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Home My WebLink About99-06691h 2 v v I J cC ?-L r lu nu: coDlli ur Cor•u1DN PLEAS CUM10fl-AN) COI IN 1 Y, PENNSYLVANIA I:ivi I Action- Law ( ) Equity NORMA 0. FRAME 547 F Street Carlisle, PA 17013 VOrS U': PlainIiff(? Addresses PHAECIPE FOR WRIT OF SUMMONS TO THE PROTIInIJOTAIIY OF SAID C RT: Please issue writ' of summons in the above-captioned action. X Writ of Sunr^ns shall be issued and forwarded to ( )Atfor (X)Sheriff Stephen J. Hogq, Esquire 19 S. Hanover St.. Ste. 101 17013 Carlislh451698 717 Names/Address/ Telephon No. of Attorney DENNIS S. HOCKENSMITH 1601 Walnut Bottom Road Newville, PA 17241 Defend::nt(s) 8 Address(es) J1gn01Ure UT ATTOrnfey Supreme Court ID No 36812 Dale: wit I T OF SUt4VI1S TO 711E ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED 111 AT 111E ABOVE-IJAMED PLA I fl1 I FF(S) I IAS/I IAVE COMMENCED AN ACTION AGAINST YOU. I' ll t ?I % ro ary wno : Dale: ]trc.....::-.:Lc... by Deputy Check here if reverse is issur_d for nd.t•. roal information rnomon. - 55 n?ppw?4ikl'e{ , . .-•? .:a.r.?mwscw.e: _. ..'?3?.1.._ ?.rlweu- - 1 r _ m v r ? n J C?4 j ?? SHERIFF'S RETURN - REGULAR CASE NO: 1999-06691 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FRAME NORMA 0 VS. HOCKENSMITH DENNIS S 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 HOCKENSMITH DENNIS S the defendant, at 13:19 HOURS, on the 2nd day of December 1999 at 1601 WALNUT BOTTOM ROAD NEWVILLE, PA 17241 CUMBERLAND County, Pennsylvania, by handing to PAT HOCKENSMITH (WIFE) a true and attested copy of the WRIT OF SUMMONS and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 7.44 Affidavit .00 q ,• ?-'? . Surcharge 8.00 A-Tiomas ine, eri $-ST--T?-F-STEPHEN J. HOGG 12/06/1999 by ep/u / 5 eri Sworn and subscribe to before me this //&-- day of Y8 2CvilA?.D?.? ?o ono er?- n li IN THE COURT OF COMMON PLEAS OF CUMBERRLAND COUNTY, PENNSYLVANIA NORMA O. FRAME, Plaintiff v. DENNIS O. HOCKENSMITI I. Defendant No. 99-6691 CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECII'E FOR ENTRY OF APPEARANCE PURSUANT TO I'a.R.C.P. 1012 'r0 TI IL' PROTI IONO"TARY• Kindly enter the appearance of Robert A. Lerman, Esquire and Ann Margaret Grab, Esquire of Griffith, Strickler, Lerman. Solyntos & Calkins, as attorneys for the Defendant, Dennis O. Hockensmith, in the above-captioned matter and mark the docket accordingly. GRIFFITH,? T ICKLER, LGRMAN, S LY. OS & CALKINS B Y : LTJ R BERT A. LGRMAN, ESQUIR Supreme Court I.D. No. 07490 ,r ANN MARGARET.GRAB, ESQUIRE Supreme Court I.D. No. 55986 Attorneys for Defendant 110 South Northern Way York. PA 17402 Telephone No. (717) 757-7602 i r i IN THE COURT OF COMMON PLEAS OF CUNIBERRLAND COUNTY, PENNSYLVANIA NORMA O. FRAME, Plaintiff V. DENNIS O. HOCKENSMITH, Defendant No. 99-6691 CIVIL. CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this U5/L?day of February, 2000, 1, Ann Margaret Grab, Esquire, a member ofthe firm ofGRIFFI'1'1-I, S"rRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have, this date, served a copy of the Praecipe for Entry of Appearance on behalf of Defendant, Dennis O. Flockensmith, by United States Mail, addressed to the party or attorney of record as follows: Stephen J. I logg, Esquire 19 South Hanover Street. Suite 101 Carlisle. PA 17013 GRIFFrI'H, S"?RICKLER, LERMAN, SOLYMOS & CALKINS ti BZOBE?FRTA. LERMAN, ESQUIR Supreme Court I.D. No. 07490 Attorneys for Defendant / 110 South Northern Way York. PA 17402 Telephone No. (717) 757-7602 gccq/bockensm.enc Previous Image Refilmed to Corr ect Possible; Error IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NORMA 0. FRAME, No. 99-6691 CIVIL Plaintiff V. CIVIL ACTION - LAW DENNIS S. HOCKENSMITH, Defendant JURY TRIAL DEMANDED TO THE PROTHONOTARY: PRAECIPE Please enter a Rule upon Norma O. Frame, Plaintiff, to file a Complaint within twenty (20) days from the date of the service of this Rule or suffer Judgment non-pros. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CAL(KINS Ann Margaret Grab, Esquire Attorney I.D. No. 55986 Attorney for Defendant 110 South Northern Way York, Pennsylvania 17402 Telephone: (717) 757-7602 ID 2000, RULE ISSUED AS ABOVE. P O'fHONOTARY DEPUTY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NORMA O. FRAME, No. 99-6691 CIVIL Plaintiff V. CIVIL ACTION - LAW DENNIS S. HOCKENSMITI-I, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this day of March, 2000. I. Ann Margaret Grab, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the Praecipe for Rule to File Complaint by United States Mail, addressed to the party or attorney of record as follows: Stephen J. Hogg, Esquire 19 South Hanover Street, Suite 101 Carlisle, PA 17013 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS Ann Margaret Grab, Esquire Supreme Court ID No. 55986 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 is ,.. ?/ _ IN'rm COURT OP COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NORMA O. PRAPVIE. Plaintiff DENNIS O. I-IOCKENSMIT11, Delcndant No. 99-6691 CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD 'r0: Norma 0. Prams c/o Stephen J. I logg, Esquire 19 South Hanover Street. Suite 101 Carlisle, PA 17013 You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days Isom service hereoforajudgment may be entered against you. GRIPPrr11, STRICKLER. LERMAN, SOLY\40S & CALKINS i 13Y: Ann Margaret Grab. Esquire Attorney for Defendant Supreme Court I.D. 1#55936 110 South Northern WaN York. Pennsylvania 17402 Telephone: (717) 757-7602 Ims IN TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NORMA O. FRAME. Plaintiff No. 99-6691 CIVIL DENNIS O. HOCKENSMITFI. Defendant CIVIL ACTION - LAW .IURY'rRIAI. DEMANDED ANSWER AND NEW MATTER Denied. Alter reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph no.l of Plaintiffs Complaint and same are denied and strict proof thereof is hereby demanded. 2. Admitted. 3. Admitted. 4. Admitted in part, denied in part. It is admitted that at some point prior to the accident both the Plaintiff and Defendant operated their vehicles south on Interstate 81. It is specifically denied that the Defendant was immediately behind the Plaintiff as he traveled south on Interstate 81 in the Borough of Carlisle. On the contrary, Defendant does not know where his vehicle was in relationship to the Plaintiff as they traveled on 81. 5. Admitted. 6. Admitted. 7. Admitted in part. denied in part. It is admitted that the Plainliffstopped at the stop sign and then proceeded to turn left on Walnut Bottom Road. The remaining allegations ofparagraph 7 are specifically denied. It is specifically denied that the Plaintiff stopped again at the median strip to allow a vehicle traveling west on Walnut Bottom Road to pass when the Defendant struck the rear of her vehicle. On the contrary, it is averred that at all times relevant hereto. Answering Defendant acted carefully, lawfully and prudently. 8. Denied. It is specifically denied that the direct and proximate cause of the collision was the Defendant's negligence, carelessness and/or recklessness as follows: a. Failing to exercise reasonable care in the operation of a motor vehicle; b. Failing to maintain a safe distance behind a vehicle ahead in violation of §3310(a) of the Vehicle Code. C. Failing to maintain a proper lookout for other vehicles lawfully using the road; d. Failing to maintain proper control over his vehicle; C. Failing to operate his vehicle at a speed which would allow him to slop within the assured clear distance ahead in violation of §3361 of the Vehicle Code; C Failing to operate his vehicle at a reasonable and prudent speed under the existing conditions in violation of §3361 of the Vehicle Code; g. Failing to warn the Plaintiffofan impending collision; h. Failing to avoid a collision with the Plaintiff; and i. Otherwise failing to operate his vehicle in such a manner as to avoid coiliding with another vehicle in that Defendant should have been aware of the Ilow of traffic. should have seen Plaintiff stop at the median in front of him and should have been able to avoid a collision. On the contrary, it is averred that at all times relevant hereto. Answering Defendant acted carefully, lawfully and prudently. 9. Denied. ItisspecificallydeniedthatAnsweringDefcndantwasncgligent,eareless<md reckless. The remaining allegations ofparagraph 9 are denied in that after reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph no.9 of Plaintiffs Complaint and same are denied and strict proof thereof is hereby demanded. 10. Denied. It isspecificallydenied that tile coIIisionandinjuriesanddamages therefrom were caused solely by the Defendant's negligence, recklessness and/or carelessness without any fault or negligence, recklessness or carelessness on the pan of the Plaintiff in contributing or causing the collision. On the contrary, it is averred that at all times relevant hereto, Answering Defendant acted carefully, lawfully and prudently. 11. Denied.:fter reasonable investigation, Answering Defendant is without knowledge or information sufficient to fomi a belief as to the truth of the allegations set forth in paragraph no.I I of Plaintiffs Complaint and same are denied and strict proof thereof is hereby demanded. 12. Denied. After reasonable investigation, Answering Defendant is without knowledge or information sufficient to form a beliefas to the truth of the allegations set forth in paragraph no. 12 of Plaintiffs Complaint and same are denied and strict proof thereof is hereby demanded. Wherefore, Answering Defendant dentandsjudgment in his favor and against the Plaintiff together with interest and costs suit. By way of further defense: NEW MATTER 13. Paragraphs I through 12 are incorporated herein as though filly set forth at length. 14. Plaintiff's Complaint fails to state a cause ol*action against Answering Defendant. upon which refiefcan be granted. 15. Plaintiff has not sustained a serious injury as defined by Act 1990-6. 75 Pa C.S.A. § 1702. 16. Plaintiff's claim fornon-cconomicdamages maybebarred because Plaintiffhaselected a limited tort option as set forth in Act 1990-6, 75 Pa. C.S.A. 1705(b)(3)(d). 17. Plaintiff'wascontributorilyand/orcomparitivelynegligent. which contributory and/or comparative negligence was the substantial factor in bringing about hcralleged injuries and damages. Plaintiff was negligent and her negligence was the sole factor in bringing about her alleged injuries and damages. Respectfully submitted, GRIF ITH. STRICKLER, LERMAN, SOLYMOS & CALKINS i? By: Ann Margaret Grab, Esquire Attorney for Defendant Attorney I.D. #55986 110 South Northern Way York, PA 17=402 (717) 757-7602 4 VERIFICATION 1. Ann Margaret Grab. Esquire, do hereby verify that 1 am the attorney of record for the pleading party herein, and that the facts set forth in the foregoing pleading are true to the best of my knowledge, information and belief, upon information supplied. I understand that I'alse statements made herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. Dated: t/ lol /C.{ / GRIFFITH. STRICKLER. LL=RMAN, SOLYMOS & CALKINS /i ICY: Ann Margaret Grab, Esquire Supreme Court I.D. #55986 110 South Northern Way York. Pennsylvania 17402 (717) 757-7602 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0 104A 0. PRA\-lli, No. 99-6691 CIVIL Plaintiff CIVIL ACTION - LAW DENNIS O. 1I0CKIiNSMITI1. Defendant JURY TRIAL DEMANDED CERTIFICATE, OF SERVICE AND NOW. this 25th day of April, 2000. 1, Ann Margaret Grab, a member of the firm of GRIFITH 1. STRICKLER. LERMAN. SOLYMOS & CALKINS. hereby certify that I have this date served a copy of the Answer and New Matter by United States Mail, addressed to the party or attorney ol'record as follows: Stephen J. Hogg, Esquire 19 S. Hanover Street, Suite 101 Carlisle, PA 17013 GRIFEITI-1. STRICKLER, LERMAN, SOLYMOS & CALKINS Ann=Margarct Grab, Es?uirc Supreme Court ID No. 55986 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 IN TI IE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NORMA 0. FRAME. No. 99-6691 CIVIL Plaintiff V. CIVIL ACTION - LAW DENNIS 0. HOCKENSMITH, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICF v AND NOW, this) day of May, 2000, I, Ann Margaret Grab, a member of the firm of GR .-i-rrl-l, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the Interrogatories/Request for Production of Documents of Defendant to Plaintiff Set I by United States Mail, addressed to the party or attorney of record as follows: Stephen J. Hogg, Esquire 19 South Hanover Street Suite 101 Carlisle. PA 17013 GRIFFITH, STRICKLER. LERMAN. SOLYMOS & CALKINS Ann Margaret Grabt Esquire Supreme Court ID No. 55986 110 South Northern Way York, Pennsylvania 17402 (717)757-7602 40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NORMA O. FRAME, No. 99-6691 CIVIL Plaintiff V. CIVIL ACTION - LAW DENNIS O. I-IOCKENSMITI-l, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 22nd day of September, 2000, I, Ann Margaret Grab, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the Notice of Deposition-Norma O. Frame by United States Mail, addressed to the party or attorney of record as follows: Stephen J. Hogg, Esquire 19 South Hanover Street, Suite 101 Carlisle, PA 17013 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS An`n Margaret Crab, Esquire Supreme Court ID No. 55986 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 IN THE COURT Or COMMON PLEAS Or CUMBERLAND COUNTY FRAME Vs. NO. 9CYX1 va6?oi - HOCKENSMITH CERTIFICATE PREREQUISITE'r0 SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 ANN MARGARET GRAB, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena (s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). ate: 10/2/00 ANN MARGARET GRAB, ESQUIRE 110 S NORTHERN WAY YORK, PA 17402 717-757-7602 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3590 By: Angelique Cianci File 4: M267029 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY FRAME Vs. HOCKENSMITH No. 9CV6691 TO: STEPHEN HOGG, ESQ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 9/8/00 ANN MARGARET GRAB, ESQUIRE 110 S NORTHERN WAY YORK, PA 17402 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3590 By: Angelique Cianci Enc(s): Copy of subpoena(s) Counsel return card File #: M267029 ODMMDNNEALTH OF PENNSYLVANIA ODUNPY OF CUMBERLAND FRAME Vs. 99CV6691 HOCKENSMITH File No. SUBPOENA TO PRODUCE DOCLKNTS OR THINGS FOR DIS OVERY PURSUANT TC RULE 4009.22 T0: DR GEORGE BRANSCUM, 850 WALNUT BOTTOM RD, CARLISLE PA 17013 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to Produce the following document ithtTffA!'T_7F.R_Aq ? at MEDICAL LE , ,-?P??_Gmnu em nBTLA PA (Address) You may deliver or mail legible copies of the this subpoena, together with the certificate o docLrnents Or produce things requested thi, the request at the address listed above, You have the right to seeek inoadvance the reanonablE cost of preparing the copies or producing the things sought. If you fail to produce the docunents or things required by this sub (20) days after its service, the party, serving thin s ""Pe'lli subpoena within twenty n9 You to crnply with it. ubpoena may seek a court orde:- THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLONING PERSON: NAME: ANN MARGARET GRAB, ESQ AGGRESS: _ li0 S NORTHERN WAY 7402 TELEPHONE: SUPREME OOURT ID # - , ATTORNEY FOR: 55986 DEFENDANT M267029-01 DATE: S *Off the ; urt (Eff. 7/97) ADDENDUM TO SUBPOENA FRAME Vs. No. 99CV6691 HOCKENSMITH CUSTODIAN OF RECORDS FOR: DR GEORGE BRANSCUM ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: NORMA O FRAME ADDRESS: 547 F ST CARLISLE PA DATE OF BIRTH: 02/02/55 SSAN: 587722165 CERTIFIED PHOTOCOPIES OF THE RECORDS WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. County of: CUMBERLAND MLR File #: M267029-01 Ca44y* EALTH OF PERNMVANIA mom OF CLMERInm FRAME Vs. File No. HOCKENSMITH 99CV6691 SUBPOENA TO PRODUCE DOCIIENTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 DR JOHN RODGERS, 1 DUNWOOD DR, CARLISLE PA 17013 TO: (N2nn of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following document tt'ArTAEHET) ADDENDUM at MEDICAL LEGAL You may deliver or mail legible copies of the docunents or produce things requested t% this subpoena, together with the certificate of compliance, to the party making thie request at the address listed above. You have the right to seek in advance the rea-onable cost of preoaring the copies or producing the things sought. If you fail to produce the docunents or things required by this subpoena within twenty (20) days after its service, the party, serving thin, subpoena may seek a court orde empell ing you to cmply with, it. . j THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANN MARGARET GRAB, ESQ ADDRESS: _ 110 S NORTHERN WAY R,4?, PA 17402 t TELEPHONE: SUPREME COURT ID $IATTORNEY FOR: 55986 i DEFENDANT M267029-02 DATE: Sea the.0o rt (Eff. 7/97) ADDENDUM TO SUBPOENA FRAME Vs. No.g9CV6691 HOCKENSMITH CUSTODIAN OF RECORDS FOR: DR JOHN RODGERS ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: NORMA 0 FRAME ADDRESS: 547 F ST CARLISLE PA DATE OF BIRTH: 02/02/55 SSAN: 587722165 CERTIFIED PHOTOCOPIES OF THE RECORDS WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. County of: CUMBERLAND MLR File #: M267029-02 00114XWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FRAME g9CV6691 VS. File No. HOCKENSMITH SUBPOENA TO PRODUCE DClatENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DR MARK HOLENCIK, 805 SIR THOMAS CT, HARRISBURG PA -------------- (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: **4FE ATTACHED ADDENDUM** at -- mTQ Tntr ?940 DTgSTON ST PHILA PA 19135 (Address) this Yu may deliver or mail legible copies of the docLnents or produce things requested b,, subpoena, together with the certificate of ccrrinliance, to the party making thi; request at the address listed above. You have the right to seek in advance the reagonab]E 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 serv.ce,.•the: party.. serving ,this subpoena may seek a court orde;- ampe'l ) ing you to car ply with it.. THIS Sl18POENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ANN MARGARET GRAB, ESQ ADDRESS: ' h r 4 h?rORTHIERN WAY YORK PA 17402 7z TELEPHONE:_ 55986 SUPREM COURT ID ti ATTORNEY FOR: ?- M267029-03 DATE: S of the Court BY ' COURT: ?J " Pro horiotar ler, hl Division (Eff. 7/97) ADDENDUM TO SUBPOENA FRAME Vs. No.y9CV6691 HOCKENSMITH CUSTODIAN OF RECORDS FOR: DR MARK HOLENCIK ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: NORMA O FRAME ADDRESS: 547 F ST CARLISLE PA DATE OF BIRTH: 02/02/55 SSAN: 587722165 CERTIFIED PHOTOCOPIES OF THE RECORDS WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. County of: CUMBERLAND MLR File #: M267029-03 "1 1 C .1 1 ? ?? IN THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NORMA O. FRAME, No. 99-6691 CIVIL. Plaintiff V. CIVIL ACTION - LAW DENNIS 0. HOCKENSMITH, Defendant JURY TRIAL DEMANDED CERTIFICATE, OF SERVICE AND NOW, this 22nd day of September, 2000, I, Ann Margaret Grab, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of the Amended Notice of Deposition-Norma 0. Frame by United States Mail, addressed to the party or attorney of record as follows: Stephen J. Hogg, Esquire 19 South Hanover Street, Suite 101 Carlisle, PA 17013 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS j1 v\ -- Ann Margaret Grab, Esquire Supreme Court ID No. 55986 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NORMA 0. FRAME. No. 99-6691 CIVIL Plaintiff V. DENNIS S. I IOCKENSMITI-1, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO SUBSTITUTE VERIFICATION TO TIME PROTI IONOTARY: Please substitute the attached verification of the Defendant for the verification of Defendant's counsel to the Answer and New Matter which was filed in the above-captioned matter. GRIFFITI-1, STRICKLER, LERMAN, SOLYMOS R CALKINS Dated: B Y: Ann Margaret Grab Esquire Supreme Court I.D. 455986 110 South Northern Way York, Pennsylvania 17402 Telephone: (717) 757-7602 VERIFICATION I verify that the foregoing facts are true and correct. upon my personal knowledge or information and belief. This verification is made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: Dennis S. 1-lockensmith IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NORMA O. FRAME. No. 99-6691 CIVIL Plaintiff v. CIVIL ACTION - LAW DENNIS S. I1OCKENSMITI-1. Defendant JURY'IRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 25th day of October, 2000, I, Ann Margaret Grab, a member of the firm of GRIFFITFI, STRICKLER. LERMAN, SOLYMOS & CALKINS, hereby certify that 1 have this date served a copy of the Praccipe to Substitute Verification by United States Mail, addressed to the party or attorney of record as follows: Stephen J. I logg, Esquire 19 S. Hanover Street, Suite 101 Carlisle, PA 17013 GRIFFITI I, STRICKLER, LERMAN, SOLYMOS & CALKINS Ann Margaret Grab Supreme Court ID No. 55986 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 ,r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY FRAME Vs. NO.g9CV6691 HOCKENSMITH CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 ANN MARGARET GRAB, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena (s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the N(Acice of Intent to Serve the Subpoena(s). Di ANN MARGARET GRAB, ESQUIRE 110 S NORTHERN WAY YORK, PA 17402 717-757-7602 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3590 By: Angelique Cianci File #: M267731 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY FRAME Vs. HOCKENSMITH No.C19CV6691 TO: STEPHEN HOGG, ESQ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.1 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 9/27/00 ANN MARGARET GRAB, ESQUIRE 110 S NORTHERN WAY YORK, PA 17402 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3590 By: Angelique Cianci Enc(s): Copy of subpoena(s) Counsel return card File #: M267731 r Ca%tYONWFALTH OF PENNSYLVANIA COUNTY OF CUP9HERLAID FRAME Vs. File No. HOCKENSMITH 99CV6691 ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCLWNTS OR THINGS FOR DISOOVERY PURSUANT TO RULE 4009.22 CARLISLE HOSP, 246 PARKER ST, CARLISLE PA 17013 TO: ATTN: MEDICAL RECORDS DEPT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunentgSWhArFT-A-C-HF-D ADDENDUM at _ wn?n RT. PHILA., PA MEDICAL LEGAL S-?.N?,?-B;SSTON (Address) You may deliver or mail legible copies of the documents or produce things requested b,, this subpoena, together with the certificate of ocn-cliance, to the party making thi; request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court orde:- crmpelling you to ccrply with it. THIS SUBPOENA WAS ISSUED AT THE REGLIEST OF THE FOLLOWING PERSON: NAME: ANN MARGARET GRAB, ESQ ADDRESS: 110 S NORTHERN WAY ynwy PA 1,7402 TELEPHONE: _ }5 3212 SUPREME COURT ID # ATTORNEY FOR: 55986 DEFENDA14T M267731-01 DATE: 1 f the Court (Eff. 1/97) ADDENDUM TO SUBPOENA FRAME Vs. HOCKENSMITH CUSTODIAN OF RECORDS FOR: CARLISLE HOSP No.99CV6691 Any and all hospital records, including microfilm, microfiche emergency room reports, x-ray reports, out-patient records physical therapy records, and any other information pertaining to: NAME: NORMA 0 FRAME ADDRESS: 547 F ST CARLISLE PA DATE OF BIRTH: 02/02/55 SSAN: 587722165 ORIGINAL X-RAYS REQUESTED TO INCLUDE ACTUAL X-RAY FILMS AND MRI FILMS. CERTIFIED PHOTOCOPIES OF THE RECORDS WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. County of: CUMBERLAND MLR File #: M267731-01 Ca%14DNWEALTH OF PENNSYLVANIA COLJNrY OF CUMBERLAND FRAME Vs. HOCKENSMITH File No. Q9CV6691 SUBPOENA TO PROOUCE 130C1j?ENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TODR WALTER PEPPELMAN, 805 SIR THOMAS CT, HARRISBURG PA 17109 • of Person or Ent Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following document§11 t?1ftAejWD-ADMPd_PT_;A.4 at MEDICAL LEGAL REPRODIICTIONS, 2(Address) You may deliver or mail legible copies of the documents or produce things requested h% this subpoena, together with the certificate of canpliance, to the party making thi: request at the address listed above. You have the right to seek in advance the rea.onable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court orde•- ompelling you to conply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NA E:- ANN MARGARET GRAB, ESQ ADDRESS: ----j-}t}£ NQR!1! 3ERN__WAY TELFPHONEq?__r•., YO SUPREhE COURT ID q 215-335-3212 ATTORNEY FOR: 55986 DEFENDANT M267731-02 he ?oxlOY'V?1 DATE: { S l of t thee -Cou?r"t'7- ?d?lJ (Eff. 7/97) ADDENDUM TO SUBPOENA FRAME Vs. HOCKENSMITH No.99CV6691 CUSTODIAN OF RECORDS FOR: DR NVALTER PEPPELIIAN ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: NORMA O FRAME ADDRESS: 547 F ST CARLISLE PA DATE OF BIRTH: 02/02/55 SSAN: 587722165 CERTIFIED PHOTOCOPIES OF THE RECORDS NVILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. County of: CUMBERLAND MLR File #: M267731-02 _ O ? ?" C ; -- _ e. ? ,- _ "- _J .. .- :,7 1 ?' ? ?_I C : '.1 Cl n -J _ ;? U NORMA O. FRAME, Plaintiff DENNIS S. HOCKENSMITH, Defendant : IN THE COURT OF : COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA CIVIL ACTION NO. 1998 49 GG4/ (2 c JURY TRIAL DEMANDED PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS 1. Copy of the Defendant's license at the time of the accident in question on December 16, 1997. 2. A Copy of the Title of vehicle he was driving at the time of the accident in question on December 16, 1997. 3. Any and all photographs of his vehicle taken on or after December 16, 1997. 4. Any evidence, statements, documents, reports relied upon in whole or in part by any expert who has expressed an opinion on any issue related to the subject of this lawsuit. 5. Any and all work papers, notes and documents in the file on any expert witness who is expected to testify or who has written a report which is or will be relied upon in whole or in part by a testifying expert. LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 6. A resume for each expert witness who may be called to II testify at trial. i) 7. All documents or tangible things prepared by any expert ii whom you expect to call as a witness including but not limited to his reports, factual observations, opinions, conclusions, photographs, field notes, calculations, models and exhibits. 8. A copy of any damage appraisal made of the Defendant's vehicle. 9. A copy of any repair invoice of the Defendant's vehicle. 10. A copy of any insurance agreements or policies applicable to Defendant's vehicle at the time of this accident on December 16, 1997. 11. A copy of any and all drawings, maps or sketches of the scene of the accident which has been made the basis of this lawsuit. 12. A copy of any surveillance movies or photographs which have been made of the Plaintiff. 13. A copy of any and all photographs that Defendant has taken or caused to be taken of the vehicles involved in the collision. LAW OFFICES OF STEPHEN J. IIOGG 19 S. HANOVER STREET SUITE 101 CARLISLE. PA 17013 2 14. A copy of any and all photographs the Defendant has taken or caused to be taken at the scene of the accident or any other matter relating to this case. 15. Copies of any witness statements other than discovery statements given by Defendant and Plaintiff given on October 11, 2000 which are not privileged by law. 16. Copy of any movies, videotapes or other reproduction of the accident scene. 17. A copy of any survey or plat made of the accident scene. 18. A copy of any books, documents, photographs or other tangible things which may be used at the time of trial which may have a bearing on this lawsuit. 19. A copy of the VINDecoder and AutoStats analysis sheets for the Plaintiffs Ford Taurus. 20. A copy of the Anthropometric Regression Equations from 1962 National Health Survey. 21. A copy of the examination of an exemplar 1996 Ford Taurus. 5 LAW OFFICES OF STEPHEN J. HOGG r, 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 ?-( Date: / /n n Stephen J. HogI, re Attorney for Plaintiff . 3 ',?, i LAW OFFICES OF STEPHEN J. hIOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 NORMA O. FRAME, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION //77 NO.1998 97-"c:?/ Llc?t? DENNIS S. HOCKENSMITH, Defendant JURY TRIAL DEMANDED INTERROGATORIES OF PLAINTIFF ADDRESSED TO DEFENDANT DEFINITIONS "Document" means any written, printed, typed, or other graphic matter of any kind or nature, however produced or reproduced, including photographs, microfilms, phonographs, video and audio tapes, punch cards, magnetic tapes, discs, data cells, drums, and other data compilations from which information can be obtained. `Identify or "Identity" means when used in reference to - 1. A natural person, his or her: a. full name; and b. present or last known residence and employment address (including street name and number, city or town, and state or country); 2. A document: a. its description (e.g., letter, memorandum, report, etc.), title, and date; b, its subject matter; C. its author's identity; d. its addressee's identity; e. its present location; and f. its custodian's identity; 3. An oral communication: a. its date; b. the place where it occurred; C. its substance; d. the identity of the person who made the communication; e. the identity of each person to whom such communication was made; and f. the identity of each person who was present when such communication was made; 4. A corporate entity: a. its full corporate name; 1pW OFFILESOF ii STEPHIEN J. IHOGG Iii 1 19 S. HANOVER STREET I SUITE 101 l i CARLISLE. PA 17013 b. its date and place of incorporation, if known; and c. its present address and telephone number; 5. Any other context: a description with sufficient particularity that the thing may thereafter be specified and recognized, including relevant dates and places, and the identification of relevant people, entities, and documents. "Incident" means that occurrence that forms the basis of a cause of action or claim for relief set forth in the complaint or similar pleading. 2 "Person" means a natural person, partnership, association, corporation, or government agency. LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 3 STANDARD INSTRUCTIONS 1. Duty to answer. -The interrogatories are to be answered in writing, verified, and served upon the undersigned within 30 days of their service on you. Objections must be signed by the attorney making them. In your answers, you must furnish such information as is available to you, your employees, representatives, agents, and attorneys. Your answers must be supplemented and amended as required by the Pennsylvania Rules of Civil Procedure. 2. Claim of privilege. -With respect to any claim of privilege or immunity from discovery, you must identify the privilege or immunity asserted and provide sufficient information to substantiate the claim. 3. Option to produce documents. -In lieu of identifying documents in response to these interrogatories, you may provide copies of such documents with appropriate LAW OFFICES OF STEPHEN f. IIOGG 19 S. HANOVER STREET SUITE 101 CARLISLE. PA 17013 references to the Date: interrogatories. "Stephen X Hogg, s une Attorney for Plaintiff 19 S. Hanover Street, Ste. 101 Carlisle, PA 17013 (717) 245-2698 4 Please state the name and address of each witness you expect to call to testify at trial including experts and for each such witness, describe the substance of the testimony. For each expert witness expected to be called to testify at trial, please identify the qualifications of the expert and a summary of the grounds for each opinion expressed. LAW OFFICES OF STEPHEN J. IIOGG 19 S. HANOVER STREET SUITE 101 CARLISLE. PA 17013 2. Please enclose copies of all photographs, documents, reports, medical evidence, statements and any other information on which each expert's opinion and testimony is based. LAW OFFICES OF STEPHtrN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 Date: I L Stephen J. Hogg Attorney for Plai 19 S. Hanover Stre Carlisle, PA 17013 (717) 245-2698 Ste. 101 6 ,, _:, ., NORMA O. FRAME, Plaintiff DENNIS S. HOCKENSMITH, Defendant : IN THE COURT OF : COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA CIVIL ACTION NO. 99-6691 JURY TRIAL PRAECIPE FOR DISMISSAL TO THE PROTHONOTARY OF SAID COURT: Please dismiss the Complaint in the above captioned matter without prejudice. Respectfully Submitted, LAW OFFICESOF STEPHENJ.HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 Date: ??i ?o? ? 1 f