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HomeMy WebLinkAbout07-2838• r "'b O . c G, CD C^? co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff, Vs. No. 0 7- ,z 8 3 8' PRAECIPE FOR WRIT OF SUMMONS IN CIVIL ACTION STEPHEN A. SKINNER, Defendant. Filed on behalf of Plaintiff Counsel of record for this party: Raymond J. Conlon, Esquire PA I. D. # 49495 conlon@conlontarker.com Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 724.285.7700 724.285.6700 fax .a' i. 'w' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, No. 6 7- a ?.3? Plaintiff, VS. STEPHEN A. SKINNER, Defendant. PRAECIPE FOR WRIT OF SUMMONS TO: Curtis R. Long, Prothonotary Please issue a Writ of Summons in Civil Action against the Defendant in the above-captioned matter. Respectfully submitted, Conlon Tarker, P.C. Raymond J. Fon squire Attorney for Plaintif S 1 -l I Q ? OQ t7 ri, r ? c7 Vl ? ? a CZ) 7 7` ? 0 , . , Commonwealth of Pennsylvania County of Cumberland Ralph C. Crone Plaintiff Court of Common Pleas V& No. _ 07_ 2838_ Civil Term ________ _____ lg Stephen A. Skinner Defendant In __ Civil Law ------------------------------- 4607 Connecticut Avenue NW Washington, D. C. 20008 To ___ Stephen_A._ Skinner ------------------- You are hereby notified that ------- Ralph C,,- Crone -----____-- -------------------------------------------------------------- the Plaintiff has commenced an action in ----------- lY-U-LanL__________________________________ against you which you are required to defend or a default judgment may be entered against you. (SEAL) --1---_---# --- ------------- J.s Prothonotary Date _ _LApY_ 10_,_ 2007 ______ p?c___ g - Y ----------------_ ------------------------- Deputy nJi rr o°o ?j i? C I 1 .P N I--? I I--`• I }-? I? I .? CD O C ?F-, i o 1 I 1 Ul 0) C4 In p j n I N (11 t:) fi loo C-4) F- F O 1 1 n 00 ?I o l rno ?j F- o ; (D fi C) I I fi ? W I I r. p ? I I i H I 1 1 1 I (p ;9 1 1 I I I lD i ? I I I 1 I I I I I I I M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, : Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Todd B. Narvol, Esquire, Marc A. Moyer, Esquire, and Thomas, Thomas & Hafer LLP, 305 North Front Street, 6th Floor, Post Office Box 999, Harrisburg, PA 17108, on behalf of Defendant Stephen A. Skinner. We are authorized to accept service of all documents in this matter. Respectfully submitted, Dated: June 11, 2007 Todd/B. Narvo , squire Attorney I.D o. Marc A. er, Esquire Attorney .76434 THO , THOMAS & HAFER LLP 305 North Front Street, 6th Floor Post Office Box 999 Harrisburg, PA 17108 717-441-3960 mmoyer@tthlaw.com Counsel for Defendant Stephen A. Skinner I .A CERTIFICATE OF SERVICE On this 11'' day of June 2007, I, Kristine Hendrix, a legal secretary, with the law firm Thomas, Thomas & Hafer, LLP, hereby certify that I have, this day, served a true and correct copy of the PRAECIPE FOR ENTRY OF APPEARANCE upon the person(s) and at the address(es) below named via United States First Class Mail, postage prepaid, in Harrisburg, PA: Raymond J. Conlon, Esquire Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 Counsel for Plaintiff Kri tine Hendrix 508775.1 ? ? ? ' . ?-.j t 7 :..? ?` }"? ? r " ? .?? y J' '? ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, No. 07-2838 Civil Term Plaintiff, VS. AFFIDAVIT OF SERVICE OF WRIT OF SUMMONS STEPHEN A. SKINNER, Defendant. Filed on behalf of Plaintiff Counsel of record for this party: Raymond J. Conlon, Esquire PA I. D. # 49495 conton@contontarker.com Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 724.285.7700 724.285.6700 fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, No. 07-2838 Civil Term Plaintiff, VS. STEPHEN A. SKINNER, Defendant. AFFIDAVIT OF SERVICE OF WRIT OF SUMMONS TO: Curtis R. Long, Prothonotary I hereby certify that the Writ of Summons in Civil Action was served upon the Defendant, Stephen A. Skinner, on May 17, 2007, and May 21, 2007 as evidenced by the certified mail return receipts attached hereto as Exhibits A and B respectively. Respectfully submitted, , P.,,r,,. Sworn to and subscribed before me this 110 day of June 2007 Notary Public COMMONWEALTH OF PENNSYLVANIA =MZicheeleAA. ry Public County Oct. 31,20M Member, Pennsylvania Association of Notaries Raym6R6J./Conlon, Esquire Attorney fof Plaintiff EXHIBIT A ¦ Complete items 1, 2, and 3. Also complete Item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. .0 Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to., Stephi n A. Skinner 4607 `Connecticut Avenue NW Washington, X 20008 ?C SigrvaUxe El 'ggerd x 4, Addresse eeehred (PdntedName) C. of Deliver D. Is delivery address different from Item 11 13 Yes If YES, enter delivery address below, ? No RECEIVED MAY 2 12007 3. Service Type RA Cert W Mail 0 Express Mall 0 Registered 0 Return Receipt for'Merchandis4 0 insured Malt 0 C.O.D. 4. Restricted Deliver/? pft Fee) 0 Yes 2. Article Number 7005 1160 11002 1820 3547 (Thmfer from servloe IOW PS Form 3811, February 2004 Domestic Return Receipt 102sss-o24M-154 a h LISPS - Track & Confirm 0 UNIT DSTA POSTAL SERVFCEe Page 1 of 1 Home I Help Track & Confirm Track & Confirm !Search flesults Label/Receipt Number: 70051160 0002 1820 3547 Status: Delivered Your item was delivered at 2:13 PM on May 17, 2007 in WASHINGTON, DC 20008. Addt'CFnar9Dy0Bss Rstmra I9R 1#SF f s / Track, Confirm Enter Label/Receipt Number. ifcation i?ptions Track & Confirm by email Get current event information or updates for your item sent to you or others by email. oii ® POSTAL INSPECTORS site map contact us government services jobs National & Premier Accounts Preserving the Trust Copyright ©1999-2004 LISPS. All Rights Reserved. Terms of Use Privacy Policy http://trkcnfrml .smi.usps.com/PTSIntemetWeb/InterLabelInquiry.do 6/11/2007 EXHIBIT ` i I SENDER: COMPLETE THIS SECTION COMPLETE THIS SrCTION OtJ OELIVEHY ¦ Complete Items 1, 2, and 3. Also complete A. Sign Item 4 H Restricted Delivery is desired. X ? Agent ¦ Prinfydur name and address on the reverse.- 13 Addresse so that we can return the card to you. B. Re ed by ( ted ' e) C. Date of Deliver ¦ Attach this card to the back of the mallplece, or on the front If space permits. D. Is delivery address different from Item 17 ? Yes 1..prticle Addressed to: It YES, enter delivery address below: ? No : 3 .. Stephen A. Skinner 5 Y1'. East Main Street Atment C8 Lekington, KY 40508 a. Service type ER Certified Mai! ? Express Mail 1 ? Registered ? Return Receipt for Merohandia i ? Insured Mail ? C.O.D. 4. Restricted Delivery? {Extra Fee) ? Yes 2, Article Number 7005 116 0 0002 1 8 2 0 3561 (Trenskr from service k6e7J PS Form 3811, February 2004 Domestic Return Receipt 102595)2-wFtst 3 ri s . LISPS - Track & Confirm Track Confirm Search Results Page 1 of 1 Label/Receipt Number: 70051160 0002 1820 3561 Confirm Status: Delivered Track & Enter LabeUReceipt Number. Your item was delivered at 3:49 PM on May 21, 2007 in WASHINGTON, DC 20008. Addidara DoWs> „!fame U1 USPS.cem Mow > Track & Confirm by email Get current event information or updates for your item sent to you or others by email. 60> ® POSTAL INSPECTORS site map contact us government services jobs National & Premier Accounts Preserving the Trust Copyright ©1999-2004 USPS. All Rights Reserved. Terms of Use Privacy Policy http://trkci&ml.smi.usps.com/PTSintemetWeb/InterLabellnquiry.do 6/11/2007 3TAMS Home I Help CERTIFICATE OF SERVICE I hereby certify that a copy of the within document was served upon the individual named below on the I0, - day of June, 2007 by first class, U.S. mail, postage prepaid. Stephen A. Skinner 4607 Connecticut Avenue, NW Washington, D.C. 20008 Stephen A. Skinner 521 East Main Street Apartment C8 Lexington, KY 40508 Conlon Acke{, P.C. Raymond J. Attorney for -. ? ' C 3 _ 4"%? (,_., .....4 -s{- ,?"' ;=? -'ct .,: ? _% _-?? t1 ? ..?' _ f"+w) ?? Ilk IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff, VS. STEPHEN A. SKINNER, Defendant. No. 07-2838 Civil Term AFFIDAVIT OF SERVICE OF WRIT OF SUMMONS Filed on behalf of Plaintiff Counsel of record for this party: Raymond J. Conlon, Esquire PA I. D. # 49495 conlon@conlontarker.com Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 724.285.7700 724.285.6700 fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff, No. 07-2838 Civil Term VS. STEPHEN A. SKINNER, Defendant. AFFIDAVIT OF SERVICE OF WRIT OF SUMMONS TO: Curtis R. Long, Prothonotary I hereby certify that the Writ of Summons in Civil Action was served upon the Defendant Stephen A. Skinner on June 18, 2007, as evidenced by the certified mail return receipt attached hereto as Exhibit A. Sworn to and subscribed before me this 0jAND day of June 2007 '-?p 0 1.) a -t? - Notary Public COMMONWEAL, H OF PENNSYLVANIA Notarial Seal Michele A. Reno, Notary Public City Of Butler, Butler County My Commission Expires OcL 31, 2009 Member, Pennsylvania Association of Notaries Respectfully submitted, Conlon Tarker, P.C. Raymo ,. ¦ Complete Items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mallpiece, or on the front if space permits. 1. Article Addressed to: Stephen A. Skinner 4607 Connecticut Avenue NW Washington, DC 20008 A. Signat X ? Agent Addressee B. Received by (Printed Name) C. Date of Delivery 51. WNrjj„_ 6 o //w D. Is delivery address different from ftem 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type IN Certified Mail ? Express Mail ? Registered ? Return Receipt for MerchanIdise i ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number 7003 1680 0006 4350 6078 (Transfer from service labeQ PS Form 3811, February 2004 Domestic Retum Receipt 102595-02-M-1640 1 T. EXHIBIT A CERTIFICATE OF SERVICE I hereby certify that a copy of the within document was served upon the individual named below on the day of June, 2007 by first class, U.S. mail, postage prepaid. Marc A. Moyer, Esquire Thomas, Thomas Et Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 Attorney for Defendant Conlon Tarker, P.C. Raymoric. CO on,squire Attorn f Pl intiff fem... ?6 ? L % Thomas, Thomas & Hafer, LLP Todd B. Narvol, Esquire Attorney I.D. No. 42136 Marc A. Moyer, Esquire Attorney I.D. No. 76434 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7133 - direct tnarvol@tthlaw.com (717) 441-3960 - direct mmoyer@tthlaw.com (717) 237-7105 - fax Attorneys for Defendant Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant PRAECIPE FOR RULE TO FILE COMPLAINT THE PROTHONOTARY: Kindly issue a Rule upon Plaintiff, Ralph C. Crone, to file a Complaint within twenty (20) days or suffer Judgment of Non Pros. Respectfully submitted, Dated: June 25, 2007 Todd B/Natvol, Es 'ire Attorney I.D. No. 2136 Marc A. Moyer, squire Attorney No. 7 434 THOMAS, THOMAS & HAFER LLP 305 North Front Street, 6th Floor Post Office Box 999 Harrisburg, PA 17108 717-441-3960 mmoyer@tthlaw.com Counsel for Defendant Stephen A. Skinner CERTIFICATE OF SERVICE On this 25 h day of June 2007, I, Kristine Hendrix, a legal secretary, with the law firm Thomas, Thomas & Hafer, LLP, hereby certify that I have, this day, served a true and correct copy of the PRAECIPE FOR RULE TO FILE COMPLAINT upon the person(s) and at the address(es) below named via United States First Class Mail, postage prepaid, in Harrisburg, PA: Raymond J. Conlon, Esquire Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 Counsel for Plaintiff 512628.1 C N O 23 O (T?j?, am ? T? h , ..r T Thomas, Thomas & Hafer, LLP Todd B. Narvol, Esquire Attorney I.D. No. 42136 Marc A. Moyer, Esquire Attorney I.D. No. 76434 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7105 - fax Attorneys for Defendant Stephen A. Skinner (717) 237-7133 - direct tnarvol@tthlaw.com (717) 441-3960 - direct mmoyer@tthlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, V. Plaintiff Defendant NO. 07-2838 CIVIL TERM STEPHEN A. SKINNER, RULE TO FILE COMPLAINT AND NOW, this., day of , 2007, a Rule is entered upon Plaintiff to file a Complaint within twenty (20) days after service of this Rule by the Defendant. PRO ONOT :T -- P t° ? ? C> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH C. CRONE, CIVIL DIVISION - LAW Plaintiff, A.D. NO. 07-2838 Civil Term VS. COMPLAINT IN CIVIL ACTION STEPHEN A. SKINNER, Defendant. Filed on behalf of: Plaintiff Counsel of record for this party: Raymond J. Conlon, Esquire PA I.D. No. 49495 Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 (724) 285-7700 JURY TRIAL DEMANDED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH C. CRONE, CIVIL DIVISION - LAW Plaintiff, A.D. No. 07-2838 Civil Term VS. STEPHEN A. SKINNER, Defendant. 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 judgment for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Curtis R. Long, Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17103-3387 Conlon Tarker, P.C. 1 ? Raymond J. Con on, Esqu re Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH C. CRONE, CIVIL DIVISION - LAW Plaintiff, A.D. No. 07-2838 Civil Term VS. STEPHEN A. SKINNER, Defendant. COMPLAINT IN CIVIL ACTION AND NOW, comes the Plaintiff, Ralph C. Crone, by and through his attorneys, Conlon Tarker, P.C. and Raymond J. Conlon, Esquire, and files the following Complaint in Civil Action and in support thereof, avers as follows: 1. The Plaintiff, Ralph C. Crone is an adult individual who resides at 857 East Louther Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Stephen A. Skinner, is an adult individual who currently resides at 4607 Connecticut Avenue NW, Washington, D.C. 20008. 3. The events which gave rise to this lawsuit took place on July 5, 2005, on State Route 641, otherwise known as Trindle Road. 4. On July 5, 2005, the Plaintiff, Ralph C. Crone, was operating his 1998 Dodge Van in an easterly direction on Trindle Road. 5. On that same date, the Defendant, Stephen Skinner, was operating his 2005 Dodge Neon in a westerly direction on Trindle Road. 6. Suddenly and without warning, the Defendant, Stephen Skinner, negligently, recklessly, and carelessly crossed the center line of Trindle Road, directly into the path of the Plaintiff's vehicle, causing a head on collision to occur. 7. Ralph C. Crone avers the Defendant, Stephen Skinner, was negligent, reckless, and careless generally and in the following particulars: a. In operating a motor vehicle when he knew or should have known that he was improperly trained to do so; b. In failing to keep his vehicle under control and failing to brake, stop, slow down, or otherwise alter the speed, movement, and/or direction of the vehicle; C. In failing to keep his vehicle under proper control; d. In failing to keep his vehicle in his designated lane of travel; e. In operating his motor vehicle at an excessive rate of speed under the circumstances; f. In negligently colliding his vehicle into the Plaintiff's vehicle; g. In driving too fast for prevailing conditions; h. In crossing the center line; and i. In failing to operate his vehicle at a safe and reasonable speed under the circumstances then and there existing. 8. Solely and proximately as a result of the negligence, recklessness, and carelessness of the Defendant, Stephen Skinner, the Plaintiff, Ralph Crone, sustained the following injuries, some or all of which may be permanent in nature: a. A torn right ACL, resulting in both severe pain and a decreased range of motion; b. Injuries to his right shoulder; C. Subacromial impingement in his left shoulder; d. Pain and bruising of his left wrist; e. Lower back pain; f. Upper cervical pain; g. Bilateral neck pain; and h. Frequent headaches. 11. As a further direct and proximate result of the negligent, reckless, and careless conduct of the Defendant, Stephen Skinner, the Plaintiff, Ralph Crone, has incurred medical expenses and may continue to be caused to incur said expenses into the indefinite future. 12. As a further direct and proximate result of the negligent, reckless, and careless conduct of the Defendant, Stephen Skinner, the Plaintiff, Ralph Crone, has incurred pain, suffering, inconvenience and a loss of life's pleasures. 13. As a further direct and proximate result of the negligent, reckless, and careless conduct of the Defendant, Stephen Skinner, the Plaintiff, Ralph Crone, has sustained a loss of income and loss of earning capacity. 14. In addition, at the time of the subject accident, the Plaintiff, Ralph Crone, was in the process of remodeling a commercial building for use in his business enterprise. 15. As a direct and proximate result of the injuries and damages he sustained, the Plaintiff, Ralph C. Crone, was unable to complete the work on his own as planned and was forced to incur the following labor costs: a. Garman Plumbing $2,855.00 b. Alternative Construction Concepts $5,508.00 C. Sabolchick Electric $2,020.00 d. Essis Ft Son's Inc. $1,802.50 16. Supporting documentation for the above mentioned expenses are attached hereto as Exhibit A. 17. The Plaintiff avers that but for the injuries he sustained in the subject accident, he would have completed all of the above referenced work himself and, as a result, the Plaintiff is claiming these additional costs as a direct item of damages in this litigation. WHEREFORE, the Plaintiff, Ralph C. Crone, demands judgment against the Defendant, Stephen Skinner, in an amount in excess of $50,000.00, plus interest, costs, and attorneys fees and such other relief that this Court deems appropriate. Respectfully submitted, Conlon Tarker, P.C. Raymond I Co on, Esquire Attorney for Plaintiff 09 07 11,59a Jul. b. 2001 5:20PM Conlon Taker P.1 NO, 410a r 1, RALPH C. CRONE, have read the foregoing COMKAiNT IN CIVIL ACTION. The , statements therein are correct to the best of my personal knowledge, inforrtertion and belief. j This statement and verification are made subject to the penalties of 18 Pa.C.S.A. 34904 relating to unshorn falsification to authorities, which provides that if 1 make knowingly false averments, I may be subject4o criminal penalties. 71-710 7 TE MLW C: CRONE i J? } r CERTIFICATE OF SERVICE I hereby certify that a copy of the within document was served upon the individual named below on the Y3 day of July, 2007 by first class, U.S. mail, postage prepaid. Marc A. Moyer, Esquire Thomas, Thomas & Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 Attomey for Defendant Conlon Tarker, P.C. T dox-el' / (' /-.,- Raym d J. Co Ion, Esquire Attorney for Pla ntiff /-.? l N t: _? r` ca --n ?..a ..?, i?=- ,?_ ---1 _ ?_._ <R,?.? . -, ? ???;- _.. ?,-o , ?: i??s. _ ,: .. ?. ??,, y? r-- - w :X7 ?: ?, --?: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff, No. 07-2838 Civil Term VS. EXHIBIT A TO PLAINTIFF'S COMPLAINT STEPHEN A. SKINNER, Filed on behalf of Plaintiff Defendant. Counsel of record for this party: Raymond J. Conlon, Esquire PA I. D. # 49495 conlon@conlontarker.com Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 724.285.7700 724.285.6700 fax EXHIBIT Q 1.5-35 Noinf2 Frlarket :9 ?trt' it ;a 1 22-11 -6 7A4'2 BILL -M A-S =R L@ "S 3 E" ? A, I 1g" 3 DATE-- JOB DcS0 PP€"!OM t } E STED i'MAJOIC E 1,10. z t -yi E'Ei C 7 rTP..fy.E .. P Z 3Ri.SCRIPTIi_; Hf L:? i; 1` ATE ai t t xt 1b 1.4 F 11*1 C -1-11 2 P.? 1i f '? ? ? ? +a ? s * 7 ) / l ) 3" PV .3,60 n 1. Li "i L J d? \ ih 3 l? - l+3 A?a 1 V Y.-7,. 2S N't 1 q g } , {' J" PVC 4.?.?E."*t..? kNiL ?j 1 A 2 09 ( ),1t?t? x'1 . 2q1 90 &'6`E M 2" PVC 45 5 1.1.41 5 N"I 2' PVC ST 45 1 N't 12" PVC COT "PLINNG i.46 ;E ?tE? P?aPs 13" 3 3, 27 a'i 1 i' ?. 3 i j { I y.y "I i o qv-" - 1-12 PVC T J 3 ? 1.644 4.9'-2 To T>17(7 r i - + ? i k t :; 1? r.i . - 7 , ?r' . 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ST1_!_ TO C`i Lt?-K LRCM 3577 F kST LOUT' ::, ST P.,.'?I3 r: l -E Nvz lUE No. Y _ t: 25/2006 4 1.;:';,1 i 4 NEW I TNi t;T01,J ' TU Otl J.C _ :Pt E art i< a w Dl_,?7;CRIP 9Oki QTY RATE 1 ?lli,10L*,JT m 1 1 d Ci+Rt M-11 GsLDRUN l 15.86 i 15w.80 C FRL =R ff N-DIC AP SINK 1 ? 10.00 210.00 Ind `, It ,t, T C IH A TF: LT P8933 B.3.'IM F AJ K`3T 1 5.00 3 - ? pry 'z r1i??C1O??-?IQ?? 8.25 i 11 C'1 R0NNSE UV,,'E Vt' LVE, 0i -WX gz Sl fu CON1? t .p i l., 2' PEX LAY' VA1 9? ,, [ 8 1.1.351 910.80 All 3/8" X 20 CHROME, LAV SUPPLY 5 3.85 19.'25 1 It[ } 3i$" ti 1 CHROME TOILET SL.?PPPLY 5 ? 2.85 14.25 M i 1/2" X 4 CHROP.,E NIPPLES 5 1 3.25 10.25 ! M WA- RINGS i :? 2.50 50 12 Ri 3 TOILET BOWL BOLTS ? f } ' k 1 5 ?s 3 . q R 75 ?i ULTRA TvIuETMURTI", `bn? r ' ?aa t @¢i f _.. i-N BEY 7IS 5117 SENT i 4 ^rt :} r r . N ?Zl f * U-1 , i o;U m ULTRA - F;ADfCAP TOILET ,,PES ..,..9f-'i m t R BEMIS 1500 TOILET SEAT' ?°° ° 1 I It3.8CE g L 45. s R?I i DELTA 13 i ? ? ` ? 20.0; 1:,u xi l d DEI,T,? N253024 LA.V VALVE 1 1 It!.0tt ' 13r10?1 #141 i 8" 1 16 POLY I_ "V' SUPPLY 5.85 ;t t T1,:: (1 .r j p:x (r?ILp Rr4T{': t 1 ;j r' 3 i` ; lttl i 1/2 " PUY BALL' AL Y it } ry,Jv i 3 :fE) I?:1 i P EX, 30 F 31: 1.,. r'rx INSERT ADAPTOR m i 14' l 1 2" Pl-N FWALE's ADAPTOR 1 y 1.63 1 ,3 L LABOR - 1/24/06, 1 MAN/ 7 HOLRS .; ; tiri.il(1 L LA1?OI? - 1/25/06, 1 MAN/ 7 HOURS L § LABOR - V27/06. 1 MAN/ 3 HOURS } f E t ALL MAJOR. CREDIT CA_'<.DS AC. .'371. Alternative Construction Concepts John W. Alt, Sole Proprietor 76 Edison Road Palmyra, PA 17078-8518 BILL TO Chuck Crone 857 East Louther Street Carlisle, PA 17013 J I PpsT6O 9 Invoice DATE INVOICE # 12/28/2005 294 P.O. NO. 442 DESCRIPTION AMOUNT Labor from 12/7/05 to 12/23/05 (92.5 hours @ $27/hour = $2,497.50) 2,497.50 Labor from 12/7/05 to 12/23/05 (49.5 hours @ $15/hour = $742.50) 742.50 Home Depot 30.62 RE: 7574 CARLISLE PIKE, MECHANICSBURG, PA 17050 Total $3,270.6 Altefnathw Construction Concepts John W. Alt, Sole Proprietor 76 Edison Road Palmyra, PA 17478-8518 BILL TO Chuck Crone 857 East Louther Street Carlisle, PA 17013 Invoice DATE INVOICE # 1/13/2006 297 P.O. NO. 442 DESCRIPTION AMOUNT Labor from 12/24/05 to 118/06 (30 hours Q $27/hour = $810) 810.00 Labor from 12/24/05 to 1/8/06 (30 hours a $I5/hour = $450) 450.00 Lowe's 20.19 RE: 7574 CARLISLE PIKE, MECHANICSBURG, PA 17050 S J 1 Total $1,280.19 ALTERNATIVE CONSTRUCTION CONCEPTS JOHN W. ALT, Sole Proprietor 76 Edison Road Palmyra, PA 17078-8518 (717) 832-2002 Fax: (717) 832-0262 E-mail. alteonstruction@comcast.net Bill To_ 1/23/2006 Chuck Crone 857 East Louther Street Carlisle, PA 17013 Description: Labor from 1/9/06 to 1/20/06 Bryan 24 hours @ $27/hour = $648.00 Labor From 1/9/06 to 1/20/06 Jess 24 hours @ $15/hour = $360.00 B? -7dq 12E:...7 , Z E, YT1,j, N 57-AAE--,?e T AIC tA) t Cs X7071 Total: $1008.00 Sa o'Ichick Electric yq-3 Z®Z g Invoice 122 East Lefler Street Mechanicsburg, PA 17055 717-796-7040 Bill To Crone's Tae Kwon Do School Chuck Crone 24 East Main Street New Kingstown, PA 17072 Date Invoice # 1/16/2006 737 POSTED Due Date Project 1/31/2006 Quantity Description Rate Am 1 Quote 2,020.00 2,020.00 Relocate switches for lights in two rooms. Rewire 18 lights in those rooms with MC cable. Install 4 exit signs and 5 emergency battery packs. Install feed to new water heater. Install bath fan. Install receptacles once drywall is complete. , Original quote: $2200 .3 Credit for deletion of 5 smoke detectors: $300 Addition of 1 exit sign and 1 battery pack: $120 f; It's been a pleasure working with you! Total $2,020.00 13 07 09;42a ESSIS & SON'S INC 6220 CARLISE PIKE 717-697-9423 FAX 717-697-7797 Date: February 2 2006 Estimator Joseph Essis TO: Crones Carlisle Pike New Kingstown PA We are pleased to submit the following sales agrement Job Description: MATERIALS 8 LABOR QUANTITY DESCRIPTION Umrr PRICE TOTAL 5000.00 eet Zebra Matting 3.61 18,050.00 • 5000.00 abor matting material 1.50 7.500.00 700.00 eet 1/8 commercial cove base 0.90 630.00 700.00 eet Labor base 0.50 350.00 415.00 eet 8x8 Sorno Be' ceramic file 2.50 1.037.50 415.00 'e et ceramic labor wall and floor 3.50 1,452.50 4.00 inset 18.50 74.00 4.00 archement sanded rout 18.00 72.00 9.00 Sheulter metal 15.00 135.00 2.00 aulki parchment 9.50 19.00 143.00 ds Lodestar Marble Grey 19.00 2,717.00 167.00 ds carpet labor 4.50 751.50 24.00 ds Natural Selections Rosewood kitchen 15.00 360.00 Total Bid Price 33,148.50 P.1 -00ST FO Price vaNd until. 30 days from estimate dat, CERTIFICATE OF SERVICE I hereby certify that a copy of the within document was served upon the individual named below on the ck 3`6 day of July, 2007 by first class, U.S. mail, postage prepaid. Marc A. Moyer, Esquire Thomas, Thomas Et Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 Attorney for Defendant Conlon T rker, P.C. I Raymon J. C n, Esquire Attorney lai tiff t > ?' ?'? .. t ... ?- r ?._ _) _ ???? ... ?, ?. i - "^1 .i ??':. ? VERIFICATION I, RALPH C. CRONE, have read the foregoing COMPLAINT IN CIVIL ACTION. The statements therein are correct to the best of my personal knowledge, information and belief. This statement and verification are made subject to the penalties of 18 Pa.C.S.A. 54904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. D &E RALPH C. CRONE i? t.J, 5 - ? -i x,I Thomas, Thomas & Hafer, LLP Todd B. Narvol, Esquire Attorney I.D. No. 42136 Marc A. Moyer, Esquire Attorney I.D. No. 76434 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7133 - direct tnarvol@tthlaw.com (717) 441-3960 - direct mmoyer@tthlaw.com (717) 237-7105 - fax Attorneys for Defendant, Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant NOTICE TO PLEAD TO: RALPH C. CRONE, PLAINTIFF c/o RAYMOND J. CONLON, ESQUIRE CONLON TARKER, P.C. 108 EAST DIAMOND STREET BUTLER, PA 16001 YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS OF SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. THOMAS, THOMAS & HAFER, LLP By: Tefdd B. Narvo squire Attorney I.D o. 42136 Marc A. er, Esquire Attorney I.D. No. 76434 305 North Front Street, 6th Floor P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 Date: August 7, 2007 Attorneys for Defendant Stephen A. Skinner Thomas, Thomas & Hafer, LLP Todd B. Narvol, Esquire Attorney I.D. No. 42136 Marc A. Moyer, Esquire Attorney I.D. No. 76434 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7133 - direct tnarvol@tthlaw.com (717) 441-3960 - direct mmoyer@tthlaw.com (717) 237-7105 - fax Attorneys for Defendant, Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant ANSWER AND NEW MATTER OF DEFENDANT, STEPHEN A. SKINNER, TO PLAINTIFF'S COMPLAINT Defendant, Stephen A. Skinner, by and through his counsel, Thomas, Thomas & Hafer, LLP, respectfully submits his Answer with New Matter to Plaintiff's Complaint as follows: 1. After reasonable investigation, Defendant, Stephen A. Skinner, is without sufficient knowledge or information to form a belief as to the truth of the averments set forth in Paragraph 1 of Plaintiffs Complaint. The averments are, therefore, DENIED, and proof thereof is demanded at time of trial. 2. ADMITTED. 3. DENIED as stated. It is ADMITTED that Plaintiff s Complaint is based upon an automobile accident that occurred between Plaintiff Ralph C. Crone and Defendant, Stephen A. Skinner, on July 5, 2005. 4. ADMITTED based upon information and belief. 5. ADMITTED. 6. The averments set forth in Paragraph 6 of Plaintiff's Complaint are conclusions of law to which no response is required. To the extent the averments are deemed to be factual in nature, it is DENIED that Defendant, Stephen A. Skinner, caused a head on collision to occur between his motor vehicle and Plaintiff's motor vehicle by negligently, recklessly, or carelessly crossing the center line of Trindle Road and driving into the path of Plaintiff s vehicle. 7. The averments set forth in Paragraph 7 of Plaintiffs Complaint are conclusions of law to which no response is required. To the extent the averments are deemed to be factual in nature, it is DENIED that Defendant, Stephen A. Skinner, was negligent, reckless or careless generally, or in the following particulars: a. It is DENIED that Defendant, Stephen A. Skinner, was negligent, reckless, or careless or that he operated a motor vehicle when he knew or should have known that he was improperly trained to do so. By way of further Answer, it is DENIED that Defendant, Stephen A. Skinner, was improperly trained to operate his motor vehicle at all times material to Plaintiff s Complaint. b. It is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly failed to keep his vehicle under control, or negligently, recklessly, or carelessly failed to brake, stop, slow down, or otherwise alter the speed, movement, and/or direction of his motor vehicle; c. It is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly failed to keep his vehicle under proper control at all times material to Plaintiff's Complaint; 2 d. It is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly, failed to keep his vehicle in his designated lane of travel at any time material to Plaintiff's Complaint; e. It is DENIED that Defendant, Stephen A. Skinner, was negligent, reckless, or careless or that he operated his motor vehicle at an excessive rate of speed under the circumstances at any time material to Plaintiff's Complaint; f. It is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly collided his vehicle into Plaintiff's vehicle; g. It is DENIED that Defendant, Stephen A. Skinner, was negligent, reckless, or careless or that he drove his vehicle too fast for prevailing conditions at any time material to Plaintiff's Complaint; h. It is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly or carelessly crossed the center line; and i. It is DENIED that Defendant, Stephen A. Skinner, was negligent, reckless, or careless or that he failed to operate his vehicle at a safe and reasonable speed under the circumstances then and there existing at the time of the accident referred to in Plaintiff's Complaint. 8. The averments set forth in Paragraph 8 of Plaintiff's Complaint are conclusions of law to which no response is required. To the extent the averments are deemed to be factual in nature, it is DENIED that Defendant, Stephen A. Skinner, was negligent, reckless or careless or that he caused or contributed to Plaintiff, Ralph C. Crone, sustaining any injuries, some or all of which are of a permanent nature. It is further DENIED that Plaintiff suffered the injuries or 3 damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial. By way of further answer: a. It is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly caused or contributed to Plaintiff experiencing a torn right ACL, severe pain or decreased range of motion. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial; b. It is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly caused or contributed to Plaintiff experiencing injuries to his right shoulder. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial; c. It is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly caused or contributed to Plaintiff experiencing subacromial impingement in his left shoulder. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial; d. It is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly caused or contributed to Plaintiff experiencing pain and bruising of his left wrist. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial; 4 e. It is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly caused or contributed to Plaintiff experiencing lower back pain. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial; f. It is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly caused or contributed to Plaintiff experiencing upper cervical pain. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial; g. It is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly caused or contributed to Plaintiff experiencing bilateral neck pain. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial; and h. It is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly caused or contributed to Plaintiff experiencing frequent headaches. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial. 11. The averments set forth in Paragraph 11 of Plaintiff's Complaint are conclusions of law to which no response is required. To the extent the averments are deemed to be factual in nature, it is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly 5 caused or contributed to Plaintiff incurring medical expenses in the past or into the indefinite future. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial. 12. The averments set forth in Paragraph 12 of Plaintiff's Complaint are conclusions of law to which no response is required. To the extent the averments are deemed to be factual in nature, it is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly, or carelessly caused or contributed to Plaintiff experiencing pain, suffering, inconvenience or loss of life's pleasures. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial. 13. The averments set forth in Paragraph 13 of Plaintiff's Complaint are conclusions of law to which no response is required. To the extent the averments are deemed to be factual in nature, it is DENIED that Defendant, Stephen A. Skinner, negligently, recklessly or carelessly caused or contributed to Plaintiff sustaining a loss of income or loss of earning capacity. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial. 14. After reasonable investigation, Defendant, Stephen A. Skinner, lacks sufficient knowledge or information to form a belief as to the truthfulness of the averments set forth in Paragraph 14 of Plaintiff's Complaint. The averments are, therefore, DENIED and proof thereof is demanded at time of trial. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial. 6 15. The averments set forth in Paragraph 15 of Plaintiff's Complaint are conclusions of law to which no response is required. To the extent the averments are deemed to be factual in nature, it is DENIED that Defendant, Stephen A. Skinner, caused or contributed to Plaintiff experiencing any injuries or damages, or that he caused or contributed to Plaintiff incurring labor costs, including injuries and damages allegedly resulting from Plaintiff's inability to complete construction work on his own behalf. By way of further Answer, it is DENIED that Defendant, Stephen A. Skinner, caused or contributed to Plaintiff incurring labor costs from Garmin Plumbing, labor costs from Alternative Construction Concepts, labor costs from Sabolchick Electric, or labor costs from Essis & Son's, Inc. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial. 16. DENIED. It is DENIED supporting documentation for the expenses identified in Paragraph 15 of Plaintiff s Complaint were originally attached to Plaintiff's Complaint upon service thereof. It is further DENIED that Plaintiff suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial. 17. The averments set forth in Paragraph 17 of Plaintiff s Complaint are conclusions of law to which no response is required. To the extent the averments are deemed to be factual in nature, and after reasonable investigation, Defendant, Stephen A. Skinner, lacks sufficient knowledge or information to form a belief as to what work identified in Paragraph 15 of the Complaint, if any, Plaintiff would have performed himself. The averments are, therefore, DENIED and proof thereof is demanded at time of trial. It is further DENIED that Plaintiff 7 suffered the injuries or damages alleged and proof thereof, as well as the proof as to the causation of such injuries and/or damages is demanded at time of trial. WHEREFORE, Defendant, Stephen A. Skinner, requests that this Honorable Court enter judgment in his favor and against Plaintiff, Ralph C. Crone, and that Plaintiff's Complaint be dismissed with prejudice. NEW MATTER 18. Defendant Stephen A. Skinner hereby incorporates his Answers to Paragraphs 1 through 17 of Plaintiff's Complaint by reference as if fully set forth at length herein. 19. Plaintiff's Complaint fails to state a cause of action upon which relief can be granted under Pennsylvania law. 20. Plaintiff's claims are barred and/or limited by the Pennsylvania Comparative Negligence Act. 21. Plaintiffs claims are barred by assumption of the risk. 22. The negligence of Plaintiff Richard C. Crone was the sole and proximate cause of Plaintiff's injuries. 23. The claimed injuries and/or damages of Plaintiff, the existence of which are DENIED, were caused in whole or in part by acts or omissions of another or others for whom Defendant Stephen A. Skinner was not responsible and whose conduct he had no reason to anticipate. 24. Defendant Stephen A. Skinner is not responsible for the actions of any other parties whose conduct may have caused the injuries complained of in Plaintiff's Complaint. 8 25. The alleged actions and omissions of Defendant Stephen A. Skinner were not a substantial factor, or were an insignificant factor, or were not a legal factor in causing or contributing to Plaintiffs alleged injuries and damages, if any. 26. Plaintiff's alleged injuries and damages, if any, were not caused or aggravated by the acts or omissions of Defendant Stephen A. Skinner, but rather were pre-existing, or caused by something other than the collision on or about July 5, 2005. 27. As discovery may show, Plaintiff s recovery may be barred or limited by the affirmative defenses of statutes of limitations, waiver, release, immunity, settlement, accord and satisfaction, immunity, arbitration and award, contributory negligence, collateral estoppel and/or equitable estoppel. 28. Recovery for Plaintiff's alleged injuries and damages, if any, are barred or limited by the provisions of the Pennsylvania Motor Vehicle Financial responsibility Law, 75 Pa. C.S. § 1701, et. seq. 29. Plaintiff, if he suffered any injuries at all, did not suffer any permanent loss of a bodily function, permanent disfigurement nor permanent dismemberment. 30. Plaintiff Richard C. Crone was negligent per se. 31. Future discovery may show that Plaintiff may have failed to mitigate his damages. 32. Future discovery may show that the negligent acts or omissions of others may have constituted intervening, superseding causes of the damages and/or injuries alleged to have been sustained by the Plaintiff. 9 WHEREFORE, Defendant Stephan A. Skinner respectfully requests that judgment be entered in his favor and against Plaintiff Richard C. Crone together with such other relief as the Court may deem just and equitable. Respectfully submitted, TVdd 9.'?farv J Esquire Attorney I. No. 42136 Marc A. Oyer, Esquire Attorney I.D. No. 76434 THOMAS, THOMAS & HAFER LLP 305 North Front Street, 6th Floor Post Office Box 999 Harrisburg, PA 17108 717-441-3960 mmoyer@tthlaw.com Dated: August 7, 2007 517264.1 Counsel for Defendant 10 VERIFICATION I, Stephen A. Skinner, state that I have read the foregoing ANSWER AND NEW MATTER OF DEFENDANT STEPHEN A. SKINNER TO PLAINTIFF'S COMPLAINT which has been drafted with the assistance of counsel. The factual statements contained therein are true and correct to the best of my information, knowledge, and belief, although the language is that of counsel and, to the extent that the content of the foregoing document is that of counsel, I have relied upon counsel in making this Verification. This statement is made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false statements, I may be subject to criminal penalties. `7 / Dad Stephen A. Skinner CERTIFICATE OF SERVICE On this 7t' day of August 2007, I, Kristine Hendrix, a legal secretary, with the law firm Thomas, Thomas & Hafer, LLP, hereby certify that I have, this day, served a true and correct copy of the ANSWER AND NEW MATTER OF DEFENDANT STEPHEN A. SKINNER TO PLAINTIFF'S COMPLAINT upon the person(s) and at the address(es) below named via United States First Class Mail, postage prepaid, in Harrisburg, PA: Raymond J. Conlon, Esquire Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 Counsel for Plaintiff Krist? e Hendrix Pi c- FTz z; z CIO a? r tom'' ;,? Frl Thomas, Thomas & Hafer, LLP Todd B. Narvol, Esquire Attorney I.D. No. 42136 Marc A. Moyer, Esquire Attorney I.D. No. 76434 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7133 - direct mmol@tthlaw.com (717) 441-3960 - direct tnmoyer@tthlaw.corn (717) 237-7105 - fax Attorneys for Defendant, Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff V. STEPHEN A. SKINNER, Defendant NO. 07-2838 CIVIL TERM CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve a Subpoenas with copies of the subpoenas attached thereto was mailed or delivered to each party on or about August 21, 2007; 2. A true and correct copy of the Notice of Intent, including a copy of the proposed subpoenas, is attached to this Certificate. 3. The twenty day objection period has been waived by Attorney Conlon pursuant to his email dated August 26, 2007; 4. The subpoenas which will be served are identical to the subpoenas which are attached to this Certificate. THOMAS & HAFER, LLP Date: NX 01 MAFC,-A' R, ESQUIRE ATTORNE # 76434 305 NORTH RONT STREET - 6TH FLOOR HARRISBURG, PA 17108 (717) 237-7133 ATTORNEY FOR DEFENDANT Thomas, Thomas & Hafer, LLP Todd B. Narvol, Esquire Attorney I.D. No. 42136 Marc A. Moyer, Esquire Attorney I.D. No. 76434 305 N. Front Street P.O. Box 999 Harrisburg, PA 17105-0999 (717) 237-7105 - fax Attorneys for Defendant Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff V. STEPHEN A. SKINNER, Defendant NO. 07-2838 CIVIL TERM NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant intends to serve subpoenas identical to the ones that are 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 subpoenas will be served. THOMAS, THOMAS & HAFER, LLP Date: ?' ) a 16-7 (717) 237-7133 - direct tnarvol cdi tthlaw.com (717) 441-3960 - direct mmoyer@ttillam,.com Marc'A! Moyer Attorney I.D.- 305 North Won P. O. Box 999 Harrisburg, PA (717) 441-706C Esquire 76434 t Street 17108-0999 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff V. STEPHEN A. SKINNER, Defendant NO. 07-2838 CIVIL TERM SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Mechanicsburg Family Practice, 122 South Filbert Street, Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C. Crone, DOB: 12/13/1958, SS# 202-52-6366, including but not limited to any and all medical records in patient and out patient testing, diagnostic studies, etc. at: Thomas, Thomas & Hafer, LLP. 305-N. Front St., P.O. Box 999, Harrisburg, PA 17108 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff V. STEPHEN A. SKINNER, Defendant NO. 07-2838 CIVIL TERM SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Orthopedic Institute of PA, 450 Powers Avenue, Harrisburg, PA 17101 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C. Crone. DOB: 12/13/1958, SS# 202-52-6366. including but not limited to any and all medical records, in patient and out patient testing, diagnostic studies, etc. at: Thomas, Thomas & Hafer, LLP, 305 N. Front St.. P.O. Box 999. Harrisburg, PA 17108 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Penn's Woods Physical Therapy, 419 Stonehege Drive, Suite 3, Carlisle, PA 17013 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C. Crone, DOB: 12/13/1958, SS#_202-52-6366 , including, but not limited to any and all medical records. in patient and out patient testing, diagnostic studies, etc. at: Thomas, Thomas & Hafer, LLP 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108 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 parry 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff V. STEPHEN A. SKINNER, Defendant NO. 07-2838 CIVIL TERM SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Holy Spirit Hospital, Attn: Medical Records, 503 N. 21St Street, Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C. Crone, DOB: 12/13/1958, SS# 202-52-6366 including but not limited to any and all medical records in patient and out patient testing, diagnostic studies. etc. at: Thomas, Thomas & Hafer, LLP 305 N. Front St.. P.O. Box 999, Harrisburg. PA 17108 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff V. STEPHEN A. SKINNER, Defendant : NO. 07-2838 CIVIL TERM SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Casses Chiropractic Clinic, P.C., 313 South Hanover Street, Carlisle, PA 17013 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C. Crone, DOB: 12/13/1958, SS# 202-52-6366 including but not limited to any and all medical records in patient and out patient testing diagnostic studies. etc. at: Thomas, Thomas & Hafer, LLP 305 N. Front St. P.O. Box 999, Harrisburg, PA 17108 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Hospital, Attn: Medical Records, 246 Parker Street, Carlisle, PA 17013 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C Crone, DOB: 12/13/1958, SS# 202-52-6366 including but not limited to any and all medical records in patient and out patient testing, diagnostic studies, etc. at: Thomas. Thomas & Hafer, LLP 305 N. Front St. P.O. Box 999, Harrisburg. PA 17108 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff v. STEPHEN A. SKINNER, Defendant NO. 07-2838 CIVIL TERM SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Cumberland Goodwill Fire Rescue and EMS, EMS Division, 102 West Ridge Street, Carlisle, PA 17103 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete cry of the medical file regarding Ralph C. Crone, DOB: 12/13/1958, SS# 202-52-6366 including, but not limited to any and all medical records inpatient and outpatient testing diagnostic studies etc. at: Thomas. Thomas & Hafer, LLP 305 N Front St. P.O. Box 999, Harrisburg, PA 17108 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff V. NO. 07-2838 CIVIL TERM STEPHEN A. SKINNER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: State Auto Insurance, P.O. Box 2006, Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the file regarding Ralph C. Crone, DOB: 12/13/1958, SS# 202-52-6366. policy no. APA2171497, claim no. CRON 2171497 including but not limited to any and all medical records, determinations, findings, recorded statements photogrVhs IME reports claim notes. wage and benefit information, correspondence. etc. at: Thomas. Thomas & Hafer LLP 305 N. Front St., P.O. Box 999, Harrisburg. PA 17108 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff V. STEPHEN A. SKINNER, Defendant NO. 07-2838 CIVIL TERM SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Harrisburg Hospital, Attn: Medical Records, 111 South Front Street, Harrisburg, PA 17101 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C. Crone, DOB: 12/13/1958, SS# 202-52-6366 including but not limited to any and all medical records in patient and out patient testing. diagnostic studies, etc. at: Thomas, Thomas & Hafer, LLP 305 N. Front St. P.O. Box 999. Harrisburg, PA 17108 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I do hereby certify that on this day I served a true and correct copy of the foregoing document by first class mail, postage prepaid, addressed to the following: Raymond J. Conlon, Esquire Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 Counsel for Plaintiff Thomas, Thomas & Hafer, LLP by Beth DePhillips, Paralegal Date: CERTIFICATE OF SERVICE I do hereby certify that on this day I served a true and correct copy of the foregoing document by first class mail, postage prepaid, addressed to the following: Raymond J. Conlon, Esquire Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 Counsel for Plaintiff Thomas, Thomas & Hafer, LLP Beth E. DePhi ips, Paralegal Date: q 1Y1V 0 vs C,o C) Thomas, Thomas & Hafer, LLP Todd B. Narvol, Esquire Attorney I.D. No. 42136 Marc A. Moyer, Esquire Attorney I.D. No. 76434 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7133 - direct tnarvol@tthlaw.com (717) 441-3960 - direct mmoyer@tthlaw.com (717) 237-7105 - fax Attorneys for Defendant Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, V. STEPHEN A. SKINNER, Plaintiff NO. 07-2838 CIVIL TERM Defendant MOTION OF DEFENDANT STEPHEN A. SKINNER TO COMPEL PLAINTIFF'S RESPONSES TO DISCOVERY AND NOW, comes Defendant Stephen A. Skinner, by and through his counsel, Thomas, Thomas & Hafer, LLP, and files this Motion to Compel Plaintiff's Response to Discovery as follows: 1. This action was initiated by Plaintiff Ralph C. Crone on May 10, 2007 through the filing of a Writ of Summons. 2. Plaintiff, thereafter, filed his Complaint on July 13, 2007 pursuant to the Court's Rule to File a Complaint. A copy of Plaintiff's Complaint is attached hereto as Exhibit "A". 3. Plaintiff's Complaint alleges, inter alia, that Plaintiff experienced personal injuries as the result an automobile accident with Defendant Stephen A. Skinner on July 5, 2005. See, Complaint, IT 3, 6, 8. 4. Plaintiff's Complaint further alleges that as a result of the injuries and damages he sustained from the accident, Plaintiff was unable to complete the process of remodeling a commercial building for use in his business enterprise. See, Complaint, TT 14-15. 5. Upon information and belief, the "business enterprise" to which Plaintiff refers is Crone's Tae Kwon Do School located at 24 East Main Street, New Kingston, PA 17072. See, Exhibit "B". 6. Upon information and belief, Plaintiff is currently the Head Master of Crone's Tae Kwon Do School and is actively engaged in Tae Kwon Do and other martial arts instruction. 7. On July 6, 2007, Defendant Stephen A. Skinner served Plaintiff with Interrogatories (Set I) and a Request for Production of Documents. Defendant, thereafter, served Plaintiff with a Second Set of Interrogatories on July 19, 2007. A copy of Defendant's Interrogatories are attached hereto as Exhibit "C" and a copy of Defendant's Second Set of Interrogatories are attached hereto as Exhibit "D". Also attached is a copy of Defendant's Request for Production of Documents as Exhibit "E". 8. To date, Plaintiff has not answered any of Defendant's Interrogatories. 9. Instead, by letter dated January 31, 2008, forty (40) days prior to the filing of this Motion, Plaintiff's counsel represented that Plaintiff's Answers to Interrogatories were merely awaiting Verification by the Plaintiff. See, Exhibit "F". 10. On January 18, 2008, and January 31, 2008, Plaintiff served Defendant with partial responses to his Request for Production of Documents. Notably however, Plaintiff has not yet served Defendant with documents responsive to Request Nos. 12, 13, 20, 21, 22, 23, 24 and 27. 11. Notably, each of the foregoing document requests directly pertain to Plaintiffs "business enterprise" and physical ability to conduct martial arts training. 2 12. On February 8, 2008, the undersigned counsel wrote to Plaintiff's counsel for the purpose of requesting that the aforementioned documents be produced no later than March 7, 2008, eight months following service thereof. 13. Despite undersigned counsel's request, Plaintiff has yet to serve Defendant with documents responsive to those Requests. 14. As a result of Plaintiffs refusal to provide Defendant with responses to his discovery requests, Mr. Skinner continues to be prejudiced in his ability to defend himself in this matter. WHEREFORE, Stephen A. Skinner respectfully requests that this Honorable Court compel Plaintiff to fully and completely respond to his Interrogatories and to produce documents responsive to Request Nos. 12, 13, 20, 21, 22, 23, 24 and 27, without objection, within twenty (20) days. Respectfully submitted, AVA Todd B. N ol, Esquire Attorney . No. 42136 Marc A. oyer, Esquire Attorney No. 76434 THOMAS, THOMAS & HAFER LLP 305 North Front Street, 6th Floor Post Office Box 999 Harrisburg, PA 17108 717-441-3960 mmoyer@tthlaw.com Dated: March 10 , 2008 576078.1 Counsel for Defendant Stephen A. Skinner 3 CERTIFICATE OF SERVICE On this ( I day of March, 2008, I, Jennifer L. Deitch, a legal secretary, with the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I have, this day, served a true and correct copy of the MOTION TO DEFENDANT STEPHEN A. SKINNER TO COMPEL PLAINTIFF'S RESPONSES TO DISCOVERY upon the person(s) and at the address(es) below named via United States First Class Mail, postage prepaid, in Harrisburg, PA: Raymond J. Conlon, Esquire Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 Jenni r L. Deitc 4 Mad coos i?031?A?3b 63IH36 00006 QcCow*G? jj6 1 b,1c ?? COPY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH C. CRONE, CIVIL DIVISION - LAW Plaintiff, A.D. NO. 07-2838 Civil Term VS. STEPHEN A. SKINNER, COMPLAINT IN CIVIL ACTION Defendant. Filed on behalf of: Plaintiff Counsel of record for this party: Raymond J. Conlon, Esquire PA I.D. No. 49495 Conlon Tarker, P.C. 108 East Diamond Street Butter, PA 16001 (724) 285-7700 JURY TRIAL DEMANDED IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH C. CRONE, CIVIL DIVISION - LAW Plaintiff, A.D. No. 07-2838 Civil Term VS. STEPHEN A. SKINNER, Defendant. 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 judgment for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Curtis R. Long, Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17103-3387 Conlon Tarker, P.C. Raymond J. Con on, Esq Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH C. CRONE, CIVIL DIVISION - LAW Plaintiff, A.D. No. 07-2838 Civil Term VS. STEPHEN A. SKINNER, Defendant. COMPLAINT IN CIVIL ACTION AND NOW, comes the Plaintiff, Ralph C. Crone, by and through his attorneys, Conlon Tarker, P.C. and Raymond J. Conlon, Esquire, and files the following Complaint in Civil Action and in support thereof, avers as follows: 1. The Plaintiff, Ralph C. Crone is an adult individual who resides at 857 East Louther Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Stephen A. Skinner, is an adult individual who currently resides at 4607 Connecticut Avenue NW, Washington, D.C. 20008. 3. The events which gave rise to this lawsuit took place on July 5, 2005, on State Route 641, otherwise known as Trindle Road. 4. On July 5, 2005, the Plaintiff, Ralph C. Crone, was operating his 1998 Dodge Van in an easterly direction on Trindle Road. 5. On that same date, the Defendant, Stephen Skinner, was operating his 2005 Dodge Neon in a westerly direction on Trindle Road. 6. Suddenly and without warning, the Defendant, Stephen Skinner, negligently, recklessly, and carelessly crossed the center line of Trindle Road, directly into the path of the Plaintiff's vehicle, causing a head on collision to occur. 7. Ralph C. Crone avers the Defendant, Stephen Skinner, was negligent, reckless, and careless generally and in the following particulars: a. In operating a motor vehicle when he knew or should have known that he was improperly trained to do so; b. In failing to keep his vehicle under control and failing to brake, stop, slow down, or otherwise alter the speed, movement, and/or direction of the vehicle; C. In failing to keep his vehicle under proper control; d. In failing to keep his vehicle in his designated lane of travel; e. In operating his motor vehicle at an excessive rate of speed under the circumstances; f. In negligently colliding his vehicle into the Plaintiff's vehicle; g. In driving too fast for prevailing conditions; h. In crossing the center line; and i. In failing to operate his vehicle at a safe and reasonable speed under the circumstances then and there existing. 8. Solely and proximately as a result of the negligence, recklessness, and carelessness of the Defendant, Stephen Skinner, the Plaintiff, Ralph Crone, sustained the following injuries, some or all of which may be permanent in nature: a. A torn right ACL, resulting in both severe pain and a decreased range of motion; b. Injuries to his right shoulder; C. Subacromial impingement in his left shoulder; d. Pain and bruising of his left wrist; e. Lower back pain; f. Upper cervical pain; g. Bilateral neck pain; and h. Frequent headaches. 11. As a further direct and proximate result of the negligent, reckless, and careless conduct of the Defendant, Stephen Skinner, the Plaintiff, Ralph Crone, has incurred medical expenses and may continue to be caused to incur said expenses into the indefinite future. 12. As a further direct and proximate result of the negligent, reckless, and careless conduct of the Defendant, Stephen Skinner, the Plaintiff, Ralph Crone, has incurred pain, suffering, inconvenience and a loss of life's pleasures. 13. As a further direct and proximate result of the negligent, reckless, and careless conduct of the Defendant, Stephen Skinner, the Plaintiff, Ralph Crone, has sustained a loss of income and loss of earning capacity. 14. In addition, at the time of the subject accident, the Plaintiff, Ralph Crone, was in the process of remodeling a commercial building for use in his business enterprise. 15. As a direct and proximate result of the injuries and damages he sustained, the Plaintiff, Ralph C. Crone, was unable to complete the work on his own as planned and was forced to incur the following labor costs: a. Garman Plumbing $2,855.00 b. Alternative Construction Concepts $5,508.00 r C. Sabolchick Electric $2,020.00 d. Essis Ft Son's Inc. $1,802.50 16. Supporting documentation for the above mentioned expenses are attached hereto as Exhibit A. 17. The Plaintiff avers that but for the injuries he sustained in the subject accident, he would have completed all of the above referenced work himself and, as a result, the Plaintiff is claiming these additional costs as a direct item of damages in this litigation. WHEREFORE, the Plaintiff, Ralph C. Crone, demands judgment against the Defendant, Stephen Skinner, in an amount in excess of $50,000.00, plus interest, costs, and attorneys fees and such other relief that this Court deems appropriate. Respectfully submitted, Conlon Tarker, P.C. i Raymond J. Co on, Esquire Attorney for Pl?intiff ?I 09 07 11:59a P.1 ¦ Jul, 6. 2007 5:20PM Conlon Tarker no. 4100 +. V YERIFICATI,ON 1, RALPH C. CRONE, have read the foregoing COMPLAINT IN CIVIL ACTION. The , statements therein are correct to the best of my personal knowledge, information and belief. This statement and verification are made subject to the penalties of 18 s Pa.C.S.A.149Q4 relating to unsworn falsification to authorities, which provides that if I make knowingty false averments, I may be subject4a criminal penalties. 7/7 V 7 DATE RALPH C: CRONE i L 4 CERTIFICATE OF SERVICE I hereby certify that a copy of the within document was served upon the individual named below on the ,311 day of July, 2007 by first class, U.S. mail, postage prepaid. Marc A. Moyer, Esquire Thomas, Thomas & Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 Attorney for Defendant Conlon Tarker, P.C. T ' 6MA?'jq Raym d J. Co Ion, Esquire Attorney for Pla ntiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff, No. 07-2838 Civil Term vs. EXHIBIT A TO PLAINTIFF'S COMPLAINT STEPHEN A. SKINNER, Filed on behalf of Plaintiff Defendant. Counsel of record for this party: Raymond J. Conlon, Esquire PA 1. 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QTY RATE 1. 15.;5,[5, ! t 5,,80 ? 1 10.00 2io.0!? t. ? t;'+.Cfi E `•,1.5, ?„'• 9I Q?R 24.75 i 3 19. 21 5 2.85 11.25 5 3. 21 5 16.2 2.50 J2.50 5 18.75 ? E @5 9 31.60 v : ,"y4ea z 1 130.0 i 1.3t ,vu 1 L;o.or) ; 13?1.Oi) 3. lift ?i q 3.60 1 1.63 ?rl;i(i ? i?a) 5,)O I i(I.o a tc- x- I ALL MAJOR. CREDIT CA DS ACCT-?7TD,, Alternative- Construction Concepts -1'ohn W. Alt, Sole Proprietor Edison Road Palmyra, PA 17078-8518 BILL TO Chuck Crone 857 East Louther Street Carlisle, PA 17013 Invoice DATE INVOICE # 1/13/2006 297 ALTERNATIVE CONSTRUCTION CONCEPTS JOHN W. ALT, Sole Proprietor 76 Edison Road Palmyra, PA 17078-8518 (717) 832-2002 Fax: (717) 832-0262 E-mail. aliconstruction@comcast net Bill To: 1/23/2006 Chuck Crone 857 East Louther Street Carlisle, PA 17013 Description: Labor from 1/9/06 to 1/20/06 Bryan 24 hours @ $27/hour = $648.00 Labor From 1/9/06 to 1/20/06 Jess 24 hours @ $15/hour = $360.00 Box -7oq Jam , O? 41 IV F iA) e? AJ 6- 5 723 ;,J /J 70 7 7 / v Total: $1008.00 _ j Alternative Construction Concepts Pos7" Invoice ,r,,Im W. Alt, Sole Proprietor j Edison Road Palmyra, PA 17078-8518 BILL TO Chuck Crone 857 East Louther Street Carlisle, PA 17013 DESCRIPTION Labor from 12/7/05 to 12/23/05 (92.5 hours Q $27/hour = $2,497.50) Labor from 12/7/05 to 12/23/05 (49.5 hours @ $I5/hour = $742.50) Home Depot RE: 7574 CARLISLE PIKE, MECHANICSBURG, PA 17050 At??? ? g2` DATE INVOICE # 1212812005 294 P.O. NO. 442 AMOUNT 2,497.50 742.50 30.62 Total il S bolchic k ElectriCl yq,3 . 72. East Keller Street' r,iechanicsburg, PA 17055 717-796-7040 Bill To Crone's Tae Kwon Do School Chuck Crone 24 East Main Street New Kingstown, PA 17072 Quantity Description Invoice Date Invoice # 1/16/2006 737 POSTED Due Date Project 1/31/2006 Rate 1 Quote 2,020.00 2,020.00 Relocate switches for lights in two rooms. Rewire 18 lights in those rooms with MC cable. Install 4 exit signs and 5 emergency battery packs. Install feed to new water heater. Install bath fan. Install receptacles once drywall is complete. , Original quote: $2200 Credit for deletion of 5 smoke detectors: $300 Addition of 1 exit sign and 1 battery pack: $120 s been a pleasure working with you! Total $2,020.00 too ESSIS & SON'S INC 6220 CARLISE PIKE 717-697-9423 FAX 717-697-7797 ¦iiiiiiii??i?iii?ii??i??ii?i¦ Date: February 2 2006 Estimator Joseph Essis TO: Crones Carlisle Pike New Kingstown PA We are pleased to submit the following sales agrement Job Description: MATERIALS 6 LAWR QUANTITY DESCRIPTION UNIT PRICE TOTAL 5000,00 el Zebra Matting 3.61 18,050.00 • 5000.00 bor mattin material l 1.50 7,500.00 700.00 eet 118 commercial cove base I 0.90 630.00 700.00 eet Labor base 0.50 350.00 415.00 8x8 Soma, Be" ceramic die eet 2.50 1,037.50 415.00 Peet ceramic tabor wall and floor 3.50 1,452.50 4.00 inset 18.50 74.00 4.00 rchement sanded rout 18.00 72.00 9.00 eulter metal [ 15.00 135.00 2.00 ulki parchment 9.50 19.00 143.00 Lodestar Marble Grey ds 19.00 2,717.00 167.00 ds carpet labor 4.50 751.50 24.00 ds Natural Selections Rosewood kitchen 15.00 360.00 Total Bid Price 33,14$.50 P•? 0 10 0 Price valid until. 30 days from estimate dat, M'D'd %0E S31!l3800006 l_ - Welcome to Crone's Tae Kwon Do School Page 1 of 1 If you're looking for an outstanding martial arts school with friendly students and highly qualified teachers, then you've come to the right place. Crone's Tae Kwon Do School, located in New Kingstown, Pennsylvania, is a high-quality institution that is actively devoted to its students as well as to its community. We have worked hard to be able to provide a wide variety of training programs in our school to ensure that we truly offer something for everybody! Our Mission Crone's Tae Kwon Do School's goal is to teach its students important life skills through fitness and the martial arts in a safe, structured, positively reinforced environment. We seek to discover the full potential of each of our students and to help prepare them to be outstanding martial artists and leaders in their communities. Contact Information Telephone (717) 691-4116 FAX (717) 766-2594 Postal address 24 E. Main Street, P.O. Box 704, New Kingston, PA 17072 E-Mail Head Master: MasterCrone@CronesTaeKwonDo.com Program Director: Kathy@CronesTaeKwonDo.com Webmaster: WebMaster@CronesTaeKwonDo.Com Send mail to WebMaster(o7CronesTaeKwonDo.Com with questions or comments about this web site. Copyright © 2oo6 Crone's Tae Kwon Do School Last modified: io/o3/o6 http://www.cronestaekwondo.com/ 3/10/2008 Instructor Bios Page 1 of 2 Crone's Tae Kwon Do School has an excellent team of dedicated, qualified instructors and assistant instructors! In addition to their teaching responsibilities, many of them are students in our school, so they know first-hand the hard work and hours of practice that are necessary to achieve goals here. They are motivators, mentors, and (of course) excellent teachers! Read on to learn more about our fabulous staff.. Master Crone - Head Instructor Master Crone is a 4th Degree Black Belt in the World Tae http://www.cronestaekwondo.com/instructor-bios.htin 3/10/2008 Instructor Bios Page 2 of 2 Kwon Do Federation as well as a 1st Degree Black Belt in the World Tae Kwon Do Association He studied under 9th Degree Grand Master Saipoon Chang. As a martial arts student since 1975, he has researched and studied many styles of martial arts and self-defense, including Judo, Wrestling, Boxing, Kick Boxing, Hapkido, Tae Kwon Do "WTA (Chung Do Kwon) WTF and Moo Duk Kwan". He has been along time member of the National Association of Professional Martial Artists (NAPMA), The Martial Arts Teachers Association, the Martial Arts Industry Association and Shuman Concepts. Master Crone has participated in many seminars held by some of the most recognized martial artists in the industry. Mr. Keeler - Instructor, Tournament Coordinator Mr. Keeler has been studying Tae Kwon Do with Master Crone for five years, and he has developed into a very qualified and dedicated Instructor. Being a tournament aficionado and a very organized person, he is a perfect fit for the role of Tournament Coordinator for Crone's Tae Kwon Do School. Mr. Keeler has been certified by Master Melody Shuman of Shuman Concepts to teach children and is one of our Mini and Little Ninjas Instructors. Ms. Bucher - Head Mini and Little Ninjas Instructor, Program Director As Program Director of Crone's Tae Kwon Do School, Ms. Bucher spends a lot of time making sure that classes run smoothly and that there is something for everyone here. As an instructor, she does effectively the same thing in a more hands-on sense. She has attended many martial arts seminars on many different subjects, and she brings a lot of experience of working with children. Send mail to WebMasterOCronesTaeKwonDo.Com with questions or comments about this web site. Copyright © 20o6 Crone's Tae Kwon Do School Last modified: io/o3/o6 h4://www.cronestaekwondo.com/instructor-bios.htrn 3/10/2008 S31a3S00006 !U- Thomas, Thomas & Hater, LLP Todd B. Narvol, Esquire Attorney I.D. No. 42136 Marc A. Moyer, Esquire Attorney I.D. No. 76434 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7133 - direct tnarvol@ttltlaw.com (717) 441-3960 - direct mmoyer@tthlaw.com (717) 237-7105 - fax Attorne}+s for Defendant Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, V. STEPHEN A. SKINNER, Plaintiff NO. 07-2838 CIVIL TERM Defendant INTERROGATORIES OF DEFENDANT STEPHEN A. SKINNER DIRECTED TO PLAINTIFF RALPH C. CRONE Pursuant to the provisions of the Pennsylvania Rules of Civil Procedure 4005 and 4006, the following Interrogatories are to be answered under oath within thirty (3 0) days. These interrogatories are continuing and any information secured subsequent to the filing of your answers, which would have been includable in the answers had it been known or available, are to be supplied by supplemental answers. This means that if between the preparation of your answers to the following interrogatories and the time of trial of this case you or anyone acting on your behalf should learn the identities or locations of any persons having knowledge of discoverable matters, the identities of any persons expected to be called as expert witnesses at trial, the subject matter of such expected expert testimony and the substance of such expert testimony, you shall promptly furnish the same to the undersigned by supplemental answers. If between the preparation of your answers to the following interrogatories and the time of trial of this case you or anyone on your behalf should obtain information upon the basis of which you know that an earlier answer to the following interrogatories was incorrect when made or, though correct when made, is no longer true, you shall promptly furnish the same to the undersigned by supplemental answers. These interrogatories are addressed to you, but all references to you shall be deemed to also include references to anyone acting on your behalf. The word "incident", "accident" or "occurrence", as used herein, refers to those events which allegedly caused harm to Plaintiff, Ralph C. Crone. Please attach written materials to any answer for which written materials are available. If they are not available, state where they may be obtained. Label the written materials with the number of the interrogatory to which they pertain. I. DEFINITIONS Unless otherwise stated, the terms set forth below are defined as follows: A. "Document" or "documents" shall mean all written or printed matter of any kind, including the originals and all non-identical copies thereof, whether different from the originals by reason of any notation made on such copies or otherwise, including without limitation minutes, agendas, contracts, agreements, reports, summaries, inter-office and intra-office communications, offers, notations of any sort of conversations, diaries, appointment books or calendars, teletypes, telefax, thermafax, confirmations, corputer data (including inforniation of programs stored in a computer, whether or not ever printed out or displayed), and all drafts, alterations, modifications, changes and amendments of any of the foregoing, and all graphic or manual records or representations of any kind, including without limitation photographs, microfiche, microfilm, videotape, records, and motion pictures, and electronic, mechanical or 2 electric records or representations of any kind, including without limitation tapes cassettes, discs, magnetic cards, and recordings. B. "All documents" shall mean every document, whether an original or copy, as above defined, known to you and every such document or writing which you can locate or discover by reasonably diligent efforts. C. "Oral communication" shall mean any utterance, spoken or heard, whether in person, by telephone, or otherwise. D. "And" shall mean and/or. E. "Or" shall mean and/or. F. "Identify" or "identity," when used in reference to an individual person, shall mean to state his or her full name, present or last known business address, or residence address if no present business address is known, telephone number, and the name of such person's present or last known employer, place of employment and position, and the position during the relevant time period. G. "Identify" or "identity," when used in reference to an entity, shall mean to state its full and complete name and the present or last known address of its headquarters or principal place of business. H. "Identify" or "identity," when used in reference to a document shall mean to state the nature of the document (e.g., letter, memorandum, etc.); the date, if any, appearing on the document; the identity of the person(s) who wrote, signed, dictated, or otherwise participated in the preparation of the document; the identity of all persons who received copies of the document; and the present location and custodian of the document. 3 I. "Identify" or "identity," when used in reference to a meeting or to an oral communication, shall mean to state the following: the date and place thereof, the identity of the individual(s) who initiated the meeting or oral communication; the identity of each person who participated in, or who was present at, any part or all of the meeting or oral communications, or who became privy to the substance of said meeting or oral communications; the subject of the meeting or oral communication and whether the meeting or oral communication occurred in person or by telephone, and if both, the method by which each individual participated. J. "Refer to," "referring to," and "concerning" mean directly or indirectly, in whole or in part, referring to, relating to, connected with, commenting on, impinging or impacting upon, affecting, responding to, showing, describing, analyzing, reflecting or constituting. K. Whenever an interrogatory requests you to "state the facts" or "describe," you should provide all information relating to the subject matter of such interrogatory, including a specification of dates of all events which relate to such subject matter, the identity of all oral communications and meetings relating to the subject matter, the identity of all persons with knowledge of the facts that relate to such subject matter, and the identity of all documents which refer to, relate to, or contain information concerning such subject matter. If there were any oral or written communications concerning the subject matter of the interrogatory, include the identity of the participants to such communications and set forth the substance of such communications. L. "Aware" shall mean to have knowledge of the existence of and substance of a certain subject or subject matter. 4 II. INSTRUCTIONS A. If you claim any form of privilege, whether based on statute or otherwise founded, as a ground for not answering an interrogatory or any part of an interrogatory or for not producing any document or part of any document, set forth all facts upon which the claim of privilege is based. B. If you claim any form of privilege, whether based on statute or otherwise, as a ground for not identifying requested oral conununications or documents, set forth all facts upon which the claim of privilege is based. C. Whenever a date, amount, or other computation or figure is requested, the exact date, amount, or other computation or figure is to be given unless it is not known; and in that case the approximate date, amount, or other computation or figure should be given or the best estimate thereof; and the answer should state that the date, amount, or other computation provided is an estimate or approximation. D. Where facts are set forth in the answers or portions thereof and are supplied upon information and belief rather than your direct personal knowledge, you should so state, and specifically identify each source of such infonnation and belief. Should you be unable to answer any interrogatory or portion thereof by either actual knowledge or upon information and belief, you should so state. 5 III. INTERROGATORIES State: (a) Your full name; (b) Each other name, if any, which you have used or by which you have been known; (c) The name of your spouse at the time of the accident and the date and place of your marriage to such spouse; (d) The address of your present residence and the address of each other residence which you have had during the past five years; (e) Your present occupation and the name and address of your employer; (f) Date of your birth; (g) Your Social Security number; (h) Your military service and positions held, if any; and (i) The schools you have attended and the degrees or certificates awarded, if any. ANSWER: 6 2. INJURIES: Describe separately each injury Plaintiff sustained in the incident and the approximate date on which Plaintiff recovered from each such injury. ANSWER: 7 3. Do you contend that you are currently unable to perform or engage in any activities, including any martial arts tasks or maneuvers which you were able to participate in or perform prior to the incident? If so, identify with particularity the activities, maneuvers or tasks you are no longer able to perform. ANSWER: HEALTH CARE PROVIDERS: Identify each health care provider who has examined, treated or rendered services to Plaintiff because of this incident, including dates of such services. ANSWER: 5. MEDICAL EXPENSES AND INSURANCE PAYMENTS: State the total amount of medical expenses incurred by Plaintiff that relate to this incident, the amount compensated by first-party benefits, Med-pay benefits or any other form of insurance (identifying whether the payment made by any other form of insurance are from an ERISA-qualified plan), the amount, if any, subject to a lien of any sort, the identity of any lien holder, and the amount claimed to be recoverable at trial ANSWER: 10 5. Please complete the chart below by entering in column "A" the names of the medical care provider who rendered care and treatment to you for injuries you allegedly sustained as a result of the accident; column "B" the total amount of charges for each medical provider; column "C" the total amount of medical expenses for each provider that was paid by any insurance carrier; column "D" the amount of medical expenses that were "written off', forgiven, adjusted, otherwise not owed; and column "E" the total amount of medical expenses that were owed by Plaintiff. ANSWER: A B C D E Medical Care Total Medical Amount of Amounts Amounts Paid Provider Charges for Medical "Written Off", or Owed by Each Medical Charges Paid by Forgiven or Plaintiff or His Care Provider Plaintiffs Otherwise Not or Her Insurance Owed to the Representative Medical Care Personally (i.e. Provider not paid by insurance or written of 11 TERMINATION OF MEDICAL SERVICE: When and by whom was Plaintiff last examined or given medical attention for each of the injuries received in this incident? ANSWER: 12 CONTINUATION OF MEDICAL SERVICES: If Plaintiff is still being treated for the injuries received in this incident, please identify by whom, state how frequently such treatments are being given now, the nature of the treatment being administered, and the extent to which such treatment will be required in the future. ANSWER: 13 FAMILY PHYSICIAN: Please state the name and address of Plaintiff's family physician for the last ten (10) years. ANSWER: 14 10. Prior or subsequent injuries or diseases. - If, either prior to or subsequent to the incident, you suffered any injury or disease in those portions of the body claimed by you to have been affected by the incident, state: (a) The injury or disease you suffered; (b) The date and place of any accident, if such injury or disease was caused by an accident; (c) The identity of hospitals, doctors, or practitioners who rendered treatment or examination because of such injury or disease; or (d) The identity of anyone against whom a claim was made, and the tribunal and docket number of any claim or lawsuit that was filed in connection with such injury or disease. ANSWER: 15 11. DISABILITY: Does Plaintiff contend that he has been permanently injured as a result of this incident? If so, please describe the exact nature of the alleged disability, the degree of disability, and the identity of any health care provider who has either informed Plaintiff that the injury is permanent or who has assigned a degree of disability to any condition. If you expect a health care provider to form an opinion regarding disability, degree of disability, and/or permanency, but he has not yet done so, please identify that health care provider. ANSWER: 16 12. Earnings before the incident. - For the period of seven (7) years immediately preceding the date of the incident, state; (a) The name and address of each of your employers or, if you were self- employed during any portion of that period, each of your business addresses and the name of the business while self-employed; (b) The dates of commencement and termination of each of your periods of employment or self-employment and location of employment; (c) The nature of your occupation in each employment or self=employment; and (d) The wage, salary, or rate of earnings received by you in each employment or self-employment and the amount of income from employment and self- employment for each year. ANSWER: 17 13. Earnings after the incident. - If you have engaged in one or more gainful occupations subsequent to the date of the incident, state: (a) The name and address of each of your employers or, if you were self- employed at anytime subsequent to the incident, each of your business addresses and the name of the business while self-employed; (b) The dates of commencement and termination of each of your periods of employment or self-employment and location of employment; (c) The nature of your occupation in each employment or self-employment; (d) The wage, salary, or rate of earnings received by you in each employment or self-employment and the amount of income from employment or self- employment for each year; and (e) The date(s) of any absence(s) from your occupation resulting from any injury or disease suffered in this incident and the amount of any earnings or other benefits lost by you because of such absence(s). ANSWER: 18 14. STATEMENTS: Has Plaintiff or anyone acting on Plaintiffs behalf obtained any statements, reports, memorandum or testimony in any form from any person relating to this incident. If so, please identify from whom the statement was taken, the date of the statement and provide a copy in answer to this Interrogatory. ANSWER: 19 15. WITNESSES: Please identify any witness who has any knowledge of, or information as to, facts pertaining to this incident regarding liability or damages and provide a summary of the information which each witness has concerning this incident. ANSWER: 20 16. Identify all persons whom you intend to call as witnesses to testify at the trial of this matter, and provide a summary of the substance of their testimony. ANSWER: 21 17. EXHIBITS: Identify all exhibits, books, magazines or other such writings, documents, tangible objects, models, specimens or things which will be used or introduced as an exhibit at the trial of this case and state whether they will be used during the liability or damages portions of the trial. ANSWER: 22 18. EXPERT WITNESSES: Identify all experts whom Plaintiff expects to call at the trial of this case, and pursuant to Pennsylvania Rule of Civil Procedure 4003.5(a) (1) (b), please state the substance of the facts and opinions to which Plaintiffs expert will testify and a summary of the grounds for each opinion. The facts, opinions and grounds of the expert may be contained in an expert report which may be attached. Such report or answer to this Interrogatory should be signed by Plaintiff s expert. ANSWER: 23 19. PHOTOGRAPHS. DOCUMENTS AND THINGS: If Plaintiff, or anyone acting on Plaintiffs behalf, has or knows of any photographs, diagrams, measurements, video recordings, maps, models, surveys or other descriptions regarding or relating in any way to this incident, vehicles involved in the incident, or to personal injury or damages claimed to be sustained by the Plaintiff, please identify those items and provide a copy of such items as attachments to these Answers. ANSWER: 24 20. If Plaintiff, or anyone acting on Plaintiffs behalf, has or knows of any photographs, diagrams, measurements, video recordings, maps, models, surveys or other descriptions regarding or depicting in any way Plaintiff performing or instructing martial arts from July 5, 2000 to present, please identify those items and provide a copy of such items as attachments to these Answers. ANSWER: 25 21. RELATED LAWSUITS: Please identify by caption, docket number and court any other kind arising from this incident or relating to the injuries claimed by which Plaintiff has been involved. ANSWER: lawsuits or claims of any Plaintiff in this suit, or in 26 22. Please itemize and describe any other expenses or financial losses which you have paid or incurred which you attribute to the incident. ANSWER: 27 23. PRIOR CONVICTIONS: Have you been convicted or pled guilty to any crime within the past ten (10) years. If so, please state, for each conviction or plea, the offense charged, the court caption and docket, and the disposition and sentence. ANSWER: 28 24. Would any settlement or verdict secured by you in this matter be subject to any Federal Lien, State Lien, FELA Lien, Workmen's Compensation Lien, or any similar or other lien? If so, please identify the holder of the lien, the amount of the lien, the costs or expenses covered by the lien, and the circumstance under which you are or might be obligated to satisfy the lien. ANSWER: 29 25. OCCURRENCE OF INCIDENT: State in detail the manner in which you assert the incident giving rise to this suit occurred specifying your exact position, activities, movements, and actions both before and at the time of the incident. ANSWER: 30 26. INSURANCE OPTIONS: (a) If you are a named insured on a policy of insurance covering a Pennsylvania registered motor vehicle which was written or renewed after July 1, 1990, indicate whether you chose the "limited tort" option or "full tort" option as described in the Pennsylvania Motor Vehicle Financial Responsibility Act, as amended July 1, 1990 of Act VI, and contained in 75 Pa.C.S.A. Section 1705. (b) If you are not a named insured on a policy of insurance covering a Pennsylvania registered motor vehicle which was written or renewed after July 1, 1990, indicate whether the named insured(s) in the household in which you reside chose the "limited tort" or "full tort" option as described in the Pennsylvania Motor Vehicle Financial Responsibility Act, as amended July 1, 1990 of Act VI, and contained in 75 Pa.C.S.A. Section 1705. ANSWER: 31 27. If you, or a named insured(s) in the household in which you reside chose the limited tort option as set forth in 75 Pa.C.S.A. Section 1705; please state whether you claim to have suffered a "serious injury" as defined in 75 Pa.C.S.A. Section 1702. ANSWER: 32 28. If you are claiming you have suffered a serious injury, as defined in 75 Pa.C.S.A. Section 1702; please identify whether the personal injury you suffered resulted in death, serious impairment of a body function, or a permanent serious disfigurement. (a) If you have claimed a serious impairment of a bodily function, please state in detail the injury you have received, and the bodily function that has been seriously impaired. (b) If you have claimed that you suffered injuries resulting in permanent serious disfigurement, please state in detail the injuries you received and the permanent serious disfigurement you suffered as a result of these injuries. ANSWER: 33 29. If you did not own a motor vehicle the date of this accident, please state the tort election made by your spouse and every other relative residing in your household on the date of the accident. ANSWER: 34 30. Identify all martial arts tournaments, contests, demonstrations, seminars, conferences or other events in which Plaintiff participated with respect to martial arts from July 5, 2000 to present. ANSWER: 35 31. Identify all martial arts or business awards, honors, trophies, and inductions Plaintiff has received from July 5, 2000 to present, and the dates Plaintiff received such honors and awards. ANSWER: 36 r 32. Identify the names, addresses and telephone numbers of all individuals who received martial arts instruction or training from Plaintiff from July 5, 2000 to present. ANSWER: 37 33. Identify the names, addresses and telephone numbers of all individuals who were employed by Plaintiff or by Crone Tae Kwon Do School, or who provided martial arts instruction on Plaintiff's behalf or at Crone's Tae Kwon Do school from July 5, 2000 to present. ANSWER: 38 34. Identify each style of martial arts and self-defense for which Plaintiff had provided instruction and training from July 5, 2000 to present, and set forth the time periods for which such instruction and/or training was provided by the Plaintiff. ANSWER: 39 35. Identify all associations and organizations in which Plaintiff was a member from July 5, 2000 to present. ANSWER: Respectfully submitted, T6dd B. Narvol, quire Attorney I.D. N . 42136 Marc A. Moy , Esquire Attorney No. 76434 THOMAS, THOMAS & HAFER LLP 305 North Front Street, 6th Floor Post Office Boa 999 Harrisburg, PA 17108 717-441-3960 mmoyer@tthlaw.com Dated: July ?. , 2007 514781.1 Counsel for Defendant Stephen A. Skinner 40 CERTIFICATE OF SERVICE i On this .' day of July 2007, I, Kristine Hendrix, a legal secretary, with the law firm Thomas, Thomas & Hafer, LLP, hereby certify that I have, this day, served a true and correct copy of the INTERROGATORIES OF DEFENDANT STEPHEN A. SKINNER DIRECTED TO PLAINTIFF RALPH C. CRONE upon the person(s) and at the address(es) below named via United States First Class Mail, postage prepaid, in Harrisburg, PA: Raymond J. Conlon, Esquire Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 Counsel for Plaintiff J e'9 ,r is'tme Hei Brix M'D'd %OC 63189S OOD06 Thomas, Thomas S Hafer, LLP Todd B. Narvol, Esquire (717) 237-7133 - direct Attorney I.D. No_ 42136 tnarvolntthlaw.com Marc A. Moyer, Esquire ('117) 441-3960 - direct Attorney I.D. No. 76434 mmoyer car tthlaw.com 305 N. Front Street P.O. Box 999 (717) 237-7105 - fax Harrisburg, PA 17105-0999 Attorneys for Defendant Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, V. STEPHEN A. SKINNER, Plaintiff NO. 07-2838 CIVIL TERM Defendant SECOND SET OF INTERROGATORIES OF DEFENDANT STEPHEN A. SKINNER DIRECTED TO PLAINTIFF RALPH C. CRONE Pursuant to the provisions of the Pennsylvania Rules of Civil Procedure 4005 and 4006, the following Interrogatories are to be answered under oath within thirty (30) days. These interrogatories are continuing and any information secured subsequent to the filing of your answers, which would have been includable in the answers had it been known or available, are to be supplied by supplemental answers. This means that if between the preparation of your answers to the following interrogatories and the time of trial of this case you or anyone acting on your behalf should learn the identities or locations of any persons having knowledge of discoverable matters, the identities of any persons expected to be called as expert witnesses at trial, the suvject matter of such expected expert testimony and the substance of such expert testimony, you shall promptly furnish the same to the undersigned by supplemental answers. If between the preparation of your answers to the following interrogatories and the time of trial of this case you or anyone on your behalf should obtain information upon the basis of which you know that an earlier answer to the following interrogatories was incorrect when made or, though correct when made, is no longer true, you shall promptly furnish the same to the undersigned by supplemental answers. These interrogatories are addressed to you, but all references to you shall be deemed to also include references to anyone acting on your behalf. The word "incident", "accident" or "occurrence", as used herein, refers to those events which allegedly caused harm to Plaintiff, Ralph C. Crone. Please attach written materials to any answer for which written materials are available. If they are not available, state where they may be obtained. Label the written materials with the number of the interrogatory to which they pertain. 1. DEFINITIONS Unless otherwise stated, the terms set forth below are defined as follows: A. "Document" or "documents" shall mean all written or printed matter of any kind, including the originals and all non-identical copies thereof, whether different from the originals by reason of any notation made on such copies or otherwise, including without limitation minutes, agendas, contracts, agreements, reports, summaries, inter-office and intra-office conununications, offers, notations of any sort of conversations, diaries, appointment books or calendars, teletypes, telefax, thennafax, confirmations, computer data (including information of programs stored in a computer, whether or not ever printed out or displayed), and all drafts, alterations, modifications, changes and amendments of any of the foregoing, and all graphic or manual records or representations of any kind, including without limitation photographs, microfiche, microfilm, videotape, records., and motion pictures, and electronic, mechanical or 1) electric records or representations of any kind, including without limitation tapes cassettes, discs, magnetic cards, and recordings. B. "All documents" shall mean every document, whether an original or copy, as above defined, known to you and every such document or writing which you can locate or discover by reasonably diligent efforts. C. "Oral communication" shall mean any utterance, spoken or heard, whether in person, by telephone, or otherwise. D. "Acid" shall mean and/or. E. "Or" shall mean and/or. F. "Identify" or "identity," when used in reference to an individual person, shall mean to state his or her full name, present or last known business address, or residence address if no present business address is known, telephone number, and the name of such person's present or last known employer, place of employment and position, and the position during the relevant time period. G. "Identify" or "identity," when used in reference to an entity, shall mean to state its full and complete name and the present or last known address of its headquarters or principal place of business. H. "Identify" or "identity," when used in reference to a document shall mean to state the nature of the document (e.g., letter, memorandum, etc.); the date, if any, appearing on the document; the identity of the person(s) who wrote, signed, dictated, or otherwise participated in the preparation of the document; the identity of all persons who received copies of the document; and the present location and custodian of the document. I. "Identify" or "identity," when used in reference to a meeting or to an oral communication, shall mean to state the following: the date and place thereof, the identity of the individual(s) who initiated the meeting or oral communication; the identity of each person who participated in, or who was present at, any part or all of the meeting or oral communications, or who became privy to the substance of said meeting or oral communications; the subject of the meeting or oral communication and whether the meeting or oral communication occurred in person or by telephone, and if both, the method by which each individual participated. J. "Refer to," "referring to," and "concerning" mean directly or indirectly, in whole or in part, referring to, relating to, connected with, commenting on, impinging or impacting upon, affecting, responding to, showing, describing, analyzing, reflecting or constituting. K. Whenever an interrogatory requests you to "state the facts" or "describe," you should provide all information relating to the subject matter of such interrogatory, including a specification of dates of all events which relate to such subject matter, the identity of all oral communications and meetings relating to the subject matter, the identity of all persons with knowledge of the facts that relate to such subject matter, and the identity of all documents which refer to, relate to, or contain information concerning such subject matter. If there were any oral or written communications concerning the subject matter of the interrogatory, include the identity of the participants to such communications and set forth the substance of such communications. L. "Aware" shall mean to have knowledge of the existence of and substance of a certain subject or subject matter. 4 11. INSTRUCTIONS A. If you claim any form of privilege, whether based on statute or otherwise founded, as a ground for not answering an interrogatory or any part of an interrogatory or for not producing any document or part of any document, set forth all facts upon which the claim of privilege is based. B. If you claim any form of privilege, whether based on statute or otherwise, as a ground for not identifying requested oral communications or documents, set forth all facts upon which the claim of privilege is based. C. Whenever a date, amount, or other computation or figure is requested, the exact date, amount, or other computation or figure is to be given unless it is not known; and in that case the approximate date, amount, or other computation or figure should be given or the best estimate thereof; and the answer should state that the date, amount, or other computation provided is an estimate or approximation. D. Where facts are set forth in the answers or portions thereof and are supplied upon information and belief rather than your direct personal knowledge, you should so state, and specifically identify each source of such information and belief. Should you be unable to answer any interrogatory or portion thereof by either actual knowledge or upon information and belief, you should so state. 5 III. INTERROGATORIES 1. Set forth the names and addresses of all hospitals and/or other healthcare providers in which Plaintiff has been a patient or received treatment within seven (7) years preceding the accident forming the basis for this lawsuit, and identify the dates of confinement and/or treatment, and the charges for same. ANSWER: Respectfully submitted, Todd B. Narvol: Esquire Attorney I.D. Pb. 42136 Marc A. MoAr, Esquire Attorney No. 76434 THOMAS, THOMAS & HAFER LLP 305 North Front Street, 6th Floor Post Office Box 999 Harrisburg, PA 17108 717-441-3960 milioyer@tthlaw.com Dated: July 19, 2007 514781.2 Counsel for Defendant Stephen A. Skinner 6 CERTIFICATE OF SERVICE On this 19th day of July 2007, 1, Nora A. Starnes, a legal secretary, with the law firm Thomas, Thomas & Hafer, LLP, hereby certify that I have, this day, served a true and correct copy of the SECOND SET OF INTERROGATORIES OF DEFENDANT STEPHEN A. SKINNER DIRECTED TO PLAINTIFF RALPH C. CRONE upon the person(s) and at the address(es) below named via United States First Class Mail, postage prepaid, in Harrisburg, PA: Raymond J. Conlon, Esquire Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 Counsel for Plaintiff 2, Nora A. Starnes M'j d % OE ?a31?A?3N' S31899 00006 I` Thomas, Thomas S Hafer, LLP Todd B. Narvol, Esquire Attorney I.D. No. 42136 Marc A. Moyer, Esquire Attorney I.D. No. 76434 305 N. Front Street P.O. Box 999 Harrisburg, PA 1 7 1 08-0999 (717) 237-7133 -direct tnarvol@tthlaw.com (717) 441-3960 - direct mmoyer@tthlaw.com (717) 237-7105 - fax Attorneys for Defendant Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant REQUEST FOR PRODUCTION OF DOCUMENTS OF DEFENDANT, STEPHEN A. SKINNER, DIRECTED TO PLAINTIFF Pursuant to Pennsylvania Rule of Civil Procedure 4009, Defendant requests Plaintiff to supply within thirty (30) days the originals or authentic and legible copies of the documents and things hereinafter identified to the offices of Thomas, Thomas & Hafer, LLP, 305 North Front Street, P.O. Box 999, Pennsylvania 17108. This Request for Production of Documents shall be deemed to be continuing in nature so as to require the production of further documents obtained between the date this present request is responded to and the date of trial, or such earlier time as the Court in this case may fix as the deadline for the production of documents which are to be used or will be usable at the time of the trial of this case. INSTRUCTIONS 1. In answering these Requests for Production of Documents, the respondent shall furnish all information available at the time of answering, including information in the possession of any and all representatives, agents, or attorneys and shall supplement the responses whenever necessary in accordance with the Pennsylvania Rules of Civil Procedure. 2. Each Request for Production of Documents shall be answered separately and as completely as possible. The fact that investigation is continuing or that discovery is not yet completed shall not be reason for failure presently to answer each request as fully as possible. 3. If any form of privilege or other protection from disclosure is claimed as a ground for withholding responsive information, respondent shall set forth each and every fact supporting the claim with sufficient specificity to permit full determination by the court as to whether the claimed privilege or protection is valid. With respect to a document regarding which a privilege or protection is claimed, a respondent shall set forth that document's name, date of creation, identification of the author and all other information required for identification of the document without revealing the information for which the privilege or the protection from the disclosure is claimed. 4. For the purposes of these discovery request, the singular form shall include the plural, and vice versa; the masculine form shall include the feminine, and vice versa; and the words "and" and "or" shall be construed conjunctively or disjunctively, whichever construction is required in order for the request to have its broadest interpretation. 5. "Person" shall mean, without limitation, any natural person, corporation, partnership, limited partnership, association, joint venture or any other business entity, organization, firm, or arrangement or any other type of person. 6. "Document" or "documents" shall mean all written or printed matter of any kind, including the originals and all non-identical copies thereof, whether different from the originals by reason of any notation made on such copies or otherwise, including without limitation minutes, agendas, contracts, agreements, reports, summaries, inter-office and intra-office communications, offers, notations of any sort of conversations, diaries, appointment books or 2 calendars, teletypes, telefax, thermafax, confirmations, computer data (including information of programs stored in a computer, whether or not ever printed out or displayed), and all drafts, alterations, modifications, changes and amendments of any of the foregoing, and all graphic or manual records or representations of any kind, including without limitation photographs, microfiche, microfilm, videotape, records, and motion pictures, and electronic, mechanical or electric records or representations of any kind, including without limitation tapes, cassettes, discs, magnetic cards, and recordings. 7. "Identify", when applicable to a document, shall mean to state: (a) the title of the document and any distinguishing file or department number assigned thereto; (b) the date the document was originally prepared or created; (c) the identification of the author, creator, sender and/or originator of the document; (d) identification of all persons to whom the document was sent, directed or addressed, and identification of all persons who are in possession of the original and any copy of the document; (e) identification of the present custodian of the document; (f) the present location of the document. 8. "Identify", when applicable to a person, shall mean to state: (a) the person's full name; (b) The person's present and/or last known address and telephone number; (c) an identification of the person's present and/or last known employer; 3 (d) an identification of employment. DOCUMENTS AND THINGS REQUESTED 1. All photographs showing, representing or purporting to show any of the vehicles, instrumentalities, locales, persons, property, injuries and any and all other matters related to the subject matter of this litigation. 2. All diagrams, sketches, drawings, plans, measurements or blueprints showing, representing or purporting to show any of the vehicles, instrumentalities, locales, persons, property, injuries or other matter involved in the incident which form the basis of Plaintiffs Complaint or cause of action. 3. All statements, including but not restricted to those defined by Pa.R.C.P. 4003.5, signed statements, transcripts of recorded statements or interviews, or any memoranda or summary of transcripts of statements or interviews of any party, person or witness, or their agents or employees, who have any knowledge or information of the facts concerning or pertaining to the incident, the subject matter, the claims, the damages, injuries, or any other matter involved in or pertaining to this case. 4. All expert opinions, expert reports, expert summaries or other writings, and curriculum vitae as to each such expert or experts which relate to the subject matter of this litigation and the incident in question. 5. All documents prepared by you or by any insurer(s), representative(s), agent(s) or anyone acting on your behalf, except your attorney(s), during an investigation of any aspect of the incident in question. Such documents shall include any documents made or prepared through the present time with the exclusion of mental impressions, conclusions or opinions respecting the value or merit of a claim or defense or respecting strategy or tactics. 5 (NOTE: As referred to herein, "documents" includes written, printed, typed, recorded or graphic matter, however produced or reproduced, including correspondence, telegrams, other written communications, data processing storage units, tapes, videos, films, microfilm, microfiche, contracts, agreements, notes, memoranda, summaries, analyses, projections, indices, work papers, studies, test reports, test results, surveys, diaries, calendars, films, photographs, videos, movies, diagrams, drawings, sketches, minutes of meetings or any other writing [including copies of the foregoing, regardless of whether the parties to whom this request is addressed is not in the possession, custody or control of the original] now in the possession, custody or control of Plaintiff, his former or present counsel, agents, employees, officers, insurers or any other persons acting on his behalf.) 6. If not otherwise covered by the above Requests, the complete claims/investigation/subrogation/insurance file(s) of your insurer(s), including. but not limited to, your first party automobile insurance carrier, dealing with the incident in question, with the exclusion of the mental impressions, conclusions or opinions respecting the value or merit of a claim or defense, or respecting strategy or tactics. 7. All documents relating in any way to all injuries, damages and losses sustained by Plaintiff. This should include, but not be limited to bills, invoices, medical reports, medical records, receipts, hospital records, charts and x-rays, wage and employment information, and all other documents in any way relating to Plaintiff's alleged injuries and damages. 8. Any release or other agreement between any person or entities given or obtained in regard to the subject incident. 6 9. Any and all documents evidencing or pertaining to any lien by any person or entity against potential recovery of damages by Plaintiff in this action. 10. All documents or exhibits which you intend to offer or identify as exhibits and/or evidence at any depositions or at the trial of this matter. 11. All documents, including but not limited to, advertisements, circulars, brochures, pamphlets, leaflets, writings and other such promotional items any expert witness you have retained for use at trial uses and has used in the past to promote his services as an expert witness. 12. All financial records concerning the Plaintiff including but not limited to any and all tax returns, W-2's, and other filings, employment records, and wage or salary information for the five (5) years preceding the accident to the present. 13. All financial records concerning the Plaintiffs business operations including but not limited to any and all tax returns, W-2's, and other filings, employment records, and wage or salary information for the five (5) years preceding the accident to the present. 14. Any and all documents which evidence any facts on the basis of which it will be asserted that the Defendant caused or contributed to the happening of the injuries sustained by the Plaintiff. 15. Any documents identified in your Answers to any set of Interrogatories propounded by any party to this litigation. 16. All documents which would support any claims for injuries/damages averred in Plaintiff s Complaint. 17. A copy of any declaration sheet for any automobile insurance policy applicable to this case under which you are an insured. 7 18. All records regarding any treatment, consultation or therapy for any psychological or psychiatric condition, injury or issue. 19. Any document or thing obtained by subpoena or authorization. 20. All documents bearing the names, addresses or telephone numbers of all customers or students of Crone's Tae Kwon Do School or other individuals who received martial arts instruction or training from Plaintiff from July 5, 2000 to present. 21. All diaries, advertisements, calendars, or publications identifying dates and times of martial arts training or instruction conducted by Plaintiff or conducted at Crone's Tae Know Do School from July 5, 2000 to present. 22. All advertising materials created by, or pertaining to, Plaintiff or Crone's Tae Kwon Do School created or distributed from July 5, 2000 to present. 23. All newspaper articles or other publications pertaining to Plaintiff or Crone's Tae Kwon Do School published from July 5, 2000 to present. 24. All photographs or videotape recordings of Plaintiff performing or instructing martial arts taken or recorded from July 5, 2000 to present. 25. All documents and invoices pertaining to the construction or renovation of the building or location of Plaintiff's place of business. 26. Any other discoverable document or thing in your file, not specifically requested herein above. 8 27 party. Any document referring to any bankruptcy filing to which you were or are a Dated: July , 2007 5 14921.1 Respectfully submitted, r /YA/ squire Todd . N vV-42136 Attorney I.D. Marc A. Moyer, Esquire Attorney No. 76434 THOMAS, THOMAS & HAFER LLP 305 North Front Street, 6th Floor Post Office Boa 999 Harrisburg, PA 17108 717-441-3960 mmoyer@tthlaw.com Counsel for Defendant Stephen A. Skinner 9 CERTIFICATE OF SERVICE On this 6 --'?day of July 2007, 1, Kristine Hendrix, a legal secretary, with the law firm Thomas, Thomas ,& Hafer, LLP, hereby certify that I have, this day, served a true and correct copy of the REQUEST FOR PRODUCTION OF DOCUMENTS OF DEFENDANT, STEPHEN A. SKINNER, DIRECTED TO PLAINTIFF upon the person(s) and at the address(es) below named via United States First Class Mail, postage prepaid, in Harrisburg, PA: Raymond J. Conlon, Esquire Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 Counsel for Plaintiff Kri #ne Hendrix Mod -xc ®031?A331i S31H3S 00006 0 MI CotvroNTAtKEu January 31, 2008 Marc A. Moyer, Esquire Thomas, Thomas Ft Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 RE: Ralph C. Crone v. Stephen A. Skinner No. 07-2838 Civil Term yours, . Conlon Dear Mr. Moyer: As a supplement to the Plaintiff's Response to Request for Production of Documents, enclosed please find additional file materials I have received from Mr. Crone's first party carrier, State Auto. This information was provided to me in response to a request for updated first party file materials. The answers to interrogatories have been sent to Mr. Crone for verification. Upon my receipt of the signed verification, the answers to interrogatories will be forwarded to you. RJC/mar Enclosures cc: Ralph C. Crone (w/o encl. ) 1",NOti1 c)iliui:.,a,Sa.-i,i m, i (,ONION ]ARKF.K, Counsel for Plaintiffs 108 East Diamond Street Butler, Pennsylvania 16001 phone: 724.285.7700 fax: 724.285.6700 9 Z - 6 WV 118VW 3001 3HI JO 30;'ZIAC -031H RALPH C. CRONE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW STEPHEN A. SKINNER, Defendant NO. 07-2838 CIVIL TERM ORDER OF COURT AND NOW, this 17`h day of March, 2008, upon consideration of Defendant Stephen A. Skinner To Compel Plaintiff's Responses to Disco hereby issued upon Plaintiff to show cause why the relief requested granted. RULE RETURNABLE within 20 days of service. ? RaYmond J. Conlon, Esq. 108 East Diamond Street Butler, PA 16001 Attorney for Plaintiff ? Todd B. Narvol, Esq. Marc A. Moyer, Esq. 305 North Front Street 6th Floor P.O. Box 999 Harrisburg, PA 17108 Attorneys for Defendant : rc r ?07 t F.s rY??? t C£??. BY THE COURT, r J/Wesley Q*'r Jr., Motion of , a Rule is not be 7u of NA L I M 8881 A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff, No. 07-2838 Civil Term VS. STEPHEN A. SKINNER, NOTICE OF SERVICE OF PLAINTIFF'S DISCOVERY RESPONSES Filed on behalf of Plaintiff Defendant. Counsel of record for this party: Raymond J. Conlon, Esquire PA 1. D. # 49495 conlon@conlontarker.com Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 724.285.7700 724.285.6700 fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff, No. 07-2838 Civil Term VS. STEPHEN A. SKINNER, Defendant. NOTICE OF SERVICE OF PLAINTIFF'S DISCOVERY RESPONSES TO: Curtis R. Long, Prothonotary I hereby certify that the Plaintiff's discovery responses were served upon counsel for the Defendant, Marc A. Moyer, Thomas, Thomas Et Hafer, LLP, at P.O. Box 999, Harrisburg, PA 17108, by first class, U.S. mail, postage prepaid as follows: 1. Response to Request for Production of Documents of Defendant Stephen A. Skinner Directed to Plaintiff - served on 1/18/08; 3. Answers to Interrogatories of Defendant Stephen A. Skinner Directed to Plaintiff Ralph C. Crone - served on 3/18/08; 3. Answers to Second Set of Interrogatories of Defendant Stephen A. Skinner Directed to Plaintiff Ralph C. Crone - served on 3/18/08; and Respectfully submitted, , P. C. Rayn4or`d J?6nlotf,\Esquire Attorney f r Plaintiff CERTIFICATE OF SERVICE I hereby certify that a copy of the within document was served upon counsel named below on the 18th day of March, 2008 by first class, U.S. mail, postage prepaid. Marc A. Moyer, Esquire Thomas, Thomas Et Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 Attorney for Defendant Conlon Tarker, P.C. C''± ? ..1r _ ..?y.s ? 1 ? ?',..?. - ?.. ,.. _ ,? ??,. _ i"S , may. - ?- ?-?,. _ ?'+? ? ,. i 1 i '.. _.f? ? ?? ^? ?..,, .^? IN THEI COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH C. CRONE, CIVIL DIVISION - LAW Plaintiff, A.D. NO. 07-2838 Civil Term VS. STEPHEN A? SKINNER, REPLY TO NEW MATTER Defendant. Filed on behalf of: Plaintiff Counsel of record for this party: Raymond J. Conlon, Esquire PA I. D. No. 49495 Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 (724) 285-7700 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RALPH C. RONE, Plaintiff, vs. STEPHEN A . SKINNER, Defendant. CIVIL DIVISION - LAW A.D. No. 07-2838 Civil Term REPLY TO NEW MATTER AND NOW, comes the Plaintiff, Ralph C. Crone, by and through his attorneys, Conlon Tarkor, P.C. and Raymond J. Conlon, Esquire, and files the following Reply to New Matter and in support thereof, avers as follows: 1. I In response to Paragraph 18 of Defendant's New Matter, the Plaintiff incorporates his Complaint as though the same were set forth at length herein. 2. Paragraph 19 of the Defendant's New Matter is specifically denied. To the contrary the Plaintiff's Complaint states a valid cause of action upon which relief can be granted for the negligent conduct of the Defendant. 3. ? The allegations of Paragraph 20 of the Defendant's New Matter are legal conclusions to which no response is required. To the extent a response is deemed necessary, it?is specifically denied that the Pennsylvania Comparative Negligence Act applies. reasonable collided Plaintiff was operating his motor vehicle in a careful, cautious, and when the Defendant negligently, recklessly, and carelessly his vehicle, causing him to sustain the injuries and damages set forth in his Complain 4. The allegations of Paragraph 21 of the Defendant's New Matter are legal conclusions to which no response is required. To the extent a response is deemed necessary, it is specifically denied that assumption of the risk applies. The Plaintiff was operating his motor vehicle in a careful, cautious, and reasonable manner when the Defendant negligently, recklessly, and carelessly collided with his vehicle, causing him to sustain the injuries and damages set forth in his Complaint. 5. The allegations of Paragraph 22 of the Defendant's New Matter are legal conclusions o which no response is required. However, insofar as a response is deemed nec ssary, the said averments are specifically denied. It is denied that the Plaintiff wa negligent in any fashion. To the contrary, at all times relevant hereto, the Plaintiff acted in a careful, cautious, and reasonable manner. 6. The allegations of Paragraph 23 of the Defendant's New Matter are legal conclusions to which no response is required. However, insofar as a response is deemed necessary, said averments are denied. To the contrary, the sole and proximate cause of the subject accident and all the damages sustained by the Plaintiff waslthe negligent conduct of the Defendant, Stephen Skinner, as set forth in the Plaintiff's Complaint. 7. I The allegations of Paragraph 24 of the Defendant's New Matter are specifically denied. To the contrary, it is averred that the sole and proximate cause of the subject accident was the negligent conduct of the Defendant, Stephen A. Skinner, as s t forth in the Plaintiff's Complaint. 8. I The allegations of Paragraph 25 of the Defendant's New Matter amount to legal conclusions to which no response is required. To the extent a response is deemed necessary, said averments are specifically denied. To the contrary, it is averred that the negligent conduct of the Defendant, Stephen A. Skinner, was a substantial factor and was a legal factor in causing or contributing to the Plaintiff's injuries and damages. 9. ? The allegations of Paragraph 26 of the Defendant's New Matter are specifically denied. To the contrary, it is averred that all the injuries and damages set forth in the Plaintiff's Complaint were caused by the negligent conduct of the Defendant, Stephen A. Skinner, as set forth in the Plaintiff's Complaint. 10. ? The allegations of Paragraph 27 of the Defendant's New Matter amount to legal conclusions to which no response is required. To the extent a response is deemed necessary, Paragraph 27 of the Defendant's New Matter is specifically denied. None of the affirmative defenses raised by the Defendant are applicable and should be sthick as a matter of law. 11. ? The allegations of Paragraph 28 of the Defendant's New Matter amount to legal conclusions to which no response is required. 12. The allegations of Paragraph 29 of the Defendant's New Matter are specifically denied. To the contrary, it is averred that the Plaintiff sustained permanent injuries as set forth in the Plaintiff's Complaint and which will be by documents produced during the discovery process. 13. conclusion! The allegations of Paragraph 30 of the Defendant's New Matter are legal which no response is required. To the extent a response is deemed necessary, aid averments are specifically denied. To the contrary, at all times relevant he eto, the Plaintiff, Ralph C. Crone, acted in a careful, cautious, and reasonable manner. 14. The allegations of Paragraph 31 of the Defendant's New Matter are specifically enied. To the contrary, the Plaintiff has mitigated his damages to the extent Dossible. 15. ? The allegations of Paragraph 32 of the Defendant's New Matter amount to legal con lusions to which no response is required. However, insofar as a response is deemed ecessary, Paragraph 32 is specifically denied. To the contrary, it is averred that) the sole and proximate cause of the Plaintiff's injuries and damages as set forth in :ephen is Complaint was the negligent, reckless, and careless conduct of the Defendant, A. Skinner. RE, the Plaintiff, Ralph C. Crone, respectfully requests that the New Matter pled y the Defendant, Stephen A. Skinner, be dismissed and that judgment be entered in hi favor plus costs of suit as sustained. Respectfully submitted, Conlon T ker, P.C. Raymond J. C to , quire Attorney for Plaintiff VERIFICATION I, RA(PH C. CRONE, have read the foregoing REPLY TO NEW MATTER. The statements therein are correct to the best of my personal knowledge, information and belief. This statement and verification are made subject to the penalties of 18 Pa.C.S.A. §4004 relating to unsworn falsification to authorities, which provides that if I make know'ngly false averments, I may be subject to criminal penalties. TE C. CRONE CERTIFICATE OF SERVICE I her by certify that a copy of the within document was served upon the iA- individual n med below on the day of April, 2008 by first class, U.S. mail, postage prepaid. Marc A. Moyer, Esquire Thomas, Thomas Et Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 Attorney for Defendant Conlon Tarker, P.C. ?? _ ' _ s^r?s ' ?' c? ?> _ ..? ?? t ' ?- i ? ? - rcj ? F _ c? Thomas, Thomas & Hafer, LLP Todd B. Narvel, Esquire Attorney I.D. No. 42136 Marc A. Moyer, Esquire Attorney I.D. No. 76434 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7133 - direct tnarvol@tthlaw.com (717) 441-3960 - direct mmoyer@tthlaw.com (717) 237-7105 - fax Anorneys for Defendant Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, V. STEPHEN A. SKINNER, Plaintiff Defendant NO. 07-2838 CIVIL TERM CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to the service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant Stephen A. Skinner certifies that: (a) a Notice of Intent to Serve Subpoenas with a copy of the subpoenas attached thereto was mailed or delivered to each party prior to the date on which the subpoenas are sought to be served, (b) a copy of the Notice of Intent, including the proposed subpoenas, is attached to this Certificate at Exhibit A, (c) the subpoenas which will be served are identical to the subpoenas attached to the Notice of Intent, (d) Plaintiff's counsel has waived the twenty day notice period. A copy of Plaintiff's counsel's April 18, 2008 correspondence is attached at Exhibit B. Respectfully submitted, MariY . yer, Esquire Attoo.76434 THO S, THOMAS & HAFER LLP 305 rth Front Street, 6th Floor Post Office Box 999 Harrisburg, PA 17108 717-441-3960 mmoyer@tthlaw.com Dated: April 21, 2008 Counsel for Defendant Stephen A. Skinner Exhibit A Thomas, Thomas & Hafer, LLP Todd B. Narvol, Esquire Attorney I.D. No. 42136 Marc A. Moyer, Esquire Attorney I.D. No. 76434 305 N. Front Street P.U. Boa 999 Harrisburg, PA 17105-0999 (717) 237-7133 - direct marvol@rthlaw.com (717) 441-3960 - direct mmover@tthlavr.com (717) 237-7105 - fax Attorneys for Defendan! Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff v. STEPHEN A. SKINNER, Defendant NO. 07-2838 CIVIL TERM NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant Stephen A. Skinner, intends to serve subpoenas identical to the ones attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objection is made the subpoenas may be served. Respectfully submitted, ?r?e Q /?o Marc A. Moyer, Wsquitie Attorney No. 76434 THOMAS, THOMAS & HAFER LLP 305 North Front Street, 6th Floor Post Office Box 999 Harrisburg, PA 17108 717-441-3960 mmoyer@tthlaw.com Dated: April Il , 2008 Counsel for Defendant Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Spinal Imaging, Inc., P.O. Box 1200, South Easton, MA 02375 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regardinyRalph C Crone, DOB: 12/13/1958, SS# 209-52-6366 including but not limited to any and all medical records, in patient and out patient testing histories and physicals progress reports physician orders, consultations diagnostic studies MRI files x-rays reports etc at: Thomas, Thomas & Hafer, LLP, 305 N. Front St. P.O. Box 999, Harrisburg PA 17108. 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Central Pennsylvania MRI Center, 4665 Trindle Road, Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C Crone, DOB: 12/13/1958, SS# 209-52-6366 including but not limited to any and all medical records in patient and out patient testing histories and physicals, progress reports physician orders, consultations diagnostic studies MRI files x-rays reports etc at: Thomas, Thomas & Hafer, LLP, 305 N. Front St. P.O. Box 999, Harrisburg PA 17108. You may deliver or snail 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Herd Chiropractic Clinic, 2704 Market Street, Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C. Crone, DOB: 12/13/1958, SS# 209-52-6366 , including but not limited to any and all medical records in patient and out patient testing histories and physicals progress reports physician orders, consultations, diagnostic studies, MRI files, x-rays reports etc. at: Thomas, Thomas & Hafer, LLP, 305 N. Front St., P.O. Box 999, Harrisburg PA 17108. 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Grandview Suraical Center, 205 Grandview Avenue, Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file re ag rdiny, Ralph C. Crone, DOB: 12/13/1958, SS# 209-52-6366, including but not limited to any and all medical records in patient and out patient testing histories and physicals, progress reports, physician orders consultations, diagnostic studies, MRI files, x-rays, reports, etc. at: Thomas, Thomas & Hafer LLP 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108. 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. : CIVIL TERM STEPHEN A. SKINNER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Riverside Anesthesia Associates, 4999 Louise Drive, Suite 105, Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C. Crone, DOB: 12/13/1958, SS# 209-52-6366 including but not limited to any and all medical records in patient and out patient testing histories and physicals, progress reports, physician orders consultations diagnostic studies MRI files x-rays, reports, etc. at: Thomas, Thomas & Hafer LLP 305 N. Front St. P.O. Box 999, Harrisburg, PA 17108. 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL "PERM STEPHEN A. SKINNER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Quantum Imaging, 2527 Cranberry Highway, Warsham, MA 02571 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C. Crone, DOB: 12/13/1958, SS# 209-52-6366 including but not limited to any and all medical records in patient and out patient testing histories and physicals, progress reports, physician orders consultations diagnostic studies MRI files x-rays reports etc at: Thomas, Thomas & Hafer LLP 305 N. Front St. P.O. Box 999, Harrisburiz, PA 17108. 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. Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Harrisburg Hospital, 111 South Front Street, Harrisburg, PA 17101 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C. Crone, DOB: 12/13/1958, SS# 209-52-6366, including but not limited to any and all medical records in patient and out patient testing histories and physicals progress reports physician orders consultations diagnostic studies, MRI files, x-rays, reports, etc. at: Thomas, Thomas & Hafer LLP 305 N Front St P.O. Box 999, Harrisburg, PA 17108. 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 havethe 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 cowl order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Orthopedic Institute of Pennsylvania, 450 Powers Avenue, Harrisburg, PA 17109 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C. Crone, DOB: 12/13/1958, SS# 209-52-6366, from November, 2007, through the present, including but not limited to any and all medical records in patient and out patient testing, histories and vhvsicals, progress reports physician orders consultations diagnostic studies MRI files, x-rays, resorts, etc. at: Thomas Thomas & Hafer LLP 305 N. Front St. P.O. Box 999 Harrisburg, PA 17108. 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Mechanicsburg Family Practice, 122 S. Filbert Street, Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the complete copy of the medical file regarding Ralph C. Crone, DOB: 12/13/1958, SS# 209-52-6366, from October 2007 through the present, including but not limited to any and all medical records, in patient and out patient testing, histories and physicals progress reports,, physician orders consultations diagnostic studies, MRI files, x-rays, reports, etc, at: Thomas Thomas & Hafer LLP, 305 N. Front St., P.O. Box 999, Harrisburg, PA 17108. 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: Marc A. Moyer, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7133 SUPREME COURT ID#: 76434 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE On this ??day of April 2008, 1. Kristine Hendrix, a paralegal, with the law firm Thomas, Thomas & Hafer, LLP, hereby certify that I have, this day, served a true and correct copy of the NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 upon the person(s) and at the address(es) below named via Facsimile and United States First Class Mail, postage prepaid, in Harrisburg, PA: Raymond J. Conlon, Esquire Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 Counsel for Plaintiff ?lL. r?o Kristine Hendrix 584519.1 Exhibit B CoNLoN TARKER h?i ?JCCl?lnll•.r .li.): ??.TUI711?C5. April 18, 2008 VIA FACSIMILE ONLY 717.237.7105 Marc A. Moyer, Esquire Thomas, Thomas Et Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 RE: Ralph C. Crone v. Stephen A. Skinner No. 07-2838 Civil Term Dear Mr. Moyer: I waive the 20 day notice requirement for the subpoenas. Please produce complete copies of all documents you obtain by using the subpoenas. RJC/mar Cn,,4 l,o., T:?u.KiR, P. C;. Cour_sd for 11ainuffs 108 East Mirnond Su"L Buda, Pennsylvania 16001 phone: 724.285.7700 fax 724.285.6700 CERTIFICATE OF SERVICE On this 21St say of April 2008, I, Kristine Hendrix, a paralegal, with the law firm Thomas, Thomas & Hafer, LLP, hereby certify that I have, this day, served a true and correct copy of the CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 upon the person(s) and at the address(es) below named via United States First Class Mail, postage prepaid, in Harrisburg, PA: Raymond J. Conlon, Esquire Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 Counsel for Plaintiff Kristine Hendrix 586521.1 _._; ?. i ^ ?`--' r.. _? ?. .. ' ; F..J ';:1 Thomas, Thomas & Hafer, LLP Todd B. Narvol, Esquire Attorney I.D. No. 42136 Marc A. Moyer, Esquire Attorney I.D. No. 76434 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7133 - direct tnarvol@tthlaw.com (717) 441-3960 - direct mmoyer@tthlaw.com (717) 237-7105 - fax Attorneys for Defendant Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff NO. 07-2838 V. CIVIL TERM STEPHEN A. SKINNER, Defendant MOTION OF DEFENDANT STEPHEN A. SKINNER TO MAKE RULE ABSOLUTE AND NOW, comes Defendant Stephen A. Skinner, by and through his counsel, Thomas, Thomas & Hafer, LLP, to hereby file this Motion to Make Rule Absolute and in support thereof, avers as follows: 1. Plaintiff Ralph C. Crone initiated this matter on May 10, 2007, following his involvement in an automobile accident with Defendant Stephen A. Skinner which occurred on or about July 5, 2005. 2. On or about March 11, 2008, Defendant Stephen A. Skinner filed a Motion to Compel Plaintiff's Responses to Defendant's Interrogatories and Request for Production of Documents. 3. On or about March 17, 2008, the Honorable J. Wesley Oler, Jr., of this Honorable Court issued an Order compelling Plaintiff to Show Cause why Defendant's Motion should not be granted. A copy of the Order is attached hereto as Exhibit "A". 4. On or about March 18, 2008, Plaintiff s counsel produced documents purportedly responsive to document Request Nos. 12 and 13 and copies of Plaintiff s tax returns for the years 2000 through 2006. Plaintiff also served undersigned counsel with Answers to Defendant's first and second set of Interrogatories on that date. 5. On or about March 26, 2008, Plaintiff s counsel requested by correspondence that Defendant withdraw his Motion to Compel. A copy of counsel's March 26, 2008 correspondence is attached hereto as Exhibit "B". 6. On or about March 31, 2008, undersigned counsel wrote to Plaintiffs counsel in response to his counsel's March 26, 2008 correspondence. As set forth in that correspondence, undersigned counsel has not received formal replies to the individual document requests set forth in Defendant's Requests for Production of Documents but instead, has only been provided various documents which, to date, has required defense counsel to speculate as to which documents requests the documents pertain. A copy of undersigned counsel's March 31, 2008 correspondence is attached hereto as Exhibit "C". 7. Undersigned counsel further informed Plaintiff s counsel that it does appear that Defendant has been provided documents responsive to Requests Nos. 20, 21, 22, 23, 24 and 27. 8. Undersigned counsel's March 31, 2008 correspondence further alerted Plaintiff's counsel to the fact that Plaintiff's Answers to Interrogatories (Set II) merely identified the name of Plaintiff s family physician in response to the Interrogatory which sought the names and addresses of all hospitals/healthcare providers for which Plaintiff has been a patient or received treatment within the seven (7) years proceeding the accident. 9. Plaintiff's Answer to Interrogatory No. 10 (Set I) indicates that he suffered an injury to his back and neck in the course of his employment with Hall's Motor Transit in 1982, and underwent additional medical treatment. 10. For that reason, undersigned counsel once again asked that Plaintiff identify the healthcare providers, if any, who provided him with care and treatment for his injuries as requested in Defendant's Second Set of Interrogatories. Undersigned counsel further informed Plaintiff's counsel of the lack of responsiveness by Plaintiff to Defendant's Interrogatories (Set 1). WHEREFORE, Defendant Stephen A. Skinner respectfully requests that the Court enter an Order making its March 17, 2008 Rule absolute and compel Plaintiff's production, without objection, of documents responsive to Defendant's document request Nos. 20, 21, 22, 23, 24 and 27, compel Plaintiff to fully respond to Defendant's Interrogatories (Set II) by providing the names and addresses of all hospitals/healthcare providers for which Plaintiff has been a patient or received treatment within the seven (7) years proceeding the accident. Defendant further requests that the Court compel Plaintiff to answer, without objection, Defendant's Interrogatories (Set I) by identifying the photographs and videos taken of Plaintiff performing or instructing Martial Arts from July 5, 2000 to present, identify or produce the photographs and/or videos, identifying the persons whom he believes took the photographs and/or videos, and provide the names, addresses and telephone numbers of individuals who received Martial Arts instruction or training from the Plaintiff from July 5, 2000 to the present. THOMAS, THOMAS & HAFER, LLP By: w " odd B. &ol, Esquire Attorne D. No. 42136 Marc . Moyer, Esquire Att o ey I.D. No. 76434 305 North Front Street, 6th Floor P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7100 Attorneys for Defendant Stephen A. Skinner M.0.d ioe®0319A?3tl S3a3S 00006 . , RALPH C. CRONE, Plaintiff V. STEPHEN A. SKINNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2838 CIVIL TERM ORDER OF COURT AND NOW, this 17`h day of March, 2008, upon consideration of the Motion of Defendant Stephen A. Skinner To Compel Plaintiff's Responses to Discovery, a Rule is hereby issued upon Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Raymond J. Conlon, Esq. 108 East Diamond Street Butler, PA 16001 Attorney for Plaintiff Todd B. Narvol, Esq. arc A. Moyer, Esq. 21A North Front Street 6ch Floor P.O. Box 999 Harrisburg, PA 17108 Attorneys for Defendant J,fWesley Qler Jr.,, :rc M J d %a0S L031?A93d S3Ri3S 00006 ral CONLONTARKEx I'cr10111<ulcc:• Noi I'rc»nisrs. March 26, 2008 VIA FACSIMILE 717.237.7105 AND MAIL Marc A. Moyer, Esquire Thomas, Thomas Et Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 RE: Ralph C. Crone v. Stephen A. Skinner No. 07-2838 Civil Term Dear Mr. Moyer: I have received the Court's Order of March 17, 2008 issuing a rule to show cause relative to your motion to compel. I trust that by now you have received the discovery responses forwarded to you by letters dated March 18, 2008. Would you please advise if you will be withdrawing your motion to compel? Thank you for your attention to this matter. Very truly yours, Raym nd . Conlon RJC/mar x'tv??'.cunloutarlic'r.cutu (,ONL Nv TAR10:,1t, PA' Counsel for Plaintiffs 108 East Diamond Street Butler, Pennsylvania 16001 phone: 724.285.7700 fax; 724.285.6700 M 0 d cos S31H3S 00006 THOMAS, THOMAS & HAFER LLP ATTORNEYS AT LAW Mailing Address: P.O. Box 999, Harrisburg, PA 17108 Street Address: 305 North Front Street, Harrisburg, PA 17101 Phone:.(717) 237-7100 Fax: (717) 237-7105 March 31, 2008 Raymond J. Conlon, Esquire Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 Re: Ralph C. Crone v. Stephen A. Skinner Docket No.: 07-2838 - CIVIL TERM Dear Mr. Conlon: www.ttldaw.com Marc A. Moyer (717)441-3960 nimoyer@tthlam,.com Please note that I am in receipt of your March 26, 2008 correspondence inquiring into whether we will be withdrawing our Motion to Compel Plaintiff's Discovery Responses. Upon our review of the file, it appears as though we have never received formal Replies to the individual document requests set forth in Defendant's Requests for Production of Documents. Instead, we have only been provided various documents which, to date, has required us to speculate as to which document request the documents pertain. Moreover, it does not appear that we have been provided documents responsive to Request Nos. 20, 21, 22, 23, 24, or 27. With respect to Plaintiffs Answers to Interrogatories (Set II), Plaintiff was asked to provide the names and addresses of all hospitals/healthcare providers for which Plaintiff has been a patient or received treatment within the seven (7) years preceding the accident. Plaintiff s response was to merely provide the name of his family physician. Please note that Plaintiff s Answer to Interrogatory No. 10 (Set I) indicates that he suffered an injury to his back and neck in the course of his employment with Hall's Motor Transit in 1982. He further indicated that he underwent treatment with Dr. David Joiner. However, Plaintiff did not provide any contact information for Dr. Joiner. Plaintiff also indicated that due to the nature of his employment as a professional Tae Kwon Do artist and teacher, he has suffered previous injuries to his neck and back for which he has sought chiropractic treatment. Once again however, Plaintiff has not identified the healthcare providers, if any, who provided him with care and treatment for those injuries. Bethlehem Office • 3400 Bath Pike, Suite 302, Bethlehem, PA 18017 • Phone: (610) 868-1675 • Fax: (610) 868-1702 Pittsburgh Office • 301 Grant Street, Suite 1150, Pittsburgh, PA 15219 • Phone: (412) 697-7403 + Fax: (412) 697-7407 Baltimore Office • Six East Mulberry Street, Baltimore, MD 21202 • Phone: (410) 752-0075 • Fax: (410) 752-4744 Raymond J. Conlon, Esquire March 31, 2008 Page 2 Plaintiff has not responded to other Interrogatories (Set 1). Specifically, Plaintiff has indicated that he believes photographs and videos were taken of him performing or instructing martial arts from July 5, 2000 to the present. However, Plaintiff has failed to identit, or produce the photographs and/or videos and has similarly failed to identify the persons whom he believes took the photographs and videos. Similarly, Plaintiff has refused to provide the names, addresses and telephone numbers of all individuals who received martial arts instruction or training from the Plaintiff from July 5, 2000 to the present. To that end, we disagree with Plaintiff's contention that such information is not reasonably likely to lead to the discovery of admissible evidence. Although Plaintiff has responded to Interrogatory No. 34, in part, by providing a list of the styles of martial arts and self-defense for which he provided instruction and training from July 5, 2000 to present, he has not provided information pertaining to the time periods for which such instruction or training was provided, as requested through the Interrogatory. Because the foregoing documents and information are discoverable and are important to Defendant's ability to sufficiently depose Mr. Crone, we are unfortunately not able to withdraw our Motion to Compel to Discovery at this time. Thank you for your attention to this matter. MAM/j ld:s 1 4246.1 1 Very truly yours, iarc . M CERTIFICATE OF SERVICE On this 1St day of May 2008, I, Jennifer L. Deitch, a legal secretary, with the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I have, this day, served a true and correct copy of the DEFENDANT STEPHEN A. SKINNER MOTION TO MAKE RULE ABSOLUTE upon the person(s) and at the address(es) below named via United States First Class Mail, postage prepaid, in Harrisburg, PA: Raymond J. Conlon, Esquire Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 Counsel for Plaintiff Je fer L. 59tch 589000.1 ?._ h?_a I '?` _ _ , ? i C'`J Thomas, Thomas & Hafer, LLP Todd B. Narvol, Esquire Attorney I.D. No. 42136 Marc A. Moyer, Esquire Attorney I.D. No. 76434 305 N. Front Street P.O. Box 999 Harrisburg, PA 17108-0999 (717) 237-7133 - direct tnarvol@tthlaw.com (717) 441-3960 - direct mmoyer@tthlaw.com (717) 237-7105 - fax Attorneys for Defendant Stephen A. Skinner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, V. STEPHEN A. SKINNER, Plaintiff NO.07-283 8 CIVIL TERM Defendant A ORDER AND NOW, this 4 day of , 2008, upon consideration of Defendant's Motion to Make the Court's March 17, 2008 Rule absolute, an Order is entered as follows: I. Plaintiff is ordered to produce within twenty (20) days of the date of this Order, any and all documents responsive to Defendant's Request for Production of Documents Numbers 20, 21, 22, 23, 24 and 27, and that Plaintiff fully respond to Defendant's Interrogatories (Set II) by providing the names and addresses of all hospitals/healthcare providers for which Plaintiff has been a patient or received treatment wit in the seven (7) ye s proceeding th accidents o ?X ?c?' I s > S. 0? O? 2. Moreover, Plainti4 is hereby ordered to answer, without objection, Defendant's Interrogatories (Set I) by identifying the photographs and videos taken of Plaintiff performing and instructing Martial Arts from July 2000 to present, by identifying or producing the photographs and/or videos, identifying the person(s) whom he believes took the photographs and/or videos, and by providing the names, addresses and telephone numbers of individuals who received Martial Arts instruction or training from Plaintiff from Jul 5, 2000 to present t, ?,3 S L y ?y-0Y P I. C, \J BY THE COURT: J. o ? Ib1Q NO ; fir dc# 3HI :to IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, No. 07-2838 Civil Term Plaintiff, VS. STEPHEN A. SKINNER, Defendant. NOTICE OF SERVICE OF PLAINTIFF'S DISCOVERY RESPONSES Filed on behalf of Plaintiff Counsel of record for this party: Raymond J. Conlon, Esquire PA I. D. # 49495 conton@contontarker.com Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 724.285.7700 724.285.6700 fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, No. 07-2838 Civil Term Plaintiff, VS. STEPHEN A. SKINNER, Defendant. NOTICE OF SERVICE OF PLAINTIFF'S DISCOVERY RESPONSES TO: Curtis R. Long, Prothonotary I hereby certify that the Answers to the Third Set of Interrogatories of Defendant Stephen A. Skinner Directed to Plaintiff Ralph C. Crone were served upon counsel for the Defendant, Marc A. Moyer, Thomas, Thomas Ft Hafer, LLP, at P.O. Box 999, Harrisburg, PA 17108, by first class, U.S. mail, postage prepaid, on the _jk?- day of August, 2008. Respectfully submitted, Conlon Tarker, P.C. • „ - CERTIFICATE OF SERVICE I hereby certify that a copy of the within document was served upon counsel named below on the ? day of August, 2008 by first class, U.S. mail, postage prepaid. Marc A. Moyer, Esquire Thomas, Thomas Et Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 Attorney for Defendant Conlon Tarker, P.C. on J. 0m lok, Esquire v fork Plaintiff C [ C- Y'? W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff, No. 07-2838 Civil Term VS. PRAECIPE TO SETTLE, END, AND DISCONTINUE STEPHEN A. SKINNER, Defendant. Filed on behalf of Plaintiff Counsel of record for this party: Raymond J. Conlon, Esquire PA 1. D. # 49495 conlon@conlontarker.com Conlon Tarker, P.C. 108 East Diamond Street Butler, PA 16001 724.285.7700 724.285.6700 fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION RALPH C. CRONE, Plaintiff, VS. STEPHEN A. SKINNER, Defendant. No. 07-2838 Civil Term PRAECIPE TO SETTLE, END, AND DISCONTINUE TO: Curtis R. Long, Prothonotary Please mark the docket in the above-captioned matter as settled, ended, and discontinued. Respectfully submitted, Conlon TAr-kr, P.C. Raymo Attorni CERTIFICATE OF SERVICE I hereby certify that ja copy of the within document was served upon counsel named below on the day of December, 2008 by first class, U.S. mail, postage prepaid. Marc A. Moyer, Esquire Thomas, Thomas Ft Hafer, LLP P.O. Box 999 Harrisburg, PA 17108 Attorney for Defendant Conlon Tarker, P.C. c.' ? - :?° ?r? `a J a.., C . ? ..s. ;?;?- ?? ?.? . ;? s` 1"?3 ? Tom .? cz: