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HomeMy WebLinkAbout03-3529 Barbara Sump1e-Sullivao, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717)774-1445 LINDA A. RANDALL 304 SOUTH MARKET STREET MECHANICSBURG, PA 17055, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.03- %:1.9 v. Civil Action - (X) Law ( ) Equity DOROTHY A. MATESEVAC 53 PAXTON STREET HIGHSPIRE, PA 17034, Defendant PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Writ of Summons in the above-captioned action. .x.- Writ of Summons shall be issued and forwarded to: Barbara Sumple-Sullivan, Esquire i:me of Attorney Supreme Court I.D. No. 32317 Dated: July 23, 2003 ( ) Attorney ( X ) Sheriff 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 Name/Address/Telephone No. of Attorney WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. p4(" . Date: j dI; 9Lf, 2003 By: ~~ -0/ ~puty [ ] Check here if reverse is issued for additional information. -or,,, "- ,. D OJ '-'" :x::, -r::' '!\ ( ~ \t... "'I 0 --.. ~ '- ;>0 ~ ..t. & ~ v<> ;3 <;::- ~ ""'=> ;;;--- ~ --- ~ " :;:. ::0 @ SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2003-03529 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RANDALL LINDA A VS MATESEVAC DOROTHY A R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MATESEVAC DOROTHY A but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within WRIT OF SUMMONS On August 8th , 2003 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 29.25 .00 66.25 08/08/2003 BARBARA S SULLIVAN So answers. '~' ~ R. Thomas Kline Sheriff of Cumberland County ..c Sworn and subscribed to before me this J'1!!o' day of ~ Mv3 A.D. ~ () !M-HLAJ Jp;; , Prothonotary' In The Court of Common Pleas of Cumberland County, Pennsylvania Linda A. Randall VS. Dorothy A. Matesevac SERVE: same No. 03-3529 civil Now, .July 29. 2003 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. r~-<~ Sheriff of Cumberland County, PA Affidavit of Service Now, , 20_, at 0' clock M. served the within upon at by handing to a copy of the original and made lmown to the contents thereof. So answers, '. Sberiff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ @fiitt of tIre ~4eriff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 171 0 1 ph: (717) 255-2660 fax: (717) 255.2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania RANDALL LINDA A vs County of Dauphin MATESEVAC DOROTHY A Sheriff's Return No. 2055-T - -2003 OTHER COUNTY NO. 03 3529 AND NOW:August 4, 2003 at 11: l4AM served the within WRIT OF SUMMONS upon MATESEVAC DOROTHY A by personally handing to DEF 1 true attested copy (ies) of the original WRIT OF SUMMONS and making known to him/her the contents thereof at POE: PEALERS FLOWERS STRAWBERRY SQUARE HARRISBURG, PA 17102-0000 Sworn and subscribed to So Answers, jf~ before me this 4TH day of AUGUST, 2003 ~ C!-. (f)0AMu0 I PROTHONOTARY Sheriff of Dauphin County, Pa. BY~~ Deputy Sheriff Sheriff's Costs: $29.25 PD 08/01/2003 RCPT NO 181296 HOPKINS LINDA A. RANDALL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -LAW : NO. 03-3529 DOROTHY A. MATESEVAC, Defendant PRAECIPE FOR A RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule directing Plaintiff to file a Complaint in the above-referenced matter within twenty (20) days of service thereof or risk a judgment of )lon pros. NNEHEY, WARNER, OGGIN BY: Matthe L. 0 ns, Esquire LD. No. 76080 4200 Crums Mill Road, Suite B Hanisburg, PA 17112 (717) 651-3501 DATE: ,,/,,( dJ. Attorneys for the Defendant LINDA A. RANDALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. 03-3529 DOROTHY A. MATESEVAC, Defendant CERTIFICATE OF SERVICE I,~, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this ~ay of November, 2003, I served a copy of the foregoing document via First Class United States mail, postage prepaid as follows: Barbara Sump Ie-Sullivan, Esquire 549 Bridge Street New Cumberland, PAl 7070 ~~ LINDA A. RANDALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION -LAW NO. 03-3529 DOROTHY A. MA TESEV AC, Defendant RULE AND NOW, this .:26.../l.-.dayof . A h\EJY\b~ ,2003, upon consideration of the foregoing Praecipe, Plaintiff is hereby ordered to file her Complaint within twenty (20) days hereof or suffer judgment of non pros. BY THE PROTHONOTARY: CLd.o- /i? . ~ .~ () C:J C) C (.-J '1 S. ~ l::JCI ~~3 rnfl,l Z:"Li N .. t'j[ 'J)' 0 , ~~C ,. (-I .-C ~d oJ.';:: (_ (0", ~.7 ",. -, ~-l' N -,) r-,' pi::::: z. ;:;:-1 c=- ::~] =2 (J""> -< Barbara Swnple-Sullivan. Esquire Supreme Court #32317 549 Bridge Street New Cwnberland. P A 17070 (717) 774-1445 LINDA A. RANDALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - (X) Law DOROTHY A. MATESEV AC, Defendant : NO. 2003-3529 : JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IFYOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LmERTY AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland,PA 17070 (717) 774-1445 LINDA A. RANDALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - (X) Law DOROTHY A. MATESEV AC, Defendant NO. 2003-3529 : JURY TRIAL DEMANDED COMPLAINT AND NOW COMES Plaintiff, Linda A. Randall, by and through her attorney, Barbara Sumple-Sullivan, Esquire, and states the following: I, Plaintiff, Linda A. Randall, is an adult individual residing at 304 S. Market Street, First Floor, Mechanicsburg, Cumberland County, Pennsylvania 17055, 2. Defendant, Dorothy A. Matesevac, an adult individual residing at 53 Paxton Street, Highspire, Dauphin County, Pennsylvania 17034. 3, On September 4,2001, at approximately 1:25 p.m., Plaintiff was operating her motor vehicle on Central Boulevard, approaching the intersection with Trindle Road, in Cumberland County, Pennsylvania. 1 4. At that time and place, Plaintiff came to a stop behind another vehicle stopped at the stop sign at the intersection of Central Boulevard and Trindle Road. 5. Plaintiff was operating her vehicle in a proper and law1i1l manner at all times. 6. After coming to a complete stop, Plaintiff's vehicle was struck violently from behind by a motor vehicle operated by Defendant. 7. The force of the collision threw Plaintiff's head and upper torso violently forward and caused Plaintiff to strike her head on the steering wheel of her vehicle, with lost consciousness. 8. The collision was caused solely and prominently by the negligence of Defendant. 9. Defendant was negligent in: (a) Failing to keep a proper lookout for vehicles in front of her; (b) Following Plaintiff's vehicle too closely; (c) Failing to have her vehicle under sufficient control to stop before hitting Plaintiff's vehicle in the rear; and (d) Failing to stop her vehicle before it struck Plaintiff's vehicle in the rear. 10. Plaintiff has suffered physical and mental/emotional injuries and pain and suffering as a proximate result of Defendant's negligence in striking Plaintiff's vehicle in the rear. 2 11. Plaintiff's injuries and pain and suffering are on-going; they include bulging discs and other spine injury, with associated significant neck and bilateral shoulder pain, headaches, and aggravation of pre-existing post-traumatic stress disorder and major depression, 12. As a result of the injury suffered by Plaintiff, she has undergone several surgeries and periods of hospitalization, extensive physical therapy and other treatment modalities. 13. Plaintiff's damages claimed against Defendant are a result of Defendant's negligence as described herein exceed the amount requiring reference to compulsory arbitration in Cumberland County. WHEREFORE, Plaintiff, Linda A. Randall, demands judgment against Defendant, Dorothy A. Matesevac, in an amount in excess of$10,000,OO, pIUs c // / DATE: November 25,2003 Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court J.D. 32317 3 Barbara Swnple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cwnberland, P A 17070 (717) 774-1445 LINDA A RANDALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - (X) Law DOROTHY A MATESEV AC, Defendant NO. 2003-3529 JURY TRIAL DEMANDED VERIFICATION I, LINDA A. RANDALL, hereby certifY that th,~ facts set forth in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief I understand that any false statements made herein are subject to penalties of 18 Pac C.S.A Section 4904 relating to unsworn falsification to authorities. Dated: ~\J. '2...4 ,2003 ~ -A .~AIIrla 0 t A A. RANDA L Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717)774-1445 LINDA A RANDALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - (X) Law DOROTHY A MATESEV AC, Defendant NO, 2003-3529 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certifY that on this date, I served a true and correct copy of the foregoing COMPLAINT, in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Matthew L. Owens, Esquire Marshall, Dennehey, Warner, Coleman and Goggin 4200 Crums Mill Road, Suite Harrisburg, PA 171~ Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court J.D. No. 32317 DATED: November 25, 2003 ~ 0 ~ w z .--.{ 1$ 0 ;fi~I-t < N :,~~;~3 ~ a> i'') L ;.~ ,':.9 ~C) :po F::H iQ ::J: (.?c") '!' !Sm ~ N ~ (lD LINDA A. RANDALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW : NO. 03-3529 DOROTHY A. MATESEVAC, Defendant NOTICE TO PLEAD TO: Plaintiff, Linda Randall c/o Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070 You are hereby notified to plead to the enclosed Answer with New Matter to Plaintiffs Complaint within twenty (20) days from service hereof or a delimit judgment may be filed against you. MARSHALL, DENNEHEY, WARNER, COLEMA GOGGIN B . AT E L. l.D. No. 76080 4200 Crums Mill Road, Suite B Harrisburg, P A 17112 (717) 651-3501 Attorneys for the Defendant DATE: 1/3" (OY LINDA A. RANDALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION -LAW : NO. 03-3529 DOROTHY A. MATESEVAC, Defendant ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT AND NOW comes Defendant, Dorothy A. Matesevac, by and through the undersigned counsel, who answers Plaintiff's Complaint as follows: I. Denied. Responding Defendant lacks knowledg,e sufficient to form a belief as to the truth of the allegations contained in Paragraph 1, and therefiJre, the same are denied with strict proof thereof required at trial. 2. Admitted. 3. Admitted. 4. Denied. Responding Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in Paragraph 4, and therefore, the same are denied with strict proof thereof required at trial. Paragraph 4 is further denied in that the same contains conclusions oflaw to which no response is required, and therefore, the same are denied with strict proof thereof required at trial. 5. Denied. Responding Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in Paragraph 5, and therefore, the same are denied with strict proof thereof required at trial. Paragraph 5 is further denied in that the same contains conclusions oflaw to which no response is required, and therefore, the same are denied with strict proof thereof required at trial. 6. Denied. Responding Defendant lacks knowledge sufficient to form a belief as to the truth of the allegations contained in Paragraph 6, and therefore, the same are denied with strict proof thereof required at trial. Paragraph 6 is further denied in that the same contains conclusions oflaw to which no response is required, and therefore, the same are denied with strict proof thereof required at trial. 7. Denied. Paragraph 7 is denied in that the same contains conclusions of law to which no response is required, and therefore, the same are denied with strict proof thereof required at trial. 8. Denied. Paragraph 8 is denied in that the same contains conclusions oflaw to which no response is required, and therefore, the same are denil~d with strict proof thereof required at trial. 9. (a) - (d) Denied. Paragraph 9 is denied in that the same contains conclusions of law to which no response is required, and therefore, the same are denied with strict proof thereof required at trial. 10. Denied. Paragraph 10 is denied in that the saml~ contains conclusions oflaw to which no response is required, and therefore, the same are denied with strict proof thereof required at trial. 11. Denied. Paragraph II is denied in that the same contains conclusions of law to which no response is required, and therefore, the same are denied with strict proof thereof required at trial. 12. Denied. Paragraph 12 is denied in that the same contains conclusions of law to which no response is required, and therefore, the same ar'~ denied with strict proof thereof required at trial. 13. Denied. Paragraph 13 is denied in that the same contains conclusions of law to which no response is required, and therefore, the same are denied with strict proof thereof required at trial. WHEREFORE, Defendant, Dorothy Matesevac, respectfully requests judgment in her favor and against the Plaintiff together with such other costs this Honorable Court deems appropriate. NEW MATTER 14. Plaintiffs claims are barred by the applicable statute oflimitations. 15. Plaintiff has failed to state a cause of action upon which relief can be granted. 16. Plaintiff is barred and/or limited by all applicable provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 17. No act or omission on the part of the Defendant was a substantial or contributing factor in bringing about Plaintiffs alleged injuries and/or damages, all such injuries and/or damages being expressly denied. 18. Any and all injuries and/or damages as described by Plaintiff in her Complaint, the same being expressly denied, were caused in whole or in part by the acts or omissions on the part of Plaintiff and/or others over whom Defendant had no control nor right of control. 19. Plaintiffs claims are barred and/or limited by the doctrine of res judicata and/or collateral estoppel. 20. Plaintiffs claims are derivative in nature and are barred as a matter oflaw. 21. Defendant breached no duty of care owed to the Plaintiff under the circumstances. 22. Plaintiffs claims are barred and/or limited by the Pennsylvania Comparative Negligence Act. 23. Plaintiffs claims are barred and/or limited by the applicable provisions of the Pennsylvania Worker's Compensation Act. 24. At all times material hereto, Defendant acted in a safe, legal and non-negligent manner. 25. Plaintiffs negligent operation of his motor vehide was the sole and proximate cause of all alleged injuries and damages. 26. Plaintiffs Complaint and or claims are barred by their selection of limited tort as set forth by 75 Pa.C.SA S 1705. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: ~ 'Matthew 1.. Owens, Esquire LD. No. 76080 4200 Crums Mill Road Harrisburg, PA 17112 (717) 651-3501 .. DATE: J {16/0'l Attorneys for the Defendant I05_A ILlABIMWILLPGI140611IACSl12180102081 VERIFICATION The undersigned hereby verifies that the statements in the foregoing Defendant's Answer with New Matter to Plaintiffs Complaint are based upon infomlation which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of the defense of this lawsuit. The language of the Defendant's Answ.:r with New Matter to Plaintiffs Complaint is that of counsel and not my own. I have read the Answer with New Matter to Plaintiffs Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the Defendant's Answer with New Matter to Plaintiffs Complaint are that of counsel, I have relied upon my counsel in making this verification. The undersigned also understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. a{}g~ Yhrrtu~~& Dorothy Mates ac DATE: ... g h~/{)J) / ' LINDA A. RANDALL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -LAW : NO. 03-3529 DOROTHY A. MATESEV AC, Defendant CERTIFICATE OF SERVICE I, J1"fd, Z;I(,"an employee of Marshall, Dennehey, Warner, Coleman & 7 Goggin, do hereby certify that on this / r.) t.uay of April 2004, I served a copy of the foregoing document via First Class United States mail, postage prepaid as follows: Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070 ~.t, z...a... -,:: :;- co ~:-~ <;'_.:;1 .L- C) ., ~ f'h:D r- -')rn ==QCJ Uc ;~;~ ~~~~ ."-, --'--- ;'j ;:,) Ch / , ),-'-1 -- :~ . ..~, """ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MATTHEW L. OWENS, ESQ. 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 this 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: 04/26/2004 cMCS on b,ehYY of ~j) r; iA/1t1dZ~ "C/~ M'AfrBEW L. OWEWESQ. , Attorney for DEFENDANT .~ \ DEll-488395 4881.3 -LO 1. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOClJMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009 _ 21 [ Note: see enclosed list of locations] TO: BARBARA SUMPLE-SULLIVAN, PLAINTIFF COUNSEL MCS on behalf of MATTHEW L. OWENS, ESQ. intencffi 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 the twenty day notice period is waived or if no objection is made, then the subpoena !Ray be served. 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: 04/06/2004 MCS on behalf of MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT CC: MATTHEW L. OWENS, ESQ. - 12180-02081 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET D800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-261428 48813 - C 01 >>> LOCATION LIST <<< LOCATION NAME RECORDS REQUESTED PAGE: 1 DR. MAX BRAUN, M.D. ACRI FAMILY CHIROPRACTIC HEALTH SOUTH PiT STATE FARM INSURANCE COMPANY PINNACLE HEALTH HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL UNIVERSITY HOSPITAL S. HERSHEY PALM BEACH GARDENS MEDICAL MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS m:02-261428 48813-COl COMMONWEAL 'fH OFPENNSYL VANIA COUNTY OF CUMBERLAND LINDA RANDALL FileNo. 03"3529 vs. DOROTIIY MATESEV AC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR. MAX BRAUN M.D. (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: ..n SEE A'IT ACHED RIDER .... at The MCS GrollP Inc 1601 Market Street Suite 800 Philadelphia PA 1'9103 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: ADDRESS: MATTHEW L. OWENS. ESO. 4200 CRUMS MILL ROAD SUITE B HARRISBURG. P A 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: A'ITORNEY FOR: Defendant Date: APR 2 6 2004 fYI :J /} r /..... J I ;)/yf , BY THE COURT: ~ Prothonotary/Clerk, Civil Di '- d4f).,,>-LJ P.~4A~ Deputy Seal of the Court 48813-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. MAX BRAUN, M.D. 175 LANCASTER BLVD. MECHANICSBURG, PA 17055 RE: 48813 LINDA RANDALL Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medkation! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: LINDA RANDALL 304 S. MARKET STREET, MECHANICSBURG, PA 17050 Social Security #: 332-54-8085 Date of Birth: 08-02-1957 SU10-497378 48813-LOl CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MATTHEW L. OWENS, ESQ. 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 Ute proposed subpoena, is attached to this 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. MCS on behalf of DATE: 04/26/2004 MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT DEll-488396 4 B B 1.3 -LO:2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RUll..E 4009.21 [ Note: see enclosed list of locations] TO: BARBARA SUMPLE-SULLIVAN, PLAINTIFF COUNSEL MCS on behalf of MATTHEW L. OWENS, ESQ. intenc~ 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 the twenty day notice period is waived or if no objection is made, then the subpoena may be served. 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: 04/06/2004 MCS on behalf of MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT CC: MATTHEW L. OWENS, ESQ. - 12180-02081 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-261428 48813 -CO 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED DR. MAX BRAUN. M.D. ACRI FAMILY CHIROPRACTIC HEALTH SOUTH PiT STATE FARM INSURANCE COMPANY PINNACLE HEALTH HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL UNIVERSITY HOSPITAL S. HERSHEY PALM BEACH GARDENS MEDICAL MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DI,02-261428 48813-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LINDA RANDALL FileNo. 03-3529 vs. DOROTHY MATESEV AC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ACRI FAMILY CHIROPRACTIC (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 RIDER .... at The MCS GrO\lO Ine 1601 Market Street Suite 800 Philadelphia PA 19103 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. TIllS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOV/ING PERSON: NAME: MATTHEW L. OWENS. ESO. ADDRESS: 4200 CRUMS MILL ROAD SlJITE B HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant Date: APR 2 6 2004 (YOu...L .2/:) noli - I f Seal of the Court BY THE COURT: ~h: Prothonotary/Clerk, Civil Div' '- a~." _P.7fC"~~ Deputy 48813-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ACRI FAMILY CHIROPRACTIC 202 N. FREDRICK ST. MECHANICSBURG, PA 17055 RE: 48813 LINDA RANDALL Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: LINDA RANDALL 304 S. MARKET STREET, MECHANICSBURG, PA 17050 Social Security #: 332-54-8085 Date of Birth: 08-02-1957 8UlO-497380 48813-L02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MATTHEW L. OWENS, ESQ. 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 this 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. MCS on behalf of DATE: 04(26(2004 MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT DEll-488397 4 B B 1. 3 - L 03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RUJl..E 4009.21 [ Note: see enclosed list of locations] TO: BARBARA SUMPLE-SULLIVAN, PLAINTIFF COUNSEL MCS on behalf of MATTHEW L. OWENS, ESQ. intenc~ 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 the twenty day notice period is waived or if no objection is made. then the subpoena may be served. Complete copies of any reproduced records may be ordered at YOllr expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/06/2004 MCS on behalf of MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT CC: MATTHEW L. OWENS, ESQ. - 12180-02081 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-261428 4 B B 1 3 - C 01 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED DR. MAX BRAUN, M.D. ACRI FAMILY CHIROPRACTIC HEALTH SOUTH PiT STATE FARM INSURANCE COMPANY PINNACLE HEALTH HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL UNIVERSITY HOSPITAL S. HERSHEY PALM BEACH GARDENS MEDICAL MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS D1W2-261428 4 a a 13 - C 0 1 COMMONWEALTH OFPENNSYL VANIA COUNTY OF CUMBERLAND LINDA RANDALL FileNo. 03-3529 vs. DOROTIIY MATESEV AC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HEALTH SOUTH prr (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 ATI ACHED RIDER **** at The MCS Group Ine 1601 Market Street Suite 800 Philadelphia PA 19103 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: ADDRESS: MATfHEW L. OWENS. ESO. 4200 CRUMS MILL ROAD smTE B HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATIORNEY FOR: Defendant BY THE COURT: L Prothonotary/Clerk, Civil Divis' '- at!.,.. J!.7f44-'FU- Deputy Date: APR 2 6 7004 /Yl~ML ~~', JI'Y)Y Seal of the Court 48813-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTH SOUTH PIT 906 CENTURY DRIVE MECHANICSBURG, PA 17055 RE: 48813 LINDA RANDALL Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: LINDA RANDALL 304 S. MARKET STREET, MECHANICSBURG, PA 17050 Social Security #: 332-54-8085 Date of Birth: 08-02-1957 81110-497382 4BB13-L03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MATTHEW L. OWENS, ESQ. 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 this 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. MCS on behalf of DATE: 04/26/2004 MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT DEll-488398 488 l 3 - L 04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PURSUANT TO RUlr..E 4009.21 [ Note: see enclosed list of locations] TO: BARBARA SUMPLE-SULLIVAN, PLAINTIFF COUNSEL MCS on behalf of MATTHEW L. OWENS, ESQ. inten(~ 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 the twenty day notice period is waived or if no objection is made, then the subpoena may be served. 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: 04/06/2004 MCS on behalf of MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT CC: MATTHEW L. OWENS, ESQ. - 12180-02081 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-261428 4BB13-COl ", LOCATION LIST <<< LOCATION NAME RECORDS REQUESTED DR. MAX BRAUN. M.D. ACRI FAMILY CHIROPRACTIC HEALTH SOUTH pIT STATE FARM INSURANCE COMPANY PINNACLE HEALTH HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL UNIVERSITY HOSPITAL S. HERSHEY PALM BEACH GARDENS MEDICAL MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS PAGE: 1 D:&02-261428 4 a a 13 - C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LINDA RANDALL FileNo. 03-3529 vs. DOROTHY MATESEV AC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for STATE FARM 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 ATIACHED RIDER .... at The MCS GroUD IDe 1601 Market Street Suite 800 Philadelphia PA ]9103 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. TIllS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MATTHEW L. OWENS. ESO. ADDRESS: 4200 CRUMS MILL ROAD SUITE B HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATIORNEY FOR: Defendant Date: APR 2 6 2004 trl~brL .]1, :J.I'Y\'( BY THE COURT: k, Prothonotary/Clerk, Civil Divi . '- 4Z".,. ,,_2 ~.I~<~ Deputy Seal of the Court 48813-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: STATE FARM INSURANCE COMPANY 2 SELLERS DRIVE ALTOONA, PA 16601 RE: 48813 LINDA RANDALL PIP REPM :PAM BOWSWER CLAIM # 381769710 Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all slllch items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: LINDA RANDALL 304 S. MARKET STREET, MECHANICSBURG, PA 17050 Social Security #: 332-54-8085 Date of Birth: 08-02-1957 Date of Loss: 09/04/2001 SU10-497384488J..3-L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBIPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MATTHEW L. OWENS, ESQ. 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 this 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. MCS on behalf of DATE: 04/26/2004 MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT DEll-4BB399 4881.3-LOS COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RUloE 4009.21 [ Note: see enclosed list of locations] TO: BARBARA SUMPLE-SULLIVAN, PLAINTIFF COUNSEL MCS on behalf of MATTHEW L. OWENS, ESQ. inten(~ 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 the twenty day notice period is waived or if no objection is made, then the subpoena !lay be served. 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: 04/06/2004 MCS on behalf of MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT CC: MATTHEW L. OWENS, ESQ. - 12180-02081 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 0802-261428 4 B B 13 -CO 1 >>> LOCATION LIST <<< LOCATION NAME RECORDS REQUESTED DR. MAX BRAUN, M.D. ACRI FAMILY CHIROPRACTIC HEALTH SOUTH PiT STATE FARM INSURANCE COMPANY PINNACLE HEALTH HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL UNIVERSITY HOSPITAL S. HERSHEY PALM BEACH GARDENS MEDICAL MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS PAGE: 1 OIl02-261428 4 B B 13 - C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LINDA RANDALL FileNo. 03-3529 vs. DOROTHY MATESEV AC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PINNACLE HEALTH HOSPITAL (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 ATIACHED RIDER .... at The MCS Grouo Ine 1601 Market Street Suite 800 Philadelphia PA ]9103 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: ADDRESS: MATTHEW L. OWENS. ESO. 4200 CRUMS MILL ROAD SUITE B HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATIORNEY FOR: Defendant Date: APR 2 6 2004 fYl'::ln r t... d I. ';LCJO'! I BY THE COURT: A Prothonotary/Clerk, Civil Divis' '- ~'-?ob _e.7f-IA~~ Deputy Seal of the Court 48813-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH HOSPITAL PO BOX 2353 HARRISBURG, PA 17105 RE: 48813 LINDA RANDALL DATES FROM 4/24/01 TO 10/31/02 Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical fIle, including but not limited to any and all records, correspondence to and from the consulting and/or treating physici~m., files, memoranda, handwritten notes, history and physical reports, medication! prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all sllch items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: LINDA RANDALL 304 S, MARKET STREET, MECHANICSBURG, PA 17050 Social Security #: 332-54-8085 Date of Birth: 08-02-1957 8U10-497386 48813-L05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MATTHEW L. OWENS, ESQ. 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 th,= proposed subpoena, is attached to this 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. MCS on behalf of DATE: 04/26/2004 MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT DEll-488400 4881. 3 - L 06 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations] TO: BARBARA SUMPLE-SULLIVAN, PLAINTIFF COUNSEL MCS on behalf of MATTHEW L. OWENS, ESQ. inten,ffi 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 the twenty day notice period is waived or if no objection is made. then the subpoena may be served. 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: 04/06/2004 MCS on behalf of MATTHEW L. OWENS. ESQ. Attorney for DEFENDANT CC: MATTHEW L. OWENS. ESQ. - 12180-02081 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 D1~02-261428 48813 -CO 1 >>> LOCATION LIST <<< LOCATION NAME RECORDS REQUESTED DR. MAX BRAUN. M.D. ACRI FAMILY CHIROPRACTIC HEALTH SOUTH PiT STATE FARM INSURANCE COMPANY PINNACLE HEALTH HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL UNIVERSITY HOSPITAL S. HERSHEY PALM BEACH GARDENS MEDICAL MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS PAGE: 1 D]802-261428 48813 - C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LINDA RANDALL FileNo. 03-3529 vs. DOROTHY MATESEV AC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL ~roneofPe~onorEntiry) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATf ACHED RIDER **** at TheMCSGroun Ine 1601 Market Street Suite 800 Philadelphia PA 19103 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. TillS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: MATTIIEW L. OWENS. ESO. 4200 CRIJMS MILL ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: A TfORNEY FOR: Defendant Date: APR 2 6 2004 fY7';u)rL _.11, ;).~ Seal of the Court BY THE COURT: ~ Prothonotary/Clerk, Civil Divisi '-- ~'?" 9 7fh~ Deputy - 48813-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA I70Il RE: 48813 LINDA RANDALL DATES FROM 9/18/99 TO 4/08/02 Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, nurse' s notes, doctor's comments, dietary restrictions, and a1ll?atient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: LINDA RANDALL 304 S. MARKET STREET, MECHANICSBURG, PA 17050 Social Security #: 332-54-8085 Date of Birth: 08-02-1957 8\:10-497388 48813-L06 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MATTHEW L. OWENS, ESQ. 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 this 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. MCS on behalf of DATE: 04/26/2004 MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT D1111-488401 48813 - L 07 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RID.E 4009.21 [ Note: see enclosed list of locations] TO: BARBARA SUMPLE-SULLIVAN, PLAINTIFF COUNSEL MCS on behalf of MATTHEW L. OWENS, ESQ. 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 the twenty day notice period is waived or if no objection is made, then the subpoena may be served. 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: 04/06/2004 MCS on behalf of MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT CC: MATTHEW L. OWENS, ESQ. - 12180-02081 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246 -0 9 0 0 DE02-261428 48813 - C 01 >>> LOCATION LIST <<< LOCATION NAME RECORDS REQUESTED PAGE: 1 DR. MAX BRAUN, M.D. ACRI FAMILY CHIROPRACTIC HEALTH SOUTH PiT STATE FARM INSURANCE COMPANY PINNACLE HEALTH HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL UNIVERSITY HOSPITAL S. HERSHEY PALM BEACH GARDENS MEDICAL MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-261428 4 B B 13 -CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LINDA RANDALL FileNo. 03-3529 vs. DOROTHY MATESEV AC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (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 RIDER .... at TheMCSGroup Ine 1601 Market Street Suite &00 Philadelphia PA 19103 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 (20IS after its service, the party serving this subpoena may seek a court order compelling you to comply with it. " , TIllS SUBPOENA WAS ISSUED AT THE REQUEST OF TIIE FOLLOVIING PERSON: MATTHEW L. OWENS. ESO. 4200 CRUMS MILL ROAD SmTE B HARRISBURG. P A 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant NAME: ADDRESS: Date: fYI. t.. APR 2 6 2004 :'/1(' ),/ ')/YJY - , BY TIIE COURT: ~ Prothonotary/Clerk, Civil IVISI ~,-n .fJ.7p-14Ac..r- Deputy Seal of the Court 48813-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL III S. FRONT STREET HARRISBURG, PA 171012099 RE: 48813 LINDA RANDALL DATES FROM 9/4/01 TO 9/6/01 Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical me, including but not limited to any and all records, correspondence to and from the consulting and/or treating physici;m, mes, memoranda, handwritten notes, history and physical reports, medication! prescription records, nurse' s notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: LINDA RANDALL 304 S. MARKET STREET, MECHANICSBURG, PA 17050 Social Security #: 332-54-8085 Date of Birth: 08-02-1957 8U10-497390 488l3-L07 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MATTHEW L. OWENS, ESQ. 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 this 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. MCS on behalf of DATE: 04/26/2004 MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT DEll-488402488l3-L08 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO Rm~E 4009.21 [ Note: see enclosed list of locations] TO: BARBARA SUMPLE-SULLIVAN, PLAINTIFF COUNSEL MCS on behalf of MATTHEW L. OWENS, ESQ. intenc~ 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 the twenty day notice period is waived or if no objection is made, then the subpoena may be served. 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: 04/06/2004 MCS on behalf of MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT CC: MATTHEW L. OWENS, ESQ. - 12180-02081 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 D802-261428 4 a a 13 - C 01 >>> LOCATION LIST <<< LOCATION NAME RECORDS REQUESTED PAGE: 1 DR. MAX BRAUN. M.D. ACRI FAMILY CHIROPRACTIC HEALTH SOUTH PiT STATE FARM INSURANCE COMPANY PINNACLE HEALTH HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL UNIVERSITY HOSPITAL S. HERSHEY PALM BEACH GARDENS MEDICAL MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS DE02-26142848813-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LINDA RANDALL FileNo. 03-3529 vs. DOROTHY MATESEV AC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for UNIVERSITY HOSPITAL S. HERSHEY (Name of Person or Entity) WitJlln twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun Ine 1601 Market Street Suite 800 Phi]ade]nhia PA 19]03 You may deliver or mail legible copies of the documents or produce thing:i 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 w:ithin 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: MATTHEW L. OWENS. ESO. ADDRESS: 4200 CRlJMS MILL ROAD SUITE B HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant APR 2 6 2004 Date: {Yl';:UJr L _<I ~ 1'JC)t./ I / Seal of the Court 48813-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: UNIVERSITY HOSPITAL S. HERSHEY MEDICAL CENTER 500 UNIVERSITY DR. # HERSHEY, PA 17033 RE: 48813 LINDA RANDALL OUTPATIENT FILE FROM 7/22/99 TO 7/31/00,INPATlENT FILE FROM 6/28/00 TO 7/12/00,ER VISIT FROM 8/25/00 TO 8/26/00 Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medkationl prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: LINDA RANDALL 304 S. MARKET STREET, MECHANICSBURG, Pi\. 17050 Social Security #: 332-54-8085 Date of Birth: 08-02-1957 SUlO-497392 48 813 -LO 8 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MATTHEW L. OWENS, ESQ. 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 this 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. MCS on behalf of DATE: 04/26/2004 MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT DEll-488403 4881. 3 - L 09 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS LINDA RANDALL TERM, -VS- CASE NO: 03-3529 DOROTHY MATESEVAC NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO Rm:.E 4009.21 [ Note: see enclosed list of locations] TO: BARBARA SUMPLE-SULLIVAN, PLAINTIFF COUNSEL MCS on behalf of MATTHEW L. OWENS, ESQ. intenc~ 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 the twenty day notice period is waived or if no objection is made, then the subpoena may be served. 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: 04/06/2004 MCS on behalf of MATTHEW L. OWENS, ESQ. Attorney for DEFENDANT CC: MATTHEW L. OWENS, ESQ. - 12180-02081 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-261428 48813 - CO 1 >>> LOCATION LIST <<< LOCATION NAME RECORDS REQUESTED PAGE: 1 DR. MAX BRAUN, M.D. ACRI FAMILY CHIROPRACTIC HEALTH SOUTH pIT STATE FARM INSURANCE COMPANY PINNACLE HEALTH HOSPITAL HOLY SPIRIT HOSPITAL HARRISBURG HOSPITAL UNIVERSITY HOSPITAL S. HERSHEY PALM BEACH GARDENS MEDICAL MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS INSURANCE MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS D]~02-261428 48813 - C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LINDA RANDALL FileNo. 03-3529 vs. DOROTHY MATESEV AC SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PALM BEACH GARDENS MEDICAL (Name of Person or Entity) Within twenty (20) days after service ofthis subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS GrollP [nc 1601 Market Street Suite 800 Phi1ade1nhia PA ]9103 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. TIIIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: MATTHEW L. OWENS. ESO. 4200 CRUMS MILL ROAD SlJITE B HARRISBURG. P A 171 10 TELEPHONE: (215) 246-0900 SUPREME COURT lD #: ATTORNEY FOR: Defendant Date: ~A fJ l.. APR 2 6 2004 ~I Ji'V)7' , :zr:CO~T: Prothonotary/Clerk, Civil Divis' < /JA.'J..... D ~p .7f0UckJ ~ Seal of the Court 48813-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PALM BEACH GARDENS MEDICAL CENTER 3360 BURNS ROAD PALM BEACH GARDENS, FL 33410 RE: 48813 LINDA RANDALL DATES FROM 2/14/85 TO 2/21/85 DATES FROM 5/20/85 TO 5/23/85 Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, fIles, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be sltored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: LINDA RANDALL 304 S. MARKET STREET, MECHANICSBURG, PA 17050 Social Security #: 332-54-8085 Date of Birth: 08-02-1957 SlJ10-497394 48813-L09 o c -J~: [...1,,;', t~; ~~;~l -<":"' ~i= ).. ~~~j c Z ~ ...., = = .r- ".. " ;;0 N \D ." :r ry ~ :r m:n ~~ ;rSfl 2~ oM """' 55 -< ..... Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 LINDA A. RANDALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - (X) Law DOROTHY A. MATESEV AC, Defendant NO. 2003-3529 JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO NEW MATTER 14, Denied. Paragraph 14 is denied as a conclusion oflaw to which no response is required, and therefore, same is denied with strict proof thereof required at trial. 15. Denied. Paragraph 15 is denied as a conclusion of law to which no response is required, and therefore, same is denied with strict proof thereof required at trial. 16. Denied. Paragraph 16 is denied as a conclusion oflaw to which no response is required, and therefore, same is denied with strict proof thereof required at trial. 17, Denied. It is averred that the acts and/or omissions of the Defendant were the sole, substantial and contributing factor to Plaintitl's injuries and/or damages. 18. Denied. It is denied that any injuries or damages describ,~d by Plaintiff in the Complaint were caused by any act or omission of Plaintiff and/or others over who Defendant had no control or right of control. By way of further answer, Plaintiff's response to paragraph 17 above is incorporated herein by reference. 19, Denied. Paragraph 19 is denied as a conclusion of law to which no response is required, and therefore, same is denied with strict proof thereof required at trial. 20. Denied. Paragraph 20 is denied as a conclusion oflaw to which no response is required, and therefore, same is denied with strict proofthereof re:quired at trial. 21. Denied. Paragraph 21 is denied as a conclusion of law to which no response is required, and therefore, same is denied with strict proof thereof re:quired at trial. By way of further answer, Defendant breached the duty of care owed to Plaintiff which duty of care included, but is not limited to, the responsibility of safe lmd proper operation of her motor vehicle, 22. Denied. Paragraph 22 is denied as a conclusion oflaw to which no response is required, and therefore, same is denied with strict proof thereof n:quired at trial. 23. Denied. Paragraph 23 is denied as a conclusion oflaw to which no response is required, and therefore, same is denied with strict proof thereof mquired at trial. 2 24. Denied. It is denied that Defendant acted in a safe, legal and non-negligent manner. By way of further answer, Plaintiff incorporates by referencl: paragraphs 6 through 9 of Plaintiff's Complaint. 25. Denied. It is denied that Plaintiff was negligent in the operation of his (sic) her vehicle. By way of further answer, paragraphs 5 through 9 of Plaintiff's Complaint are incorporated herein by reference, It is further denied that Plaintiff's operation of her vehicle was the cause of any injury or damage. 26. Denied. Paragraph 26 is denied as a conclusion oflaw to which no response is required, and therefore, same is denied with strict proof thereof required at trial. Plaintiff did not make any selection oflimited tort. DATE: APri~ 2004 ~ire Attorney for Plaintiff 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 3 Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 LINDA A. RANDALL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - (X) Law DOROTHY A. MATESEVAC, Defendant : NO. 2003-3529 : JURY TRIAL DEMANDED VERIFICATION I, Linda A. Randall, hereby certify that my Plaintiff's R,eply to New Matter are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pac C.S.A. 34904 relating to unsworn falsification to authorities. DATED: M ?3 ,2004 ~~~ A. ~2\l\"daee~ ----au;da A. Randall Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 LINDA A. RANDALL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - (X) Law DOROTHY A. MATESEV AC, Defendant : NO, 2003-3529 : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy ofthe foregoing PLAINTIFF'S REPLY TO NEW MA TIER, in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Matthew L. Owens, Esquir'e Marshall, Dennehey, Warner, Colemarl and Goggin 4200 Crums Mill Road, Suit(: B Harrisburg, P A 17112 DATED: April2Z'-,2004 Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court J.D. No. 32317 o c- ;$~ "'"1-,---", f~~fn i{(~~': ;:'Si-~:-' ~'., ec~. ;<:;,--,>- ):..-.:. \~j c:. <~ :::;f '" ~ """'" :t.. ;g W <:::> ~ '>c' w CJ) ~ 5!::n fll,-==-. "=,,.,, :,or;:, 06 =;1-,. (-):[J .';..() (Si"t] -., '"/-'" ~ Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LINDA A RANDALL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - (X) Law : NO. 2003-3529 DOROTHY A MATESEVAC, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please discontinue the above captioned matter with prejudi . DATE~~ 2005 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland,P A 17070-1931 (717) 774-1445 Supreme Court J.D. 32317 Attorney for Plaintiff ~ LINDA A. RANDALL, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -LAW : NO. 03-3529 DOROTHY A. MATESEV AC, Defendant CERTIFICATE OF SERVICE ,/] /',- /, I, r h l t t( C-, ( {;-an employee of Marshall, Dennehey, Warner, Coleman & ;; Goggin, do hereby certify that on this ~day of January, 2006, I served a copy ofthe foregoing document via First Class United States mail, postage prepaid as follows: Barbara Swnple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070 (r: - Lth~{,L2r~ , / o " (-") -'1\ --1 --:-:. ;ll -, CJ c,.: