the intersection and attempted to drive across Allen Road after the signal for traffic proceeding in Defendant's direction on Ritner Highway was red, thereby colliding violently with Mrs. Whitten's vehicle. At such time and place, Defendant operated her automobile into the intersection when she did not have a green light for e n. traffic approaching from her direction and failed to stop her automobile at the entrance of the intersection as required by law. 11. As a direct result of Defendantis unlawful conduct of driving through the red light, she caused the accident that resulted in severe and permanent injuries and damages to Plaintiffs. 12. Upon the violent impact of Defendants vehicle, Shayne was forcibly thrown approximately thirty feet from his mothers vehicle and suffered very severe and permanent injuries as a direct result of the accident. 13. Mrs. Whitten was trapped in her destroyed vehicle and also suffered permanent injuries from the impact of the collision. 14. Both Mrs. Whitten and Shayne were transported by Life Lion to Hershey Hospital as their injuries from the accident were life threatening. 15. The accident was directly and proximately caused by the negligence, unlawful acts, recklessness, and carelessness of Defendant, which consisted, among other things, of the following: (a) operating her motor vehicle in a careless, reckless, unlawful, and negligent manner; (b) not having her motor vehicle under the proper control so as to stop said vehicle within the assured clear distance ahead; (c) operating her motor vehicle without due regard to the rights, safety, and position of Mrs. Whitten's vehicle; (d) failing to have her motor vehicle under the proper control so as to prevent her vehicle from striking Mrs. Whitten's vehicle; (e) failing to keep a proper lookout; (f) failing to use due care under the circumstances; (g) failing to notice the motor vehicle of Mrs. Whitten; (h) failing to stop at a red traffic signal; (i) failing to take evasive action in order to avoid impacting with Mrs. Whitten's vehicle; and, (j) failing to yield the right-of-way to Mrs. Whitten who was lawfully in the intersection, in violation of and in contravention of the provisions of the relevant Pennsylvania statutes. 16. At all times material hereto, Mrs. Whitten acted with due care-and was not in any way contributorily negligent. 17. Mrs. Whitten incorporates by reference paragraphs 1 through 16 of this complaint as if set forth in their entirety. 18. As a direct result of Defendant's misconduct, Mrs. Whitten suffered and continues to suffer from severe and disabling injuries, including, but not limited to: abrasions and contusions, multiple rib fractures, pulmonary contusion, right pneumothorax, right hemothorax, right acetabular fracture, liver laceration, elbow laceration, closed head injury, injuries to her teeth, and psychological and emotional injuries and damages. By reason of the collision, Mrs. Whitten was injured internally and externally of a permanent and lasting nature. As a direct result of these injuries, she has undergone extensive hospitalization and medical care and treatment and has incurred substantial medical bills and related expenses. 19. As a direct result of Defendant's misconduct, Mrs. Whitten has suffered intense and excruciating pain and mental anxiety, has become highly nervous, restless, and is unable to sleep. Also, she is unable to drive or be a passenger when in congested traffic due to her mental anxiety. 20. As a result of the great bodily pain, it has become necessary for Mrs. Whitten to be treated at a pain clinic and to be administered sedatives in an attempt to relieve her unbearable physical pain and suffering. 21. All such resulting pain, suffering, and discomfort resulted wholly and entirely from Defendant's misconduct and the accident that was caused by Defendant's recklessness. 22. Mrs. Whitten's injuries are permanent, and she will continue to suffer such intense pain, inconvenience, and agony as a result of such injuries during the remainder of her life. 23. Mrs. Whitten sustained serious injuries in the accident which resulted in and caused serious impairment of her bodily functions and permanent serious disfigurement. 24. As a direct result of Defendant's misconduct, Mrs. Whitten has been unable to carry on her duties for some time and believes that in the future she will be unable to, and hindered in carrying out her duties at work and home. 25. Also, as a direct result of Defendant's misconduct, Mrs. Whitten will suffer from the disfigurement of her significant scars and the embarrassment and emotional distress related thereto. 26. As a direct result of the collision and Defendant's negligent, careless, and reckless conduct, Mrs. Whitten has and in the future will suffer an interruption of her daily habits, pursuits, and enjoyment of life's pleasures to her great and permanent detriment and loss. 27.• As a direct and proximate result of the accident and Defendant's reckless misconduct, Mrs. Whitten has incurred significant medical expenses including, doctor's and dentist's bills, hospital bills, ambulance fees, medical traveling expenses, drugs and other expenses, and in the future will continue to incur expenses for medical treatment in an amount not yet ascertained. 28. Mrs. Whitten is informed and believes, and on that basis alleges, that it will be necessary for her in the future to expend further sums of money for medical attention and care and that she will have pain and suffering for the rest of her life as a direct result of Defendant's misconduct. 29.. Also, as a direct and proximate result of Defendant's misconduct, Mrs. Whitten has suffered a loss of earnings and earning capacity. 30. Mrs. Whitten suffered, suffers, and will in the future continue to suffer great pain of body and mind. Plaintiff will suffer from disfiguration, humiliation, and embarrassment and all of such injuries and effects are serious and permanent and the use and function of all of such parts and organs is seriously and permanently diminished, impaired, and made painful, all to her injury and damage. 31. Mrs. Whitten made demand for compensation of the aforesaid injuries, damages, and losses, which Defendant has failed and refused and still refuses to pay. WHEREFORE, by reason of the injuries to Terri L. Whitten and damages to her motor vehicle, Terri L. Whitten demands judgment against the Defendant in an amount in excess of the local arbitration limit. 32. Mr. Whitten incorporates by reference paragraphs 1 through 31 of this Complaint as if set forth in their entirety. 33. The recklessness, careless, and unlawful actions of Defendant caused the injuries to Mr. Whitten's spouse, Mrs. Whitten. Because of the injuries suffered, Mr. Whitten has lost and been deprived of the services of his spouse and he will continue to be permanently so deprived of the comfort and solace usually provided by a spouse in good health, to his great detriment and loss. 34. Mr. Whitten has sustained great and irreparable loss and will be deprived for the remainder of his life of the society, companionship, consortium, and services of his spouse, for all of which loss, deprivation, injury and damage is the direct result of the misconduct of Defendant. 35. As a result of the injuries to Mr. Whitten's spouse, Mr. Whitten has become obligated for the costs of hospitalization, medicine, and other medical care and treatment of his wife including, doctor's and dentist's bills, hospital bills, nurses' and ambulance fees, medical traveling expenses, and other expenses and will be obligated to incur bills and expenses for medicines, medical care, and treatment in the future. 36. Mr. Whitten made demand for compensation of the aforesaid injuries, damages, and losses, which Defendant has failed and refused and still refuses to pay. WHEREFORE, John M. Whitten demands judgment against Jeung Yen Vanscyoc in an amount in excess of the local arbitration limit. 37. Shayne incorporates by reference paragraphs 1 through 36 of this Complaint as if set forth in their entirety. 38. As a direct result of the Defendant's misconduct, Shayne, a minor, has suffered and continues to suffer severe and disabling injuries, including, but not limited to: arm lacerations, bone fractures, closed head injury, elbow lacerations, leg laceration, soft tissue avulsion, bruises and contusions, injuries to his teeth, and extreme mental anguish. As a direct result, he has undergone extensive hospitalization and medical care and treatment which has resulted in substantial medical bills and related expenses. 39. Shayne sustained serious injuries in the accident which resulted in and caused serious impairment of his bodily functions and permanent serious disfigurement. 40. Shayne's arm was forcibly driven through the vehicle's window glass and the muscles and tendons of his arm were cut and severed in many places from his armpit down the arm and forearm. Shayne was immediately hospitalized and received medical and surgical treatment, but he has not regained the full use of his arm or hand and will never do so. 41. By reason of the injuries, Shayne was compelled to undergo surgical procedures and it was necessary that skin be grafted to portions of his arm. He was compelled to undergo injections of serums and antitoxins and to submit to anesthetics to undergo a skin graft to his arm and was caused to permanently lose partial use of his hand and arm. Shayne permanently suffers from a disfiguring, grotesque scar on his arm. 42. As a proximate result of Defendant's recklessness, Shayne has suffered permanent disfigurement which has necessitated a skin graft and which will require additional plastic surgery. These serious injuries have caused him great mental anguish, suffering, embarrassment, and humiliation. 43. As a direct result of the extensive injuries he suffered because of Defendant's misconduct, an internal fixation device, including two metal plates and approximately twelve screws, were placed in Shayne's arm. Still, the use of his arm and hand remains permanently impaired. 44. As a direct result of Defendant's misconduct, Shayne's arm will be permanently scarred and damaged. He has lost a significant amount of grip and pinch strength and will suffer problems with his damaged arm for the rest of his life. 45. Shayne will permanently suffer from and be embarrassed by the large and disfiguring scars and change in his appearance and lifestyle directly due to the accident. 46. Prior to sustaining the injuries, Shayne, who was fifteen at the time of the accident, was an attractive, active young adult in perfect health and in great physical condition, and had every reason to anticipate and expect a fine, healthy, happy, and useful life. 47. Prior to the accident, he was a good student and athlete. 48. As a direct and proximate result of the misconduct of the Defendant, Shayne has been prevented and will continue to be prevented from engaging in his usual activities, studies, schooling, avocations, social and sporting activities, and occupations. 49. As a direct and proximate result of the collision and Defendant's negligent and reckless conduct, Shayne has, and in the future will suffer an interruption of his daily habits, pursuits, and enjoyment of life's pleasures. Since the accident and resulting injuries, Shayne has undergone a profound change and is no longer able to carry on his normal schooling and social intercourse as he formerly did. 50. As a direct and proximate result of the misconduct of the Defendant, Shayne has suffered and will continue to suffer great pain, mental anguish, disfigurement, anxiety, embarrassment, emotional upset, and other functional disturbances, together with the loss of well-being, and the restrictions on his ability to engage in his normal activities and to pursue the normal pleasures of life, all of which are and will be to his great detriment and loss. 51. Shayne's injuries are permanent and he will continue to suffer great physical and mental pain and agony as a result of the injuries for the remainder of his natural life. 52. As a direct and proximate result of the collision and Defendant's misconduct, Shayne has incurred, and in the future will incur expenses for medical treatment including, doctor's bills, hospital bills, nurses' and ambulance fees, medical traveling expenses, drugs, and other expenses in an amount not yet ascertained. 53. As a direct result of Defendant's misconduct, Shayne has suffered, and will continue for the rest of his life, a severe loss of his earnings power and capacity. 54. Plaintiffs have made demand for compensation of the aforesaid injuries, damages, and losses, which Defendant has failed and refused and still refuses to pay. WHEREFORE, Shayne Whitten, by and through his parents John M. and Terri L. Whitten, demand judgment against the Defendant in an amount in excess of local arbitration limit. 55. Mr. and Mrs. Whitten incorporate by reference paragraphs 1 through 54 of the Complaint as if set forth in their entirety. 56. As a direct and proximate result of the misconduct of the Defendant, Mr. and Mrs. Whitten have been, and will be deprived of the care, company, contributions, companionship, consortium, society, and assistance of their minor son, Shayne. 57. As a direct result of Defendant's misconduct, and the accident and resulting injuries suffered by Shayne, Mr.. and Mrs. Whitten, parents of Shayne, have become obligated for the costs of hospitalization and other medical care and treatment of their minor son including, doctor's and dentist's bills, rehabilitation bills, hospital bills, nurses' and ambulance fees, medical traveling expenses, drugs, and other expenses and will be obligated to incur bills and expenses for medicines and medical care and his treatment in the future. 58. Additionally, as a direct and proximate result of the misconduct and carelessness of Defendant, as described above, the earnings of Shayne will be impaired during the period of his minority, to which earnings, Mr. and Mrs. Whitten are legally entitled, all of which is and will be to their great detriment. 59. Mr. and Mrs. Whitten made demand for compensation of the aforesaid injuries, damages, and losses, which Defendant has failed and refused and still refuses to pay. WHEREFORE, John M. and Terri L. Whitten demand judgment against the Defendant in an amount in excess of the local arbitration limit. DATE: November 9, 1999 By: r- - LARRY MILLER MARLA K. MILLER e% Pol V LE1 0 f, TERRI L. WHITTEN, have read the foregoing COMPLAINT. The roctual statements contained therein are true and correct. This Verification is wade Subject to the penalties of is Pa. Cons. $tat. °ectlun 4904 relating to unsworn falsification to authorities, which provides that if I knowingly make false averments, 11nry be subject to criminal penalties. Date: 9y. T ' HI .. NW-09-1999 20:25 95: P.01 ern P01 1, JOHN H. WHSTTSN, have read the foregoing CO!MPLUNT. The !actual statements contained therein ¦ce true and correct. This Verification is made subject to the penalties of la Pa. Cons. Stat. Section 4904 relating to uneworn falsification to authoritien, which provides that if I knowingly make fmise averments, : may be subject to criminal penalties. Date: 9y: JOHN ?-f_. TOTFL P. 17 NOU-09-1999 20:29 95% P.01 The undersigned attorney, offering the attached, certifies that the affiant or person signing the document acknowledged the genuineness of the signature and that the document or a copy with an original signature affixed will be filed if requested by the Court or a party. I hereby certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. DATED: November 9, 1999 1? ?/ lil MAR I. MILLER I HEREBY CERTIFY that I served a true and correct copy of the foregoing COMPLAINT upon counsel of record this of day of November, 1999 by placing the same in the United States Mail, CERTIFIED mail, postage prepaid, addressed as follows: Donald R. Dorer, Esquire Law Office of Jacobs & Saba 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 9y: ?- ?, r: ._ ?-: U ? ?-' F ?? - r1 ; . ?; L , ? -' r-: ? ; c> ?_ 4 ' C_i T 49HB-00122 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number. (717) 731-0988 JOHN M. AND TERRI L. WHIITEN, SHAYNE C. WRITTEN, A MINOR, BY AND THROUGH HIS PARENTS, JOHN M. AND TERRI L. WHITTEN,PLAINTIFn IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. JEUNG YEN VANSCYOC, DEFENDANT No. 99-5513 CrvII. TERM Ctvu. ACTION - LAw JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANT, RUNG YEN VANSCYOC, TO PLAINTIFFS' COMPLAINT 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. - 59. Denied. These paragraphs are generally denied pursuant to Pa.R.C.P. §1029(e). WHOWORE, the Defendant respectfully prays this Honorable Court to dismiss Plaintiffs' Complaint, and to enter judgment against the Plaintiffs and in favor of the Defendant. Nzw MATTER 60. Paragraphs 1 through 59 are incorporated herein by reference, and made a part hereof as if set forth in full. 61. Plaintiff's claims are barred in whole or in part by the provisions of the Pennsylvania No-Fault Motor Vehicle Insurance Act and/or the Pennsylvania Motor Vehicle Financial Responsibility law. WHEREFORE, the Defendant respectfully prays this Honorable Court to dismiss Plaintiffs' Complaint, and to enter judgment against the Phrintiffs and in favor of the Defendant. Respectfully submitted, LAW $yt? Dfor Defendant Identification No. 39126 Date: November 12. 1999 99BB-WI22 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp HID, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant JOHN M. AND TERRI L. WHTTTEN, SHAYNE C. WHITTEN, A MINOR, BY AND THROUGH HIS PARENTS, JOHN M. AND TERRI L. WHITTEN, PLAINTIFFS VS. JEUNG YEN VANSCYOC, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-5513 MuL TERM CPAL AcrIoN - LAw JURY TRIAL DEMANDED VERIFICATION DONALD R. RORER, ESQUIRE, hereby states that he is the attorney for the Defendant in this action, and is authorized to verify that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities. DONALD R. RORER, ESQUIRE Attorney for Defendant Dated: November 12. 1999 99HB-00122 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 JOHN M. AND TERRI L WRITTEN, SHAYNE IN THE COURT OF COMMON PLEAS AND COUNTY, PENNSYLVANIA C. WHITTEN, A MINOR, BY AND THROUGH CUERL HIS PARENTS, JOHN M. AND TERRI L. WHITTEN, PLAINTIFFS VS. I No. 99-5513 CIVIL TERM JEUNG YEN VANsCYOC, DEFENDANT CIVH, ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Answer with New Matter of Defendant Jeun¢ Yen Van jWc to Pl mad upon: aintiffs' ompl 'nit _ to be served by regular first cuss Marla K. Miller, Esquire Miller & Miller, P.C. 1423 State Road, P.O. Box 40 Duncannon, PA 17020 Date: _November 12. 1999 i Zt/onald R. Dorer, Esquire Attorney for Defendant (j C Z I: U cn ON CJ .r a O y e r'=?t? . m z ? .. U`n h.?L '? .. a n r7 Q ti L v % tiN U W 99BB-00122 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number. (717) 731-0988 JOHN M. AND TERRI L. WHr1TEN, SHAYNE C. WHI TEN, A MINOR, BY AND THROUGH HIS PARENTS, JOHN M. AND TERRI L. WHITTEN, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JEUNG YEN VANSCYOC, DEFENDANT No. 99-5513 CIVH. TERM CIVIL ACCION - LAW JURY TRIAL DEMANDED PRAECIPE TO ATTACH VERIFICATION TO ANSWER WITH NEW MATTER OF DEFENDANT, JEUNG YEN VANSCYOC, TO PLAINTIFFS' COMPLAINT TO THE PROTHONOTARY: Kindly file the attached Verification to Answer with New Matter of Defendant, Jeung Yen Vanscyoc, to Plaintiffs' Complaint filed with this Court on or about November 19, 1999 in the above referenced matter. Respectfully submitted, Date November 23. 1999 Attorney for Defendant Identification No. 39126 99BB-00122 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number. (717) 731-0988 JOHN M. AND TERRI L WRITTEN, SHAYNE IN THE COURT OF COMMON PLEAS C. WRITTEN, A MINOR, BY AND THROUGH CUMBERLAND COUNTY, PENNSYLVANIA HIS PARENTS, JOHN M. AND TERM L WHITTEN, PLAINTIFFS Vs. No. 99-5513 Crim TERM JEUNG YEN VANSCYOC, DEFENDANT CML ACTION - LAW JURY TRW, DEMANDED VERIFICATION I, Jeune Yen Vanscyoc , verify that the statements made in the foregoing Answer with New Matter of Defendant Je• pp Yen Va_nacyoc t Plaintiffs' Complaint , which are within the personal knowledge of the undersigned, are true and correct, and as to the facts based on the information of others, the undersigned, after diligent inquiry, believe them to be true. And further, this Verification is signed on the recommendation of my attorneys, who advise me that the allegations and language in this document are inquired legally to raise issues for resolution at trial, by the Court, or by continuing investigation and preparation for trial. I understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete and I leave the determination of these matters to my attorneys on their advice. I understand that all statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unswom falsifications to authorities. U?1 L Ming en Vanscyoc 991113-00122 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 JOHN M. AND TERRI L WRITTEN, SHAYNE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA C. WHITTEN, A MINOR, BY AND THROUGH HIS PARENTS, JOHN M. AND TERRI L. WRITTEN, PLAINTIFFS VS. No. 99-5513 CIVIL TERM JEUNG YEN VANSCYOC, DEFENDANT CIVIL ACTION- LAW JURY TRW DEMANDED CERTIFICATE OF SERVICE Donald R. Borer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecipe to Attach Verification to Answer with New Matter of Defendant. Jeung Yen Vansevoc to Plaintiffs' Complaint to be served by regular first class mail upon: Marla K. Miller, Esquire Miller & Miller, P.C. 1423 State Road, P.O. Box 40 Duncannon, PA 17020 Date: November 23. 1999 Donald R. Dorer, Esquire Attorney for Defendant u C17 1 CL C\j U c m J U e ? m ' '?aoa ^ O C u M ? t".Og myO n win n n N S ? _ ca Z < O ? VJ a"i tom" y .7 U a ^ ? N U v W I CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE MATTER OF: COURT OF COMMON PLEAS JOHN M. 6 TERRI L. WHITTEN, ET AL- AUTO TERM, 0 -VS- CASE NO: 99-5513 JEUNG YEN VANSCYOC - VANSCYOC As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER 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: 04/03/2000 DONALD R. DORER ESQUIRE Attorney for DEFENDANT DE11-171396 2-3339-L 03_ COMMONWEALTH OF P E NN S YLVAN TA COUNTY OF C UMB E BLAND IN THE MATTER OF: COURT OF COMMON PLEAS JOHN M. & TERRI L. WHITTEN, ET AL- AUTO TERM, 0 -VS- CASE NO: 99-5513 JEUNG YEN VANSCYOC - VANSCYOC NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS PENN'S WOOD PHYSICAL THERAPY MEDICAL TIG INSURANCE COMPANY INSURANCE MILTON S. HERSHEY MEDICAL CTR. MEDICAL TO: MARLA R. MILLER, ESQUIRE MCS on behalf of DONALD R. DORER, 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: 03/14/2000 CC: DONALD R. DOREN. ESQUIRE - 99HB-00122 MARGARET DRISCOLL - MCS on behalf of DONALD R. DORER, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-116666 2 3 3 3 9- C O 1. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN M. AND TERRI L. WHITTEN, ET AL. VS JEUNG YEN VANSCYOC File No. 99-5513 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: PENN'S WOOD PHYSICAL THERAPY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, gttar%?ftfLrlq jl?ry the court to produce the following documents or things: at THE MCS GROUP INC., 1601 MARKET STREET, 11800, 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 DONALD R. DORER, ESQUIRE ADDRESS: 214 SENATE AVENUE SUITE 503 CAMP HILL PA 11011 TELEPHONE: (215) 246 - 0900 SUPREME COURT ID B: ATTOR'N'EY FOR: THE DEFENDENT BY THE COT DATE: ally /0 ?2P2"U Prothonotary/C rk ivil Division Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE DRIVE CARLISLE, PA 17013 RE: 23339 SHAYNE WHITTEN 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 : SEIAYNE WHITTEN 630 CONONDOGUINET AVENUE, CARLISLE, PA 17013 Social Security A 202-66-9091 Date of Birth: 11-22-1981 t?? SU10-239132 23339-7,01 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE NATTER OF: COURT OF COMMON PLEAS JOHN M. 6 TERRI L. WHITTEN, ET AL- AUTO TERM, 0 -VS- CASE NO: 99-5513 JEUNG YEN VANSCYOC - VANSCYOC As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, 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: 04/0312000 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DE11-171397 2 3 3 3 9- 1-0 2 COMMONWEALTH OF P E N N S YL VAN = A COUNTY O F CUM P E RLAN D IN THE MATTER OF: COURT OF COMMON PLEAS JOHN M. 6 TERRI L. WHITTEN, ET AL- AUTO TERM, 0 -VS- CASE NO: 99-5513 JEUNG YEN VANSCYOC - VANSCYOC NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS PENN'S WOOD PHYSICAL THERAPY MEDICAL TIG INSURANCE COMPANY INSURANCE HILTON S. HERSHEY MEDICAL CTR. MEDICAL TO: MARLA K. MILLER, ESQUIRE MCS on behalf of DONALD R. DOPER, 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: 03/14/2000 CC: DONALD R. DOPER, ESQUIRE - 99HB-00122 MARGARET DRISCOLL _ Any questions regarding this matter, contact MCS on behalf of DONALD R. DOPER ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-116666 2 3 3 3 9- C O 1. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN M. AND TERRI L. WHITTEN, ET AL. VS JEUNG YEN VANSCYOC File No. 99-5513 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: TIG PREMIER INSURANCE COMPANY (Name of Person or Entity) Within twenty (20) days after service of this subpcena,gg? rtDgfAgEy the court to produce the following documents or things: at THE MCS GROUP INC., 1601 MARKET STREET, #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: DONALD R. DORER, ESQUIRE ADDRESS: 214 SENATE AVENUE SUITE 503 CAMP HILL PA 17011 TELEPHONE: (215) 246 - 0900 SUPREME COURT ID k: ATTORNEY FOR: THE DEFENDENT BY THE COURT :nn DATE: t aA4.1" /U . &VV Prothonotary/Cler C MI Division N Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TIG INSURANCE COMPANY 70 W. MICHIGAN AVENUE BATTLE CREEK, MI 49017 RE: 13339 SHAYNE WHITTEN CLAIM NO.: A98156460 POLICY NO.: TRX33508717 Any and all claims files. Dates Requested: up to and including the present. Subject : SHAYNE WHMEN 630 CONONDOGUINEP AVENUE, CARLISLE, PA 17013 Social Security N: 202-66-9091 Date of Birth: 11-22-1981 Date of Loss: 09/27/1998 SU10-239134 23339-1-02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE NATTER OF: COURT OF COMMON PLEAS JOHN N. i TERRI L. NHITTEN, ET AL- AUTO TERM, 0 -Vs- CASE NO: 99-5513 JEUNG YEN VANSCYOC - VANSCYOC As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 NCS on behalf of _DONALD R. DORER, 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: 04/03/2000 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DEII-171398 23339-L O: C OMMO NWEAI,T H OF P E N N S Y L VA N I A COUNTY OF CUMBERI-AND IN THE MATTER OF: COURT OF COMMON PLEAS JOHN M. 6 TERRI L. WHITTEN, ET AL- AUTO TERM, 0 -VS- CASE NO: 99-5513 JEUNG YEN VANSCYOC - VANSCYOC NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS PENN'S WOOD PHYSICAL THERAPY MEDICAL TIC INSURANCE COMPANY INSURANCE MILTON S. HERSHEY MEDICAL CTR. MEDICAL TO: MARLA R. MILLER, ESQUIRE MCS on behalf of DONALD R. DORER, 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: 03/14/2000 CC: DONALD R. DORER, ESQUIRE. - 99118-00122 MARGARET DRISCOLL Any questions regarding this matter, contact MCS an behalf of DONALD R. DORER, ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-116666 2 3 3 3 9- C O 1. l COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN M. AND TERRI L. WHITTEN, ET AL. VS JEUNG YEN VANSCYOC File No. 99-5513 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: THE MILTON S. HERSHEY MEDICAL CENTER (Name of Penon or Entity) Within twenty (20) days after service of this subpoena, ME AT rderAdDy the court to produce the following documents or things: at THE MCS GROUP INC., 1601 MARKET STREET, 11800, 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: DONALD R. DORER, ESQUIRE ADDRESS: 214 SENATE AVENUE SUITE 503 CAMP HILL PA 17011 TELEPHONE: (215) 246 - 0900 SUPREME COURT ID ATTORNEY FOR: THE DEFENDENT BY THE COURT: DATE /Y(Au L. /U ::-07/71 Prothonn7otary/C rktivil Division Deputy Seal of the Court (Eff. 7/97) .r?fa EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MILTON S. HERSHEY MEDICAL GTR. 500 UNIVERSITY DRIVE PO BOX 850 HERSHEY, PA 17033 RE: 23339 SHAYNE WHITTEN Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject : SHAYNE WHITTEN 630 CONONDOGUINMT AVENUE, CARLISLE, PA 17013 Social Security k: 202-66.9091 Date of Birth: 11-22-1981 SU10-239136 23339-L03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE NATTER OF: COURT OF COMMON PLEAS JOHN N. 6 TERRI L. WHITTEN. ET AL- AUTO TERN, 0 -VS- CASE NO: 99-5513 JEUNG YEN VANSCYOC - VANSCYOC As a prerequisite to service of a subpoena for documents and thin gs pursuant to Rule 4009.22 NCS on behalf of DONALD R. DORER, 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: 04/05/2000 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DE11-171889 23343--L.02- C OMMONWEAL T H O E7 P E NN S YLVAN ZA COUNTY O V CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JOHN M. & TERRI L. WHITTEN, ET AL- AUTO TERM, 0 -VS- CASE NO: 99-5513 JEUNG YEN VANSCYOC - VANSCYOC NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS CARLISLE HOSPITAL MEDICAL GRAHAM MEDICAL CLINIC MEDICAL MILTON S. HERSHEY MEDICAL CTR. MEDICAL TIG INSURANCE COMPANY INSURANCE TO: MARLA R. MILLER, ESQUIRE MCS on behalf of DONALD R. RORER, 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: 03/16/2000 CC: DONALD R. DORER, ESQUIRE - 99HB-00122 MARGARET DRISCOLL Any questions regarding this matter, contact MCS on behalf of _ DONALD R. DORER, ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-116847 2 3 3 4 1- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN M. AND TERRI L. WHITTEN, ET AL. VS JEUNG YEN VANSCYOC File No. 99-5513 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 400922 TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena,SEE ATTAyED y the court to produce the following documents or things: at THE MCS GROUP INC., 1601 MARKET STREET, 11800, 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.. DONALD R. DORER, ESQUIRE ADDRESS: 214 SENATE AVENUE SUITE 503 CAMP HILL PA 17011 TELEPHONE: (215) 246 - 0900 SUPREME COURT ID#: ATTORNEY FOR.. THE DEFENDENT BY TH/pICOURT: /S/ l ( - A? ?,• DATE/) Cj, j) j?k16 TJ Prothonotary/Clerk, Civil wn Depu(y Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR CARLISLE HOSPITAL 246 PARKER STREET P.O. BOX 310 CARLISLE, PA 17013 RE: 23341 TERRI L. WHITTEN Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up tO and including the present. Subject : TERRI L. WHTMN 630 CONONDOGUINET AVENUE, CARLISLE, PA 17013 Social Security A 19146-0420 Date of Birth: 07-08-1953 SU10-239540 23341-1,01 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE MATTER OF: COURT OF COMMON PLEAS JOHN M. S TERRI L. WHITTEN, ET AL- AUTO TERM, 0 -VS- CASE NO: 99-5513 JEUNG YEN VANSCYOC - VANSCYOC As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, 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: 04/05/2000 DONALD R. DORER, ESQUIRE Attorney for DEPENDANT DE11-171890 2 3 3 4 1- L 0 2 COMMONWEALTH OF P ENN S YT-VAN MA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JOHN M. 6 TERRI L. WHITTEN, ET AL- AUTO TERM, 0 -VS- JEUNG YEN VANSCYOC - VANSCYOC CASE NO: 99-5513 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS CARLISLE HOSPITAL MEDICAL GRAHAM MEDICAL CLINIC MEDICAL MILTON S. HERSHEY MEDICAL CTR. MEDICAL TIG INSURANCE COMPANY INSURANCE TO: MARLA R. MILLER, ESQUIRE MCS on behalf of DONALD R. DORER, 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: 03/16/2000 CC: DONALD R. DORER, ESQUIRE - 99HB-00122 MARGARET DRISCOLL _ Any questions regarding this matter, contact MCS on behalf of DONALD R. DORER ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-116847 2 3 3 4 1- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN M. AND TERRI L. WHITTEN, ET AL. VS JEUNG YEN VANSCYOC File No. 99-5513 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 400922 TO: CUSTODIAN OF RECORDS FOR: GRAHAM MEDICAL CLINIC (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 11800 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: DONALD R. DORER, ESOUIRE ADDRESS: 214 SENATE AVENUE SUITE 0 CAMP HILL PA 17011 TELEPHONE: (215) 246 - 0900 SUPREME COURT ID #: ATTORNEY FOR: THE DEFENDENT BYT ,COURT: DATE ?? 13 J M??_ Prothonotary/Clerk, Cie' vision Deputy Seal of the Court EXPLANA'T'ION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GRAHAM MEDICAL CLINIC 100 SOUTH HIGH STREET NEVWILLE, PA 17241 RE: 23341 TERRI L. WHITTEN 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 : TERRI L. WHrMN 630 CONONDOGUINET AVENUE, CARLISLE, PA 17013 Social Security A 191-46-0420 Date of Birth: 07-08-1953 SU10-239542 23341-L02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE HATTER OF: JOHN M. 6 TERRI L. WHITTEN, ET AL- AUTO -VS- JEUNG YEN VANSCYOC - VANSCYOC COURT OF COMMON PLEAS TERM, 0 CASE NO: 99-5513 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. RORER, 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: 04/05/2000 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT . DE11-171891 2-3343--1,03,1,: COMMONWEALTH OR P E NN S YI vAN TA COUNTY OR CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JOHN H. & TERRI L. WHITTEN, ET AL- AUTO TERM, 0 -VS- JEUNG YEN VANSCYOC - VANSCYOC CASE NO: 99_5513 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS CARLISLE HOSPITAL MEDICAL GRAHAM MEDICAL CLINIC MEDICAL MILTON S. HERSHEY MEDICAL CTR. MEDICAL TIG INSURANCE COMPANY INSURANCE TO: MARLA K. MILLER, ESQUIRE MCS on behalf of DONALD R. DORER 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: 03/16/2000 MCS on behalf of CC: DONALD R. DORER, ESQUIRE _ 99HB-00122 MARGARET DRISCOLL _ Any questions regarding this matter, contact DONALD R. DORER ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-116847 2 3 3 4 3-- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN M. AND TERRI L. WHITTEN, ET AL. VS JEUNG YEN VANSCYOC File No. 99-5513 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: THE MILTON S. HERSHEY MEDICAL CENTER (Name of person or Entity) Within twenty (20) days after service of this subpoena,byEpE aj?jrAdered by the court to produce the following documents or things: HEU at THE MCS GROUP INC., 1601 MARKET STREET, 11800, 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: DONALD R. DORER, ESQUIRE ADDRESS: 214 SENATE AVENUE SUITE 503 CAMP HILL PA 17011 TELEPHONE: (215) 246 - 0900 SUPREME COURT ID #: ATTORNEY FOR: THE DEFENDENT DATE 12&Wrk la Qnlo Seal of the Court EXPLANA'HON OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MILTON S. HERSHEY MEDICAL CTR. 500 UNIVERSITY DRIVE PO BOX 850 HERSHEY, PA 17033 RE: 23341 TERRI L. WHITTEN COPY SPECIFIC DATES AFTER 10/03/1998. Any and all records, correspondence, tiles and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject : TERRI L. WRITTEN 630 CONONDOGUINEI' AVENUE, CARLISLE, PA 17013 Social Security # 19146-0420 Date of Birth: 07-08-1953 SU10-239544 23343.-L.03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE MATTER OF: COURT OF COMMON PLEAS JOHN M. 6 TERRI L. WHITTEN, ET AL- AUTO TERM, 0 -VS- CASE NO: 99-5513 JEUNG YEN VANSCYOC - VANSCYOC As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. RORER, 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: 04/05/2000 DONALD R. DORER, ESQUIRE Attorney for DEFENDANT DE11-171892 2-334a--I-04 COMMONWEALTH 0 17 PENNSYLVANIA COUNTY O V CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS JOHN M. & TERRI L. WHITTEN, ET AL- AUTO TERM, 0 -VS- JEUNG YEN VANSCYOC - VANSCYOC CASE NO: 99-5513 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS CARLISLE HOSPITAL MEDICAL GRAHAM MEDICAL CLINIC MEDICAL MILTON S. HERSHEY MEDICAL CTR. MEDICAL TIG INSURANCE COMPANY INSURANCE TO: MARLA K. MILLER, ESQUIRE MCS on behalf of DONALD R. DORER, 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: 03/16/2000 CC: DONALD R. DORER, ESQUIRE - 99HB-00122 MARGARET DRISCOLL - Any questions regarding this matter, contact MCS on behalf of DONALD R. DORER, ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-116847 2 3 3 4 1- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JOHN M. AND TERRI L. WHITTEN, ET AL. VS JEUNG YEN VANSCYOC File No. 99-5513 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: TIG PREMIER 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: SEE ATTACHED at THE MCS GROUP INC., 1601 MARKET STREET, 11800, 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: DONALD R. DORER, ESQUIRE ADDRESS: 214 SENATE AVENUE SUITE 503 CAMP HILL PA 17011 TELEPHONE: (215) 246 - 0900 SUPREME COURT ID #: ATTORNEY FOR: THE DEPENDENT BY TH OU T: DATE: .02,,? Pnlhonotarv Clerk ivil Di Deputy Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TIG INSURANCE COMPANY 70 W. MICHIGAN AVENUE BATTLE CREEK, MI 49017 RE: 23341 TERRI L. WHITTEN CLAIM NO.: A98156460 POLICY NO.: TRX33508717 Any and all claims files. Dates Requested: up to and including the present. Subject : TERRI L. WHITTEN 630 CONONDOGUINEI' AVENUE, CARLISLE, PA 17013 Social Security #: 19146-0420 Date of Birth: 07-08-1953 Date of Loss: 09/27/1998 SU10-239546 23341-L04 r• ?- ?= _, .? CV _ C ? ; Lt ,; .ii , F:: y' a ' 1 . to • !_ ?_? c. 7 .t • . C.) C? File No.: 99HB Q0122 , P A CIPE FOR LISTING CASE FOR TRAL., 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 iurv. CAPTION OF CASE: (Entire Caption Must Be Stated In Full) John M. and Terri L. Whitten, Shayne C. Whitten, a minor, by and through his parents, John M. and Terri L. Whitten, ( ) Assumpsit (Check One) ( ) Trespass ( x ) Trespass (Motor Vehicle) Plaintiffs (Other) VS. Jeung Yen Vanscyoc, Defendant The trial list will be called on October 10, 2000 Trials continence on October 30. 2000 Pre-trials will be held on October 18. 2000 (Briah am due 5 days before protdals.) (the party lirtioa this use for trial rhea provide forthwith a copy of the pnecipe to all counsel, pursuant to local Rule 2141.) No. 99-5513 Civil _ 19-22- Indicate the attorney who will try case for the party who files this praecipe: Donald R. Dorer. Esquire. Indicate trial counsel for other parties if known: Marla K. Miller. Attorney for Plaintiffs: Miller & Miller. P.C.. This case is ready for trial. Print Attorney for: Defendant. Jeung Yen Vanscyoc Date: August 25, 2000 99HB-00122 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number. (717) 731-0988 JOHN M. AND TERRI L. WHITfEN, SHAYNE 11 IN THE COURT OF COMMON PLEAS C. WHITTEN, A MINOR, BY AND THROUGH CUMBERLAND COUNTY, PENNSYLVANIA HIS PARENTS, JOHN M. AND TERRI L. WHITTEN, PLAINTIFFS VS. JEUNG YEN VANSCYOC, DEFENDANT No. 99-5513 CIVIL TERM CIVIL ACTION- LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Doter, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecioe for Listing Case for Trial to be served by regular first class mail upon: Marla K. Miller, Esquire Miller & Miller, P.C. 1423 State Road, P.O. Box 40 Duncannon, PA 17020 Date:_ August 25. 2000 onald R. Dorer, Esquire Attorney for Defendant .. ?? .= ? _, _ _ 1 J ?? .%'? ii.... C'J ?).! .. ?IW ) ' Ml lL ?= U o C> V 16. John M. and Terri L. Whitten, Shayne C. Whitten, a minor, by and through his parents, John M. and Terri 1. Whitten V Jeung Yen Vanscyoc : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99-5513 CIVIL TERM AND NOW, October 12, 2000, by agreement of counsel, the above captioned case is hereby continued from the October 30, 2000 trial term. Counsel is directed to relist the case when ready. By the Court, W4. . Hess, J. Marla K. Miller, Esquire For the Plaintiff Donald R. Dorer, Esquire For the Defendant `cy V rU - CPQ ()0 \n 0 , Court Administrator z K 8? J 0 File No.: 99HB-00122 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 iurv. CAPTION OF CASE: (Entire Caption Must Be Stated In Full) (Check One) ( ) Assumpsit John M. and Terri L. Whitten, Shayne C. Whitten, a minor, by and through his parents, John M. and Teri L. Whitten, Plaintiffs VS. Jeung Yen Vanscyoc, Defendant ( ) Trespass ( x ) Trespass (Motor Vehicle) (Odter) The trial list will be called on January 2. 2001 Trials commence on January 29. 2001 Pre-trials will be held on January to. 2001 (Briefs ere due 5 days before pmtrials.) (nte party listing this Care for trial dull provide forthwith ¦ copy of the pneeipe to all counsel, pursuant to local Rule 2141.) No. 99-5513 Civil 199_ Indicate the attorney who will try case for the party who files this praecipe: Donald R. Dorer. Esquire. Attorney for Defendants Jacobs & Saba 214 Senate Avenue Suite 503, Camp Hill. Pennsylvania. 17011: (717) 731-0988. Indicate trial counsel for other parties if known: Larry L Miller Attorney for Plaintiffs: Miller & Miller. P.C.. This case is ready for trial. Print Name: Donald R Dorer. Esquire Attorney for: Defendant Jeuna Yen VanMmc Date: October 13. 2000 99BB-00122 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 IN THE COURT OF COMMON PLEAS JOHN M. AND TERRI L. WRITTEN, SHAYNE CUMBERLAND COUNTY, PENNSYLVANIA C. WRITTEN, A MINOR, BY AND THROUGH HIS PARENTS, JOHN M. AND TERRI L. WHITTEN, PLAINTIFFS VS. JEUNG YEN VANSCYOC, DEFENDANT No. 99-5513 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecipe for Listing Case for Trial to be served by regular first class mail upon: Larry L. Miller, Esquire Miller & Miller, P.C. 1423 State Road, P.O. Box 40 Duncannon, PA 17020 Date: October 13. 2000 Donald R. Dorer, Esquire Attorney for Defendant ' ,;rx ca: r? I1G? ? c U Ll <.J H a w ? ? o ??eeaoM C m < ? ? n n _ '< O ? Vj xi n" J < 5: F k i yN Uv i Y `..,. __ . _.. LARRY L. MILLER, ESQUIRE Pa. Supreme Court I.D. No. 28122 1923 State Road Duncannon, PA 17020 Telephone: [717]957-2828 Attorney for Plaintiffs JOHN M. and TERRI L. WRITTEN IN THE COURT OF COMMON PLEAS and CUMBERLAND COUNTY, PA SHAYNE C. WRITTEN, a minor by and through his parents John M. and Terri L. Whitten , Plaintiffs: V. DOCKET NO: 99-5513 Civil Term JEUNG YEN VANSCYOC , Defendant TO: THE CUMBERLAND COUNTY PROTHONOTARY Please enter on the above-referenced docket the withdrawal of Larry L. Miller as counsel for Plaintiffs, JOHN M. and TERRI L. WHITTEN and SHAYNE C. WRITTEN, a minor, by and through his parents, John M. and Terri L. Whitten. Please enter on the above-referenced docket the entry of appearance of John Havas as counsel for Plaintiffs, JOHN M. and TERRI L. WRITTEN and SHAYNE C. WHITTEN, a minor, by and through his parents, John M. and Terri L. Whitten. a By: Date: Dec r 19," 2000 Lar L. M ller Attorney I.D. 128122 I HEREBY CERTIFY that I served a copy of the foregoing Praecipe this 2 u?'day of 2004, by placing the same in the United States Mail, first class mail, postage prepaid, addressed as follows: Donald R. Dorer, Esquire Law Office of Jacobs & Saba 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 By: C: u , I.J rI: u i .t _. -j U lop, 5. John M. and Terri L. Whitten, Shayne C. Whitten a minor by and through his parents John M. and Terri L. Whitten IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V Jeung Yen Vanscyoc NO. 99-5513 CIVIL TERM ORDER OF O RT AND NOW, January 3, 2001, counsel having failed to call the above case for trial, the case is stricken from the January 2001 trial term. Counsel is directed to relist the case when ready. Larry L. Miller, Esquire For the Plaintiff By the Court, /0*00) George E. offer, P.J. f xk w.c?t\e.b, -5-0 Donald R. Dorer, Esquire For the Defendant Court Administrator bb File No.: 9910-00122 (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) John M. and Terri L. Whitten, Shayne C. Whitten, a minor, by and through his parents, John M. and Terri L. Whitten, Plaintiffs (Check One) ( ) Assumpsit ( ) Trespass ( x) Trespass (Motor Vehicle) (other) VS. Jeung Yen Vanscyoc, Defendant no trial list will be called on February 13. 2001 Trials commence on March 12. 2001 Pro-trials will be held on Febntary 21. 2001 (Briefs am due 5 days before pretriah.) (Me party living this reran for trial rhea provide forthwith a copy of the pmwtpe to as counsal, pursuant to local Rule 2141.) No. 99-5513 Civil - 19-22- Indicate the attorney who will try case for the party who files this praecipe: Donald R. Doter. Esguire. Attorney for Defendant* Jacobs & Saba 214 Senate Avenue Suite 503, Camp Hill Pennsylvania 17011 • (717) 731 09AR Indicate trial counsel for other parties if known: John Havas. Fsguire. Attorney for Plaintiffs: 73 Cedar This case is ready for trial. Print Name: ?liifonald I Dorer. Esquire Attorney for: Defendant. Jeuna Yen Vanscvoc Date: January 18. 2001 6 99BB-00122 {--? LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant JOHN M. AND TERRI L. WHITTEN, SHAYNE 11 IN THE COURT OF COMMON PLEAS C. WHITTEN, A MINOR, BY AND THROUGHE? COUNTY, PENNSYLVANIA HIS PARENTS, JOHN M. AND TERRI L. WHITTEN, PLAINTIFFS VS. JEUNG YEN VANSCYOC, DEFENDANT No. 99-5513 CIVIL TERM CIVIL AcrioN - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached _. Praecipe for Listing Case for Trial to be served by regular first class mail upon: John Havas, Esquire 73 Cedar Avenue P.O. Box 775 Hershey, PA 17033 Date: January 18. 2001 Donald R. Dorer, Esquire Attorney for Defendant w ? CL. i U O ti ? W ? 0 ? l q Hd yy w11 n VKI Y CA z y,r t P N U W 6. John M. and Terri L. Whitten, Shayne C. Whitten, a Minor, by and through his parents, John M. and Terri L. Whitten V Jeung Yen Vanscyoc IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-5513 CIVIL TERM AND NOW, February 14, 2001, the above-captioned matter is continued by agreement of counsel, from the March 2001 trial tern, at the plaintiffs request. Counsel is directed to relist the case when ready. By the Court, Ge g . Ho er, P.J. John Havas, Esquire For the Plaintiff Donald R. Dorer, Esquire For the Defendant Court Administrator CoP eS mAALn\ _ %S "0 I :bb ..?, - ? ?:>> ?_ ;! ??, r?ra ?. , ?_ Lu .i p?, a L?M4 ? i.' i PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PFVrHONITARY OF CLMERLAND COUNN 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) 704 J M . A-M-P ?MAK? L,. W (42? TeN? (x) Civil Action -Law S IA" !J Q, C . W J-\ ,T7r,'J , + M I N O,k A-4 -V -rY1Yz0 V G iA- F-t ? I Ae ti TS ?OH+J ( ) Appeal from Arbitration • J4 vQ (other) (Plaintiff VS. J-ev06- ?eN'V:4a)SCyo( V8. ( Defendant ) The trial list will be called on and Trials commence on ;c) L y Ct+ j? Pretrials will be held on U W (Briefs are due 5 days before pretria .) . (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.9'7 -SQ.? Civil "reg- N 19 1?q Indicate the attorney who will try case for the party who files this praecipe: - ?6 0 LL Ye, f7o ca a is redady for tr-ial*p Signed: Print Name: ?? p ? /- Date: ®? Attorney for: (` L-Wr N'77FGS L`^ lf) J lid n_ O J PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE P1bOTNO MARY OF CUMBERLAND COUNTY Please list the following case: (Check one) (?) 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) ,: aDArJ PA, wi+i7%e?J , Teza'? L , w?l ?? ??? (X) Civil Action -Law .W-0 SFlAynl2 C . W R'lT'k eN' 6 0.0_ fS?l A-Na ?? ?? -rVF2ouGlj RS PA4en-'rS Sor4+ K.w?tTTEN ,?Ua ( ) Appeal from Arbitration (other) (Plaintiff) VS. T e v t, ye-?J U7, fsc Y C VS. (Defendant) The trial list will be called on RIL??O and ?T Trials camience on Pretrials will be held on Q (Briefs are due 5 days befor pre rial (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. Civil y <S/ 19 ? Indicate the attorney who will try case for the party who files this praecipe: HQ 44Vp-S FD.e -rrEe (?L?4?nlT1F?S Indicate trial counsel for other parties if known: lDQA) 4L. 7 `pD1V& - `7-ej-e,u7,? u This case is ready for trial. Date: cTJ O 2 0 1 Signed: /L! J AA X rmY Print Nam/ /17TU't-k if L4aa I A.(' Attorney for: ?. \.J , JOHN M. AND TERM L WRDTTEN, SHAY IN THE COURT OF COMMON PLEAS C- WMTTEN, A MINOR, BY AND THROUGH ? Ems' COUNTY, PENNSYLVANIA HIS PARENTS, JOHN M. AND TERRI L. WRITTEN, PLAINTIFFS YS. JEUNG YEN VANSCYOC, DEFENDA* TO THE PROTHONOTARY: TO No. 99-5513 CIVIL TERM Cm ACTION- LAW JURY TRIAL DEMANDED END Please mark the above-captioned case settled, discontinued and ended. By: John Ha t Esquire Pierce as 73 C Avenue, P.O. Box 775 Hershey, PA 17033 Attorney I.D.# Attorney for Plaintiffs Date: ?01 of 99HB-00122 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 JOHN M. AND TERRI L. WRITTEN, SHAYNE IN THE COURT OF COMMON PLEAS C. WHrITEN, A MINOR, BY AND THROUGH CUMBERLAND COUNTY, PENNSYLVANIA His PARENTS, JOHN M. AND TERRI L. WHIITEN, PLAINTIFFS VS. JEUNG YEN VANSCYOC, DEFENDANT No. 99-5513 CIVIL TERM CIVIL ACTION- LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached _Praecipe to Settle. Discontinue and End to be served by regular first class mail upon: John Havas, Esquire 73 Cedar Avenue P.O. Box 775 Hershey, PA 17033 Date: December 20. 2001 Donald R. Darer, Esquire Attorney for Defendant y O? tf' I W(7 CV j O.. US tD t? Z w•= -, : N u C^ ?a .. i- C ,G o U C '. Y? W r 3 C' •' G 4 Q W ^S ufpQOQ?..I <Oy HZ'n? Jn^ in y, U Wm 110-ADMI". eOllO•fB'n110 -oN wool ']N1•M VNMNI.UYSkT 40 N01S Y'rvoS 131,3S lb