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Home My WebLink About07-3609ANGINO & ROVNER, P.C. Richard A. Sadlock Esquire Attorney ID# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 Phone: (717) 238-6791 Fax: (717) 238-5610 Attorneys for Plaintiffs: E-mail: rsadlockna aneino-rovner com Rhonda and R. Timothy Reinford RHONDA L. REINFORD and R. TIMOTHY REINFORD, her husband, Plaintiffs V. VALERIE LAIR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07 (2t u t. c? JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se persentan mas adelante en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a , las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamaci6n o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Used puede perder dinero o propiedad u otros derechos importantes para used. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 ANGINO & ROVNER, P.C. Richard A. Sadlock Esquire Attorney ID# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 Phone: (717) 238-6791 Fax: (717) 238-5610 Attorneys for Plaintiffs: E-mail: rsadlock(aan¢ino-rovner com Rhonda and R. Timothy Reinford RHONDA L. REINFORD and R. TIMOTHY REINFORD, her husband, Plaintiffs V. VALERIE LAIR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. D 7.3& 0 ? 6 'j JURY TRIAL DEMANDED COMPLAINT 1. Plaintiffs Rhonda L. Reinford and R. Timothy Reinford are adult individuals, citizens of the Commonwealth of Pennsylvania, who reside at 227 Walton Street, Lemoyne, Cumberland County, Pennsylvania. 2. Defendant Valerie Lair is an adult individual, citizen of the Commonwealth of Pennsylvania, who resides at 1490 Brandt Avenue, New Cumberland, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on Saturday, October 22, 2005, at approximately 8:39 p.m., at the intersection of South 3`d Street and Walton Street in the Borough of Lemoyne, Cumberland County, Pennsylvania. 4. At that time and place, Plaintiff Rhonda L. Reinford was a front seat passenger in the 1998 Chevrolet Silverado that was pulling a Terry Camper operated by her husband, R. Timothy Reinford. 5. At that time and place, Plaintiff Rhonda L. Reinford was a passenger in a vehicle that was traveling south on South 3`d Street in Lemoyne attempting to turn left onto Walton Street. 6. At that time and place, Defendant Valerie Lair was operating a 2001 Mazda Tribute LX and was traveling south on South 3`d Street directly behind Plaintiffs. 7. At that time and place, Defendant Valerie Lair operated her vehicle at a high rate of speed without paying attention to traffic and, suddenly and without warning, rammed the back of the Terry Camper Plaintiffs were pulling and then violently slammed into the driver's side door of the vehicle in which Plaintiff Rhonda Reinford was a passenger. 8. Defendant Valerie Lair was extremely intoxicated when she allowed her vehicle to strike Plaintiffs' vehicle. 9. Defendant Valerie Lair knew or should have know that operating a motor vehicle while extremely intoxicated would endanger other persons on the roadway. 10. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiffs Rhonda L. Reinford and R. Timothy Reinford are the direct and proximate 353005 2 result of the negligent, careless, wanton and reckless manner in which Defendant Valerie Lair operated her vehicle as follows: (a) failure to have her vehicle under such control as to be able to stop within the assured clear distance ahead; (b) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (c) failure to travel at a safe speed; (d) failure to apply her brakes in sufficient time to avoid striking the vehicle; (e) failure to take reasonable evasive action to avoid the accident; (f) failure to drive her vehicle with due regard for the highway and traffic conditions which were existing and of which she was or should have been aware; (g) failure to keep proper and adequate control over her vehicle; (h) driving the vehicle while intoxicated or otherwise impaired; and (i) driving her vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. CLAIM I RHONDA L. REINFORD v. VALERIE LAIR 11. Paragraphs 1 through 10 of Plaintiffs' Complaint are incorporated herein by reference. 353005 3 12. Plaintiff Rhonda L. Reinford sustained painful and severe injuries which include but are not limited to neck pain with tingling into arms, pain between shoulder blades, low back pain with pain radiating into the left leg and a herniated nucleus pulposus at L4-5. 13. By reason of the aforesaid injuries sustained by Plaintiff Rhonda L. Reinford, she was forced to incur liability for medical treatment, medications, hospitalizations and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 14. Because of the nature of her injuries, Plaintiff Rhonda L. Reinford has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 15. As a result of the aforementioned injuries, Plaintiff Rhonda L. Reinford has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 16. As a result of the aforementioned collision and resulting injuries, Plaintiff Rhonda L. Reinford has been and in the future will be subject to great humiliation and embarrassment, and claim is made therefor. 17. As a result of the aforementioned injuries, Plaintiff Rhonda L. Reinford has sustained work loss, loss of opportunity and a permanent diminution of her earning power and capacity, and claim is made therefor. 16. As a result of the aforementioned collision and resulting injuries, Plaintiff Rhonda L. Reinford has sustained uncompensated work loss, and claim is made therefor. 353005 4 17. As a result of the aforementioned collision and resulting injuries, Plaintiff Rhonda L. Reinford continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefor. CLAIM II R. TIMOTHY REINFORD v. VALERIE LAIR 18. Paragraphs 1 through 17 of Plaintiffs' Complaint are incorporated herein by reference. 19. As a result of the aforementioned injuries sustained by his wife, Plaintiff Rhonda L. Reinford, Plaintiff R. Timothy Reinford has been and may in the future be deprived of the care, companionship, consortium, and society of his wife, all of which will be to him great detriment, and claim is made therefor. CLAIM III RHONDA L. REINFORD AND R. TIMOTHY REINFORD v. VALERIE LAIR 20. Paragraphs 1 through 19 of Plaintiffs' Complaint are incorporated herein by reference. 21. Before the subject motor vehicle accident, Defendant Valerie Lair consumed alcoholic beverages, or other drugs, which caused her to become intoxicated. 353005 5 22. Defendant Valerie Lair while impaired and under the influence of drugs and/or alcohol drove her vehicle at an excessive rate of speed, well in excess of the posted speed limit. 23. After consuming alcoholic beverages, or other drugs, Defendant Valerie Lair knew or should have known that she was severely intoxicated and unable to safely operate a motor vehicle. 24. Defendant Valerie Lair knew or should have known that her operation of a motor vehicle while intoxicated constituted outrageous conduct and a reckless indifference to the rights of others on the highway. 25. Defendant Valerie Lair's direct collision with Plaintiffs' vehicle displayed willful, negligent and reckless indifference towards the rights of others on the highway. 26. Defendant Valerie Lair's conduct constitutes wanton and willful negligence, is outrageous and entitles Plaintiffs to an award of punitive damages WHEREFORE, Plaintiffs Rhonda L. Reinford and R. Timothy Reinford demand judgment against Defendant Valerie Lair in an amount in excess of Fifty Thousand Dollars ($50,000.00), exclusive of interest and costs, and in excess of any jurisdictional amount requiring compulsory arbitration. Date: June 15, 2007 ANGINO2& ROVE . LIT N e 7281 450 Front St et H ?isburg, P 17110 17) 238- 91 for Plaintiffs 353005 6 VERIFICATION We, RHONDA L. REINFORD and R. TIMOTHY REINFORD Plaintiffs, have read the foregoing PLAINTIFFS' COMPLAINT and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of our knowledge, information and belief. We understand that this Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unworn falsification to authorities. 354576 Dated: i !? "-F C") t-_ N OD tra 'T 1 (i1T! =i '-C top IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and R. TIMOTHY REINFORD, Plaintiffs V. VALERIE LAIR, Defendant NO. 07-3609 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE PURSUANT TO PA.R.C.P. 1012 TO THE PROTHONOTARY: Kindly enter the appearance of Michael B. Scheib, Esquire, of Griffith, Strickler, Lerman, Solymos & Calkins, as attorney for the Defendant, Valerie Lair, in the above-captioned matter and mark the docket accordingly. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS Date: July 6, 2007 By: Supreme Court I.D. No. 63868 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Valerie Lair IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and NO. 07-3609 CIVIL TERM R. TIMOTHY REINFORD, Plaintiffs V. CIVIL ACTION - LAW VALERIE LAIR, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 6th day of July, 2007, I, Michael B. Scheib, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the Praecipe for Entry of Appearance Pursuant to Pa. R.C.P. 1012, by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CA INS By. 73 MICHAEL B. SCHEIB, ESQUIRE Supreme Court I.D. No. 63868 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Valerie Lair .? co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and NO. 07-3609 CIVIL TERM R. TIMOTHY REINFORD, Plaintiffs V. CIVIL ACTION - LAW VALERIE LAIR, : Defendant JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Rhonda L. Reinford and R. Timothy Reinford c/o Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Date: July 2007 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: MICHAEL B. SCHEIB, ESQUIRE Supreme Court I.D. No. 63868 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Valerie Lair IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and R. TIMOTHY REINFORD, Plaintiffs V. NO. 07-3609 CIVIL TERM CIVIL ACTION - LAW VALERIE LAIR, Defendant JURY TRIAL DEMANDED ANSWER WITH NEW MATTER AND NOW, this day of July, 2007, comes the Defendant, Valerie Lair, by and through her attorneys, Michael B. Scheib, Esquire, and Griffith, Strickler, Lerman, Solymos & Calkins, and responds to the allegations in Plaintiffs' Complaint as follows: 1. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph I of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted in part and denied in part. It is admitted that the Plaintiff was a passenger in a vehicle traveling south on South Third Street. The remaining allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 5 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 6. Admitted. 7. Admitted in part and denied in part. It is admitted that Defendant's vehicle came into contact with the camper and with the Reinford vehicle. The remaining allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 7 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 8. Denied. This paragraph states a legal conclusion to which no response is required. 9. Denied. This paragraph states a legal conclusion to which no response is required. 10. Denied. This paragraph states a legal conclusion to which no response is required. CLAIM I RHONDA L. REINFORD v. VALERIE LAIR 11. Paragraphs 1 through 10 of Defendant's Answer With New Matter are incorporated herein as though fully set forth at length. 12. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the factual allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 12 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 13. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the factual allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a 2 belief as to the truth of the allegations set forth in paragraph 13 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 14. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the factual allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 14 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 15. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the factual allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 15 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 16. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the factual allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 16 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 17. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the factual allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 17 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 3 16. [sic] Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the factual allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 16 [sic] of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. 17. [sic] Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the factual allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 17 [sic] of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. CLAIM II R. TIMOTHY REINFORD v. VALERIE LAIR 18. Paragraphs 1 through 17 of Defendant's Answer With New Matter are incorporated herein as though fully set forth at length. 19. Denied. This paragraph states a legal conclusion to which no response is required. To the extent a response is required, the factual allegations are denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations set forth in paragraph 19 of Plaintiffs' Complaint, and the same are denied and strict proof thereof is demanded. CLAIM III RHONDA L. REINFORD AND R. TIMOTHY REINFORD v. VALERIE LAIR 20. Paragraphs 1 through 19 of Defendant's Answer With New Matter are incorporated herein as though fully set forth at length. 4 21. Admitted in part and denied in part. Defendant admits that she consumed alcoholic beverages. The remaining allegations state a legal conclusion to which no response is required and are thus denied. 22. Denied. This paragraph states a legal conclusion to which no response is required. 23. Denied. This paragraph states a legal conclusion to which no response is required. 24. Denied. This paragraph states a legal conclusion to which no response is required. 25. Denied. This paragraph states a legal conclusion to which no response is required. 26. Denied. This paragraph states a legal conclusion to which no response is required. WHEREFORE, Defendant, Valerie Lair, respectfully requests this Honorable Court to enter judgment in her favor, together with the cost of the lawsuit. BY WAY OF FURTHER DEFENSE: NEW MATTER 27. Paragraphs 1 through 26 of Defendant's Answer With New Matter are incorporated herein as though fully set forth at length. 28. Plaintiffs injuries, if any, may be barred or limited by the Motor Vehicle Financial Responsibility Law. 29. Plaintiff s injuries, if any, may be barred or limited by a limited tort selection. 30. Plaintiff's injuries, if any, were caused by the acts or omissions of a third party over whom Defendant had no control. 5 31. Plaintiff's injuries, if any, were caused by events which either predated or postdated the motor vehicle accident which is the subject of this lawsuit. 32. Plaintiffs damages were caused by her own conduct. 33. The claim of Plaintiff R. Timothy Reinford is barred by the doctrines of release and accord and satisfaction. 34. The claim of Plaintiff R. Timothy Reinford is barred by the doctrine of settlement. 35. Plaintiff R. Timothy Reinford has signed a release. WHEREFORE, Defendant, Valerie Lair, respectfully requests this Honorable Court to enter judgment in her favor, together with costs of this lawsuit. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS i Date: July , 2007 By: MI H EL B. HEIB, ESQUIRE Supreme Court I.D. No. 63868 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Valerie Lair 6 VERIFICATION I, Valerie Lair, hereby verify that the statements made in the foregoing Answer with New Matter to Plaintiffs' Complaint are true and correct to the best of my personal knowledge or information and belief, as well as reports, records, conferences and other investigatory material made available to me. To the extent that the foregoing contains averments which are inconsistent in fact, I verify that my knowledge or information is sufficient to form a belief that one or more of them is true, although I am currently unable, after reasonable investigation, to ascertain which of the inconsistent averments are true. To the extent that the foregoing contains legal conclusions or opinions, I hereby state that my Verification is made upon the advice of counsel, upon whom I have relied in the filing this document. This Verification is made subject to the penalties of 18 Pa.C.S. § 4904 related to unsworn falsifications to authorities. Lot Date: , 2007 Valerie Lair IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and R. TIMOTHY REINFORD, Plaintiffs V. VALERIE LAIR, Defendant NO. 07-3609 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this /.? `?? day of July, 2007, I, Michael B. Scheib, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the Answer with New Matter, by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS B " Y• MICHAEL B. SCHEIB, ESQUIRE Supreme Court I.D. No. 63868 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Valerie Lair c l r_ °ctfl C'J SHERIFF'S RETURN - REGULAR CASE NO: 2007-03609 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REINFORD RHONDA L ET AL VS LAIR VALERIE MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE LAIR VALERIE was served upon the DEFENDANT , at 1810:00 HOURS, on the 20th day of June 2007 at 1490 BRANDT AVENUE NEW CUMBERLAND, PA 17070 VALERIE LAIR by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 16.32 Postage .41 Surcharge 10.00 n 00 4/ s1o7 ??" V44.73 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 06/21/2007 ANGINO & ROVNER By: Deputy S eriff of , A. D. ANGINO & ROVNER, P.C. Richard A. Sadlock Esquire Attorney ID# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 Phone: (717) 238-6791 Fax: (717) 238-5610 Attorneys for Plaintiffs: E-mail: rsadlock(&-anQino rovner com Rhonda and R. Timothy Reinford RHONDA L. REINFORD and R. TIMOTHY REINFORD, her husband, Plaintiffs V. VALERIE LAIR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3609 Civil Term JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO NEW MATTER OF DEFENDANT AND NOW come the Plaintiffs, by and through their attorneys, Angino & Rovner, P.C., and hereby enter the following Reply to the New Matter of Defendant as follows: 27. No response is necessary. 28. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, all of Plaintiffs' injuries and damages are recoverable in the instant action. The Pennsylvania Motor Vehicle Financial Responsibility Law in no way limits the damages Plaintiffs may recover herein. 29. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiffs claims are not limited. Plaintiffs have plead that Plaintiff Rhonda L. Reinford sustained a serious injury and scarring, resulting in a serious impairment of bodily function and permanent serious disfigurement. Further, as the instant Defendant was charged with DUI, pled guilty, and entered the ARD Program, the Plaintiffs are granted full tort status. 75 Pa.C.S.A. § 1705(d)(1)(i). Therefore, Plaintiffs' injuries and damages are recoverable in the instant action. 30. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, the acts and omissions of the Defendant do constitute negligence and were substantial causes and factors of the subject incident and did result in the injuries and losses sustained by the Plaintiffs. Further, Defendant's averment lacks the specificity required by the Pennsylvania Rules of Civil Procedure. All of Plaintiffs' injuries and damages were caused solely and directly as a result of the negligence, carelessness, wantonness and recklessness of the instant Defendant. 31. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, there were no events that predated or postdated the motor vehicle accident. All of Plaintiffs' injuries and damages were caused solely and directly as a result of the negligence, carelessness, wantonness and recklessness of the instant Defendant. 360078 32. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiff was not negligent in any way. All of Plaintiffs' injuries and damages were caused solely and directly as a result of the negligence, carelessness, wantonness and recklessness of the instant Defendant. 33. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiff R. Timothy Reinford's loss of consortium claim is not barred by the doctrines of release and accord and satisfaction. 34. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiff R. Timothy Reinford's loss of consortium claim is not barred by the doctrine of settlement. 35. It is admitted only that R. Timothy Reinford signed a release for his own injury claim. However, he did not release his derivative consortium claim. WHEREFORE, Plaintiffs respectfully request this Honorable Court to dismiss Defendant's Answer and New Matter and enter judgment in their favor against the Defendant. Date: July 20, 2007 ANGINO &_E4WNQLP.C. 4593?Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff 360078 COMMONWEALTH OF PENNSYLVANIA: . SS. COUNTY OF DAUPHIN 1, Richard A. Sadlock, Esquire, being duly sworn according to law, depose, and state that I am counsel for Plaintiffs Rhonda L. and R. Timothy Reinford, that I am authorized to make this Affidavit on behalf of said Plaintiffs, and that the facts set forth in the foregoing REPLY TO NEW MATTER OF DEFENDANT are true and correct to the best of my Sworn to and subscribed before me this 20th day of July, 2007. Notary Public aK a+?r? " 202811 a.,,,<, .,...,.,.?..? f ,a ?' ? ,... "".? !? ?Et9,JG T i i ?#?°? TS?i?;I ? r' 4?' x ` r(8? 1 CERTIFICATE OF SERVICE I, Marcy L. Brymesser, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFFS' REPLY TO NEW MATTER OF DEFENDANT on the following via postage prepaid, first class United States mail, addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402-3737 Date: July 20, 2007 360079 ?> _ ?, ti __ rr, ;., - .?_k- _ . `r _... ?J ??,^ agGINAL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-3609 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2007 I MCS on be al 1 .5/////i MICHAEL SCHEIB, ESQ 17 Attorney for DEFENDANT R1.39 133-H DE11-0705044 14524 -LO1 COMLVIOI`•TWEALTH OF PENNSYL?AN I A COUNT Y 001F C UMB E R LAN D IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, -VS- CASE NO: 07-3609 VALERIE LAIR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: RICHARD A. SADLOCK, ESQ.. PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07125/2007 CC: MICHAEL SCHEIB, ESQ. Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 105-N DE02-0369370 1 4 5 2 4- C 0 1 >>> LOCATION L I S T <<< PAGE LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE CO. HARRISBURG HOSPITAL PINNACLE WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING R1.35S 105-N DE02-0369370 11 4 5 2 4- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MUTUAL BENEFIT INSURANCE CO. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Group, Inc 1601 Market Stret. Suite 800 Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESO. ADDRESS: 110 S. NORTHERN WAY YORK. PA 1740 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant jWL AUG 14 2007 Date: Seal of the Court BY THE COURT: r thonotary/Clerk, Civil Di n Deputy 14524-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MUTUAL BENEFIT INSURANCE CO. 409 PENN STREET P.O. BOX 577 HUNTINGDON, PA 16652 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. POLICY #M0239328 Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 10-01-2005 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 Date of Loss: 10/22/2005 R1.35S 105-N SU10-0696932 3-4 524 -L O 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 OREM% IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2007 MCS i"f ""? on beh f f _ ?? CG MICHAEL SCHEIB, ESd. Attorney for DEFENDAN R1.39 133-H DE11-0705045 14524 -LO2 COIVIlVIONWEALTH OF PENNSYLVAN Ilk COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMvION PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, -VS- CASE NO: 07-3609 VALERIE LAIR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note. sec enclosed list of locations TO. RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/25/2007 CC: MICHAEL SCHEIB, ESQ. - Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 8800 PHILADELPHIA, PA 19103 (215) 246-0900 R1:35S 105-N DE02-0369370 1 4 5 2 4- C 0 1 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE CO. HARRISBURG HOSPITAL PINNACLE WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING 21.35S 105-N DE02-0369370 1 4 5 2 4- 4--0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG H05PIT er PINNACLE - (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc., 1601 Idarket Street, Suite 800, Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEM, ESQ. ADDRESS: 110 S. NORTHERN WAY YORK= PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant QU" 14 2001 Date: l1 y a0 Seal of the Court BY THE COURT: rothonotary/Clerk, Civil Di ' o Deputy 14524-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL PINNACLE 111 S. FRONT STREET HARRISBURG, PA 17101 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 10-01-2005 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.35S 105-N SUIO-0696934 1 4 5 2 4- L O 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGIN& IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2007 MCS on behalf j V? 14 MICHAEL SCHEIB, ESQ. / Attorney for DEFENDANT R1.39 133-H DE11-0705046 14524 -L03 COMMONWEALTH OF PENNSYLVANIA C UMB E R L AN D COUNT Y c 3p IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, -VS- CASE NO: 07-3609 VALERIE LAIR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ) TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/2512007 CC: MICHAEL SCHEIB, ESQ. - Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 105-N DE02-0369370 14524-4--01 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE CO. HARRISBURG HOSPITAL PINNACLE WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING tI.35S 105-N DE02-0369370 1 4 5 2 4- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND TO: RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR Custodian of Records for WILLIAM B BUSH- M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS G=W. Inc 1601 Market Street. Suite 800, Philadelphia, PA 1 103 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: MICHAEL SCHEIB. ESQ. ADDRESS: 110 S. NORTHERN WAY YORK. PA 4 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Au[ r' Seal of the Court BY THE COURT: .1f ' r thonotary/Clerk4Di Deputy 14524-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WILLIAM B. BUSH, M.D. 5100 LANCASTER STREET HARRISBURG, PA 17111 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from: 10-01-2005 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX XX-0329 Date of Birth: 06-23-1964 R1.35S 105-N SII10-0696936 1 4 5 2 4- 1,0 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGN04 40- IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2007 CS on behalf Ila" MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R1.39 133-H DE11-0705047 14 524 - L04 CONIlVIONWEALTH OF P ENN S YLVAN I A COUNT Y O F C UMB E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, -VS- CASE NO: 07-3609 VALERIE LAIR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 I Note: see enclosed list of locations TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/25/2007 CC: MICHAEL SCHEIB, ESQ. Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 it1.35S 105-N DE02-0369370 1 4 5 2 4- C 0 1 >>> LOCATION LIST <<< PAGE: LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE CO. HARRISBURG HOSPITAL PINNACLE WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING t1.35S 105-N DE02-0369370 1 4 S 2 4- 4-70 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARTMAN REHAB. ASSOCIATES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at _ The MCS Group. Inc.. 1601 Market Street Suite 800, Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESO. ADDRESS: -110 S. NORTHERN WAY YORK. PA 17402 TELEPHONE: 1215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AUG 14 2007 Date: -J1, 1P. 2,,7 Seal of the Court BY THE OURT: -:? As/ Prothonotary/Clerk, Civil Div' n Deputy 14524-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARTMAN REHAB. ASSOCIATES 4TH & WILLOW STREET 3RD FLOOR LEBANON, PA 17046 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from. 10-01-2005 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.35S 105-N SU10-0696938 3-4524-T-,04 .4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGIML IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2007 M On behal Z4" i MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT 41 R1.39 133-H DEll-0705048 14524-L05 C4ON4N40'NWEALTH OF P' ENN S YLVAN I A COUNTY OF CiJMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, -VS- CASE NO: 07-3609 VALERIE LAIR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUWENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 I Note: see enclosed list of locations ] TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07125/2007 CC: MICHAEL SCHEIB, ESQ. - Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 105-N DE02-0369370 1 4 5 2 4- C 0 1 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE CO. HARRISBURG HOSPITAL PINNACLE WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING ti.35S 105-N DE02-0369370 1 4 5 2 4- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 VS. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DRAYER PHYSICAL THERAPY INSTIT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** EE ATTACHED RIDER **** at The MCS Ga=. Inc., 1601 Market Street Suite 800 Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB, ESQ. ADDRESS: 110 S. NORTHERN WAY YORK. PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JLJ' ??u?1 4 ?7 Date: Seal of the Court BY THE OURT: ro hoonnotary/Clerk, Civil ivis' Deputy 14524-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DRAYER PHYSICAL THERAPY INSTIT 8205 PRESIDENTS DRIVE FIRST FLOOR HUMMELSTOWN, PA 17036 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from: 10-01-2005 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.35S 105-N SU10-0696940 1 4 5 2 4- L O S CERTIFICATE ORIGIML PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2007 MI/CC L SCHEIB, ESQ. Attorney for DEFENDANT R1.39 133-H DE11-0705049 14524 -L06 CON N1C NWEALTH OF PENNSYLVAN Ilk COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, -VS- CASE NO: 07-3609 VALERIE LAIR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ) TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/25/2007 CC: MICHAEL SCHEIB, ESQ. Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 U.35S 105-N DE02-0369370 1 4 5 2 4- C 0 1 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE CO. HARRISBURG HOSPITAL PINNACLE WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES .DRAYER PHYSICAL THERAPY INSTIT TRISTAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING t1.35S 105-N DE02-0369370 1 4 5 2 4- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 VS. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for TRISTAN ASSOCIATES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****_ SEE ATTACHED RIDER **** at The MCS Group, Inc., 1601 Market Street. Suite 800. Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ES ADDRESS: 110 S. NORTHERN WA TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant L G^ 7 Date: Seal of the Court BY THE OURT: ro honotary/Clerk, Civil Di 7n n Deputy 14524-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TRISTAN ASSOCIATES 4349 CARLISLE PIKE CAMPHILL, PA 17011 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from: 10-01-2005 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.35S 105-N SU10-0696942 1 4 5 2 4- Z. 0 6 ORIGINAL CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2007 MCS on behalf f MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R1.39 133-H DE11-0705050 14524 -L07 C OMNIONWE A L T H C )IF P E NN S Y L V AN Ilk COUNT Y O F C UMB E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, -VS- CASE NO: 07-3609 VALERIE LAIR NOTICE OF INTENT TO SERYE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/25/2007 CC: MICHAEL SCHEIB, ESQ. Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 105-N DE02-0369370 1 4 5 2 4- C 0 1 >>> LOCATION LIST <<< PAGE: LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE CO. HARRISBURG HOSPITAL PINNACLE WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING 21.35S 105-N DE02-0369370 1 4 5 2 4- C !O I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HEALTHSOUTH REHAB (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * * * at The MCS Group. Inc., 1601 Market Street Suite 800, Philadelnj?a, PA 191 n3 You may deliver or mail legible copies of the documents on 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: MICHAEL SCHEIB, ESQ. ADDRESS: 110 S. NORTHERN WAY YORK_ PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AM 1 4 2007 Date: -Jdy te, Seal of the Court BY THE COURT: r thonotary/Clerk, Civil D' on eputy 14524-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH REHAB 175 LANCASTER BLVD P.O. BOX 2016 MECHANICSBURG, PA 17055 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from: 10-01-2005 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.35S 105-N SU10-0696944 1 4 5 2 4- L O 7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 ORIGIML IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2007 14 CS on beh 1 of - ` MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R1.39 133-H DE11-0705051 14524 -LO8 CC)NIMONWEALTH OF PENNSYLVAN I A COUNT Y O F C UMB E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, -VS- CASE NO: 07-3609 VALERIE LAIR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ) TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical t•o the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/25/2007 CC: MICHAEL SCHEIB, ESQ. Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ.. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 105-N DE02-0369370 1 4 5 2 4- C 0 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE CO. HARRISBURG HOSPITAL PINNACLE WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING t1.35S 105-N DE02-0369370 1 4 5 24 - d =O I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HQSPITAi (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** - at The MCS Groff Inc 1601 Market Street Suite 800. Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESQ. ADDRESS: 110 S NORTHERN WAY YORK, PA 17402 TELEPHONE: (215).246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE OURT: r thonotary/Clerk, Civil i v AUG 14 2007 Deputy Date: Seal of the Court 14524-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL MEDICAL RECORDS 111 S. FRONT STREET HARRISBURG, PA 17101 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: from: 10-01-2005 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 209-62-0329 Date of Birth: 06-23-1964 R1.35S 105-N SU10-0696946 3-4524-1j08 CERTIFICATE ORNOW PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2007 MCS on behalf f _ ?CH MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT i R1.39 133-H DE11-0705052 14524-LO9 C OMiVIO NWE A L--r14 O F P E N N S Y L V AN I A COUNT Y O F C UMB E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, -VS- CASE NO: 07-3609 VALERIE LAIR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations I TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/25/2007 CC: MICHAEL SCHEIB, ESQ. - Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 IltI.35S 105-N DE02-0369370 1 4 5 2 4- C 0 1 >>> LOCATION LIST <<< PAGE LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE CO. HARRISBURG HOSPITAL PINNACLE WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING II.35S 105-N DE02-0369370 1 4 5 2 4- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things:._ * * * * SEE ATTACHED RIDER * * * * at The MCS Group- Ind, 1601 Market street- suite 8oo Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB, ESQ. ADDRESS: 110 S. NORTHERN WAY YORK_ PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE URT: /r4ohonotary/Clerk, Civil Di AUG 14 2007 Deputy Date: L9 f 06 Seal of the Court 14524-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL BILLING RECORDS 111 S. FRONT STREET HARRISBURG, PA 17101 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all billing, insurance claims, payments, outstanding and/or delinquent invoices, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: from: 10-01-2005 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 209-62-0329 Date of Birth: 06-23-1964 R1.35S 105-N SII10-0696948 1 4 5 2 4- L 0 9 qw- CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD ORIGIA% COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- VALERIE LAIR CASE NO: 07-3609 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/14/2007 /° M S on behal of r7 ESQ. J MICHAEL SCHEIB, 1Attorney for DEFENDANT R1.39 133-H DE11-0705053 14524 -LlO C OMtvIONWE A L T H O F P E N N S Y L V AN I A COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, -VS- CASE NO: 07-3609 VALERIE LAIR NOTICE OF INTENT TO SER A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ) TO: RICHARD A. SADLOCK. ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07125/2007 CC: MICHAEL SCHEIB, ESQ. - Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET /1800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.35S 105-N DE02-0369370 14524-4--01 >>> LOCATION LIST <<< PAGE: LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE CO. HARRISBURG HOSPITAL PINNACLE WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS do BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING t1.35S 105-N DE02-0369370 1 4 5:2 4- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHOPAEDIC INSTITUTE OF PA (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun, Inc.- 1601 Market Street. Suite 500. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB, ESQ. ADDRESS: 110 S. NORTHERN WAY YORK. PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant AUG 14 2007 Date: JLLLl /'P .2 cv7 Seal of the Court BY THE OURT: lfritfi onotary/Clerk, Civi Di Deputy 14524-10 EXPLANATION TO: CUSTODIAN OF RECORDS FOR: ORTHOPAEDIC INSTITUTE OF PA 3399 TRINDLE ROAD CAMP HILL, PA 17011 RE: 14524 RONNIE REINFORD OF REQUIRED RECORDS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from: 10-01-2005 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.35S 105-N SUIO-0696950 1 4 5 2 4- L 1 0 .....7 -?t"1 t ? ,,.? "- ,? ? r ? _ .. ? ?t i.; .s T a A ANGINO & ROVNER, P.C. Richard A. Sadlock Esquire Attorney ID# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 Phone: (717) 238-6791 Fax: (717) 238-5610 Attorneys for Plaintiffs: E-mail: rsadlock64aneino-rovner.corn Rhonda and R. Timothy Reinford RHONDA L. REINFORD and R. TIMOTHY REINFORD, her husband, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. VALERIE LAIR, Defendant NO. 07-3609 Civil Term JURY TRIAL DEMANDED PLAINTIFFS' MOTION TO SERVE FINANCIAL WEALTH DISCOVERY UPON DEFENDANT PURSUANT TO Pa.R.C.P. 4003.7 Plaintiffs, by and through their attorneys, Angino & Rovner, P.C., respectfully move Your Honorable Court to permit discovery of Defendant Valerie Lair's financial wealth for the following reasons: 1. On June 18, 2007, Plaintiffs Rhonda L. and R. Timothy Reinford filed a Complaint for injuries sustained from a motor vehicle accident that occurred on October 22, 2005, at approximately 8:39 p.m. 2. Defendant Valerie Lair operated her vehicle at a high rate of speed, rammed the back of the Terry Camper Plaintiffs were pulling and then violently slammed into the driver's side door of the vehicle causing serious injuries to Plaintiffs. L 3. Defendant Valerie Lair was under the influence of alcohol when the accident occurred. 4. Plaintiffs' Complaint includes a claim for punitive damages. 5. Punitive Damages are penal in nature and may be awarded in cases where the defendant's actions are so outrageous as to demonstrate willful, wanton or reckless conduct. Hutchison v. Luddy, 896 A.2d 1260 (Pa.Super. 2006). To sustain a claim for Punitive Damages, it must be established that the Defendant had a subjective appreciation of the risk of harm and that the Defendant acted in conscious disregard of that risk. Id. at 1266. 6. Defendant Valerie Lair's operation of a motor vehicle while under the influence of alcohol constitutes outrageous conduct due to Defendant's reckless indifference to the rights and safety of others. 7. Defendant Valerie Lair knew or should have known that operating a motor vehicle while under the influence of alcohol would endanger other motorists on the roadways. 8. Defendant Valerie Lair's operation of a motor vehicle while intoxicated constitutes a conscious disregard of that risk. 9. Pennsylvania recognizes that driving under the influence of alcohol has a "very great potential for harm and serious injury" and "may under certain circumstances be deemed `outrageous conduct' and `a reckless indifference to the interest of others' sufficient to allow the imposition of punitive damages."' Focht v. Rabada, 217 Pa.Super. 35, 40, 268 A.2d 157, 160 (1970). 364222 46 10. Because the purpose of punitive damages is to punish the tortfeasor for the outrageous conduct, the wealth of the tortfeasor is relevant in order to allow the jury to weigh the conduct of the tortfeasor against the amount of damages which would deter such future conduct. Kirkbride v. Lisbon Contractors, Inc., 521 Pa. 97, 555 A.2d 800 (1989). 11. The discovery of the information concerning the Defendant's wealth is expressly permitted in Pa.R.C.P. 4003.7 by Order of the Court when there has been a valid claim for punitive damages. 12. The instant action has not been before a Judge to date. 12. Plaintiffs are represented by Richard A. Sadlock, Esquire of Angino & Rovner, P.C., 4503 North Front Street, Harrisburg, PA 17110; telephone number (717) 238-6791; fax number (717) 238-5610. 13. Defendant is represented by Michael B. Scheib, Esquire, Griffith, Strickler, Lerman, Solymos & Calkins, 110 Northern Way, York, PA 17402-3737; telephone number (717) 757-7602; fax number (717) 757-3783. 14. Prior to filing the instant Motion, on August 9, 2007, Plaintiffs' counsel wrote to Defendant's counsel and provided copies of the proposed Interrogatories and Request for Production of Documents and sought counsel's agreement to answer the financial wealth discovery. 15. To date, Defendant's counsel has not responded to Plaintiffs' counsel's August 9, 2007, letter. Therefore, it is Plaintiffs' counsel's belief that Defendant's counsel does not concur with responding to Plaintiffs' financial wealth discovery or the filing of this Motion. 364222 WHEREFORE, Plaintiffs respectfully request Your Honorable Court to permit discovery of Defendant's financial wealth. Respectfully submitted, ANGINO & ROVNER, P.C. Ric ock, Esquire 47281 503 North Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiffs Date: September 25, 2007 364222 46 CERTIFICATE OF SERVICE I, Marcy L. Brymesser, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFFS' MOTION TO SERVE FINANCIAL WEALTH DISCOVERY on the following via postage prepaid, first class United States mail, addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402-3737 Marcy L. rymess r Date: September 25, 2007 364222 w ? c ? r Ct `j s . y ` ...y rte" -cam G . 1 . A 1¦a ANGINO & ROVNER, P.C. Richard A.Sadlock Esquire Attorney ID# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 Phone: (717) 238-6791 Fax: (717) 238-5610 Attorneys for Plaintiffs: E-mail: rsadlockLt?angino-rovner corn Rhonda and R. Timothy Reinford RHONDA L. REINFORD and R. TIMOTHY REINFORD, her husband, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. VALERIE LAIR, Defendant NO. 07-3609 Civil Term JURY TRIAL DEMANDED ORDER/RULE TO SHOW CAUSE AND NOW, this 2 6" day of ., 2007, upon consideration of the foregoing Motion, it is hereby ordered that; (1) a rule is issued upon Defendant to show cause why the Plaintiffs are not entitled to the relief requested; (2) the Defendant shall file an answer to the instant Motion within 2 o days of this date; (3) the Motion shall be decided under Pa.R.C.P. No. 206.7; 'sco 1 ; (5) argument shall be held on C<thu'x? eR 5- , 2007, at a % m, in Courtroom of the Cumberland County Coin and 364222 1 1 t? 'J pit .? A --4. (6) notice of the entry of this order shall be provided to all parties by the petitioner. Distr' tion: ichard A. Sadlock, Esquire, Angino & Rovner, P.C., 4503 North Front Street, Harrisburg, A 17110,(717)238-6791 ichael B. Scheib, Esquire, Griffith, Strickler, Lerman, Solymos & Calkins, 110 South Northern Way, York, PA 17402-37')7,(717)757-7602 1 ? ? IV1, 364222 BY THE COURT: / RHONDA L. REINFORD and R. TIMOTHY REINFORD, her husband, Plaintiffs vs. VALERIE LAIR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3609 CIVIL JURY TRIAL DEMANDED IN RE: PLAINTIFFS' MOTION TO SERVE FINANCIAL WEALTH DISCOVERY ORDER AND NOW, this 25' day of October, 2007, action on the plaintiffs' motion to serve financial wealth discovery upon the defendant is DEFERRED pending the filing of a motion for summary judgment. In the event that a motion for summary judgment is not filed on or before the close of business on Monday, January 7, 2008, the plaintiffs' motion to serve financial wealth discovery will be granted as of course. BY THE COURT, Kevin . Hess, J. Richard Sadlock, Esquire For the Plaintiffs Michael Scheib, Esquire For the Defendant rlm 045P lie s ?M tL . / / x.167 i• ; , f j L• f it H -J ! " AGN LOCZ 4 r . t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and R. TIMOTHY REINFORD, Plaintiffs V. VALERIE LAIR, Defendant NO. 07-3609 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED MOTION FOR PARTIAL SUMMARY JUDGMENT OF DEFENDANT VALERIE LAIR AND NOW, come Defendant VALERIE LAIR by and through her attorneys, Michael B. Scheib, Esquire and David E. Cook, Esquire and the Law Offices of Griffith, Strickler, Lerman, Solymos, and Calkins, and states the following in support of the Motion for Partial Summary Judgment: 1) Plaintiffs initiated the above-captioned matter by filing a Complaint on or about June 18, 2007, in the Court of Common Pleas of Cumberland County. 2) Plaintiffs allege in the Complaint that Rhonda Reinford was injured on or about October 22, 2005 as a result of a motor vehicle accident. Pl.'s Compl. at ¶¶ 3, 10. A true and correct copy of the Plaintiffs' Complaint is attached hereto and made a part hereof as Exhibit "A". t t ? 3) The accident is alleged to have occurred at "approximately 8:39 p.m., at the intersection of South Td Street and Walton Street in the Borough of Lemoyne". Pis. Compl. at 13. 4) Plaintiffs' Complaint includes a claim for punitive damages. See Pls. Compl. at Claim III, Ex. A. 5) The Complaint alleges that "Defendant Valerie Lair while impaired and under the influence of drugs and/or alcohol drove her vehicle at an excessive rate of speed, well in excess of the posted speed limit." Pls. Compl. at 122, Ex. A. 6) The Complaint alleges that "Defendant Valerie Lair's conduct constitutes wanton and willful negligence, is outrageous, and entitles Plaintiffs to an award of punitive damages." Pls. Compl. at 126, Ex. A. 7) To recover punitive damages a plaintiff must show that Defendant's conduct was outrageous; outrageous conduct is an act "done with a bad motive or with reckless indifference to the interests of others." Focht v. Rabada, 217 Pa. Super. 35, 38, 268 A.2d 157, 159 (1970). 8) In Focht v. Rabada, the Court held that "under appropriate circumstances, evidence of driving under the influence of intoxicating liquors may constitute a sufficient ground for allowing punitive damages." Focht v. Rabada, 217 Pa. Super. at 42, 268 A.2d at 161 (emphasis added). 9) Plaintiffs cannot show that Defendant's conduct was outrageous sufficient to warrant punitive damages. -2- 10) Defendant testified that she consumed a couple of glasses of wine while at home. January 2, 2008, Deposition Transcript of Valerie Cliber' (hereinafter "Cliber Dep.'I at 13, 17. A true and correct copy of the Deposition of Valerie Cliber is attached hereto and made a part hereof as Exhibit B. 11) Defendant testified that she did not feel intoxicated when she left her residence. Cliber Dep. at 17, Ex. B. 12) Defendant testified that she drove from her residence to the Buger King, which is less than a mile from her home. Cliber Dep. at 17, Ex. B. 13) Defendant testified that she exited the Burger King parking lot and made a right hand turn on to 3`d Street. Cliber Dep. at 22, Ex. B. 14) Defendant testified that after exiting the Burger King parking lot she traveled approximately one half a block. Cliber Dep. at 23, Ex. B. 15) Defendant estimated her maximum speed to be between twenty to twenty- five miles per hour. Cliber Dep. at 24, Ex. B. 16) The accident occurred one half a block from the Buger King exit. Cliber Dep. Tr. at 23, Ex. B. 17) The vehicle occupied by Plaintiffs was a 1998 Chevy Silverado which was pulling a Terry Camper. Pls. Compl. at 14, Ex. A. 18) Defendant testified that the vehicle was stopped and that she did not observe any rear brake lights on the Camper. Cliber Dep. at 23, Ex. B. 19) Defendant testified that she attempted to avoid the camper but was unsuccessful. Cliber Dep. at 22, Ex. B. ' Since the filing of the Complaint, Defendant has remarried. -3- 20) Plaintiff Rhonda Reinford testified that she was a front seat passenger in the Chevy Silverado and that her husband was the driver of the vehicle. January 2, 2008, Deposition Transcript of Rhonda L. Reinford [hereinafter "Reinford Dep.'I at 32. A true and correct copy of the Deposition of Rhonda L. Reinford is attached hereto and made a part hereof as Exhibit C. 21) Plaintiff Rhonda Reinford testified that while their vehicle was stopped on 3rd Street, waiting to make a left hand turn, she felt a bump from behind. Reinford Dep. at 32, Ex. C. 22) Plaintiff Rhonda Reinford testified that she turned to her husband to indicate that she believed something had struck them from behind. Reinford Dep. at 32, Ex. C. 23) Mr. Reinford testified that "as I was sitting there, we felt a little jar to the camper. My wife turned to me and said I think somebody just hit us. I said I think you are right. My intention was then to turn onto our street, pull off to the side and get out and see what happened." January 2, 2008, Deposition Transcript of Timothy Reinford [hereinafter "Timothy Reinford Dep.'I at 8. A true and correct copy of the Deposition Transcript of Timothy Reinford is attached hereto and made a part hereof as Exhibit D. 24) Mr. Reinford testified that as he proceeded to make his left hand turn after the traffic cleared and then there was a second impact. Timothy Reinford Dep. at 8. -4- , 1 ,. 25) Plaintiff testified that there was then a second impact with Defendant's vehicle striking the driver's side door of the vehicle occupied by Plaintiffs. Reinford Dep. at 32, Ex. C. 26) Both Rhonda and Timothy Reinford testified that they did not observe Defendant's vehicle prior to the accident. Reinford Dep. at 32, Ex. C; Timothy Reinford Dep. at 10, Ex D. 27) Plaintiffs did not have the ability to estimate the speed of Ms. Lair's vehicle prior to impact. See Reinford Dep. Tr. at 32, Ex. C; see also Timothy Reinford Dep. at 10, Ex D. 28) Both Rhonda and Timothy Reinford testified that they were not aware of any witness that observed Defendant's driving prior to the accident. Reinford Dep. at 71-72, Ex. C; Timothy Reinford Dep. at 12, Ex. D. 29) Rhonda Reinford testified that she was unaware of any outrageous conduct on the part of the Defendant that evening. Reinford Dep. Tr. at 70-71, Ex. C. 30) The evidence, taken in the light most favorable to Plaintiffs, establishes that Defendant traveled half a block before a low speed impact. 31) The evidence, taken the in the light most favorable to Plaintiffs, does not establish that "but foe' the consumption of alcohol the accident would not have occurred. 32) The sole evidence Plaintiff relies upon to impose punitive damages is Defendant's consumption of alcohol. -5- 33) The consumption of alcohol alone is insufficient to impose punitive damages. 34) The consumption of alcohol alone is insufficient to be considered Respectfully Submitted, GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: r q --V-V y Y- ./ VV - V MICHAEL B. SCHEIB, ESQUIRE Supreme Court I.D. No. 63868 BY: DAVID E. COOK, ESQUIRE ID#: 78318 110 S. Northern Way York, PA 17402 Attorneys for Defendant, Valerie Lair outrageous conduct. 35) The testimony does not establish that Defendant acted with a reckless indifference to the interests of others. 36) The testimony does not establish that Defendant acted with bad motive. 37) The circumstances of this particular case are insufficient as a matter of law to allow the imposition of punitive damages. WHEREFORE, Defendant moves for partial summary judgment as no material issue of fact exists and Plaintiffs are not entitled to recover punitive damages against Defendant as a matter of law. Dated: January 2008 -6- EXHIBIT "A" jUN-21--2007 THU 02:25 PM t FAX NO, 717 534 2627 , r, Ud ANCYNO & 1MM P.C. Rich nA A. Sadlock &qu ire Attorney W# : 47281 4303 North Front Stmt Harrisburg, PA 17110.1708 Pbone. (7t7) 238.6791 Fax: (717) 238-5610 - Attorneys for PIAmt M! E•n 1: rsttdlaak nneinn-rovner.enm & Man end R: Timot$x Reinford_ RHONDA L. REINFORD and R. TfMOTHY REWORD, her husband, Plaintiffs V. VALERIE LAIR, Defendant IN THE COURT OF COMMON FLEAS CUMBERLAND COUNTY, PENNSYLVANIA CrVIL ACTION - LAW NO. 01, ,31r,61 r rug L l .. f URY TRIAL DEMANDED N0TM Td_I3_EnND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must Wce action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE T)? OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT H hIG A LAWYER. IF YOU CANNOT AFFORD TO ME A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT ACxENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLI? PERSONS AT A REDUCED FEE OR NO FEE, Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 ,,•,p? (717) 249-3166 'I TestiPrlalaj! 111,wrca. 7 IVn"O tat my l'.? rJ tha W a.I .gillSlB+ Pam PACE 2110 ? RCVD AT 6121!20071,13:53 PM (Centai Daylight Time) ? SUR;A0116•XPX0101•S!6 x DNIS:59411= CSID:117 634 26211 DURATION (mtn-ss)103.22 PACE 2116' RCVD AT 6(25!20011,21;40 PM [Central D#Ight Time) I $%A0001-00103•81291 DNIS,82595' CSID, I DURATION (mm•ss);05.18 40-21-2007 THU 02:26 PH t FAX NO, 717 534 M( r. uo Amp US'XED HA SIDO DEMANDADOIA EN CORTE. Si usted desea deihnderse de las demandas que sc persentan mds adelante en las siguientes pdginas, debe tomar aceibn dentro de los prbximos veinte (20) dial despuds de la notiecacl6n de esta Demanda y Aviso redicaudo porsocalmente o por medio de un abogado una comparecencia oscAta y radicando on la Corte por escrito sus defensas de, y objecclones a , las demandas presentadaa aqui on contra says. Se le advierte de que si ustod Ma. de tomar acoldn como se describe anteriormente, -el caso puede proceder sin ustod y un fallo por cualquier sums do dinero raclamada en la demanda o cualquier otre rcelamaci6n o remedio solicitado por cl demandante puede ser dictado en contra suya por la Corte sin miss aviso adiclonal. Used puede perder dinero o propledad u otros derechos irnporrantes pars used. US'IED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO TNMEDIATAMEN'TE. SI USED NO TM NE UN ABOGADO, LLAME 0 VAXA A LA SIGUIENTE OFIICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSECUIR UN A30GADO. SI USED NO PUEDE PAGAR ?OR LOS SERVICIOS DE UN ABOGADO, SS POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE A.GgNCIAS QUE OFREZCAN SFRVICIOS LEGALI~S SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALMCAN. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249.3166 PAGE 3110 x RCYD AT 601120011:13:53 PM Central Dayligit Tme]; SVR:A0116•XFX6101416' DNIS:51411 ° CSI0:111534 2627 E DURATION (mm•ss):03.22 PAGE 3,116' RCYD AT 6125120071:21:40 PM [Central Daylight Time]" SVRM001•00103-S1291 DNI8:82595 x CSID: I DURATION (mm?ss):05.18 JUN-21-2007 THU 02:28 PM E N MA NU, ( l l b6q d0d i I, v4 ANGWO & ROVNRR. P.C. Richud A- Wock Esquire Attorney M# : 47281 4503 North Fnmt W.-i Harrisburg, PA 17110-1708 Phone: (717) 238-6791 Fax: (717) 2334610 Attorneys for Mikindfk: E-wdl: rsad!gls ¢ino.rowcr com Rhonda and R. Tjmothy Reinford MONDA L. REINFORD and R TIMOTHY REINFORD, her husband, plaintiffs V. VALERIE LAIR, Defendant IN TBE COURT OF COMMON PLEAS CUNMERLAND COUNTY, PENNSYLVANIA, CIVYL ACTION -LAW NO. JURY TRIAL DEMANDED COMPLAAE.VNI' 1. Plaintiffs Rhonda L. Reinford and R. 'T'imothy Reinford are adult individuals, citizens of the Commonwealth of Pennsylvania, who reside at 227 Walton Street, Lemoyne, Cumberland County, Pennsylvania, 2. Defendant Valerie Lair is an adult individual, citizen of the Commonwealth of Pennsylvania, who resides at 1490 Brandt Avenue, New Cumberland, Cumberland County, Penmsylvania. 3. The facts and occurrences hereinafter related took place on Saturday, October 22, 2005, at approximately 8:39 p.m., at the intersection of So-oth P Street aad Walton Street in the Borough of Lemoyne, Cumberland County, Pennsylvania. PAGE 4110' RCVD AT 6f211200 M3;53 PM (Central DayllgN Time' SVR:A0116-XPX0101.SV DNIS;51471' CMD:717 634 2627" DURATION (mm.ss),03.22 PAGE 4116 ' RCVD AT 6125120071:21;40 PM [Central Daylight Time]' SMA0001-0010M129' DNIS:825951 CSID:' DURATION (mm-ss):05-18 'JUN-21-2007 THU 02:26 PN L FAX NO. 717 534 2627 P. 05 4. At that time and place, Plaintiff Rhonda L. Reinford was a front seat passenger in the 1998 Chevrolet Silverade that was pulling a Terry Camper operated by her husband, R. Timothy Reinford. 5. At that time and place, Plaintiff Rhonda L. Reinford was a passenger in a vehicle that was traveling south on South 3`d Street in Lemoyne attempting to tum left onto Walton Street. 6. At that time and place, Defendant Valerie Lair was operating a 2001 Mazda Tribute LX and was traveling south on South 3r' Street directly behind Plaintiffs. 7. At that time and place, Defendant Valerie Lair operated her vehicle at a high rate of speed without paying attentions to traffic and, suddenly and without warning, rammed the back of the Terry Camper Plaintiffs were pulling and then violently slammed into the driver's side door of the vehicle in which Plaintiff Rhonda Reinford was a passenger. 8. Defendant Valerie Lair was extremely intoxicated when she allowed her vehicle to strike Plaintiffs' vehicle. 9. Defendant Valerie Lair knew or should have know that operating a motor vehicle while extremely intoxicated would endanger other persons on the roadway. 10. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiffs Rhonda L. Reinford and R. Timothy Reinford asp the direct and proximate .70ws I 2 PAGE 5110 x RCVD AT 6121120071:13:53 PA1(Wal Daylight Time)' SWAM 16.10101416 ° DNI8:51471 I CSID 117 534 2621; DURATION (mm-9s):03.22 PAGE 5110 x RCV0 AT 6125120071:21:40 PM (Central Daylight Time)" SMA0001-001034129' DNIS:82595" CSID: X DURATION (mm-ssj:05.18 JUN-21-2007 THU 02:26 PM E u FOX NO, (If b34 fib' r. UU result of the negligent, careless, wanton and reckless manner in which Defendant Valerie Lair operated her vaWelc as follows: (a) failure to 1mve her vebicle under such control as to be able to atop within the assured clear distance ahead; (b) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (c) failure to travel at a safe speed; (d) failure to apply her brakes in sufficient time to avoid striking the vehicle; (e) failure to take reasonable evasive action to avoid the accident; (f) failure to drive her vehicle with due regard for the highway and traffic conditions which were existing and of which she was or should have been aware; (g) failure to keep proper and adequatt control over her vehicle; (h) driving the vehicle while intoxicated or otherwise impaired; and (i) driving her vehicle upon the highway in a manner endangering persons acid property and in a reckless manner w7th careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. CLATA'I I Ib:NDA ,REINFORD v. YALE=- LAIR 11. Paragraphs I through 10 of Plain i£fs' Complaint are incorporated herein by reference. 3539-25 3 PAGE 6110' RCVD AT 612112007113:53 RA [Central Daylght Time[' SVR:A0116-M0101516' DNIS:51471 I C90:717 534 2627 k DURATION tmm•ss):03.22 PAGE 6116 ' RCVD AT 6125120011:21:40 PM (Central Daylight Time)" SVR:A0001.00103•Sf29' DNIS:82595' CSID:"DURATION (mm•ss):05.18 JUN-21--2007 THU 02:27 PH L FAX NO, 717 534 2627 . P, U7 12. Plaintiff Rhonda L. Reinford sustained painful and severe injuries which include but are not limited to neck pain with tingUng into arms, pain between shoulder blades, low back pain with pain radiating into the left leg and a herniated nucleus pulposus at L4-5. 13. By reason of the aforesaid injuries sustained by Plaintiff Rhonda L. Reinford., she was forced to incur liability for medical treatment, medications, hospitalizations and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 14. Bocause of the nature of her isrjudes, Plaintiff Rhonda L. Reinfard has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 15. As a result of the aforementioned injuries, Plaintiff Rhonda L. Reinford has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and eajoynient, and claim is made therefor. 16. As a result of the aforementioned collision and resulting injuries, Plaintiff Rhonda L. Reinford has been and in the future will be subject to great humiliation and embarrassment, and claim is made therefor. 17. As a result of the aforementioned injuries, Plaintiff Rhonda. L. Reinford has sustained work loss, loss of opportunity and a permanent diminution of her earning power and capacity, and claim is made therefor. 16. As a result of the aforementioned collision and resulting injuries, Plaintiff Rhonda L. Reinford has sustained uncompensated work loss, and clam is made therefor. MOM F+ PAGE 7110' RCVD AT 6121120071:13:53 PIA (Central Daylight Time) "SVR:A0116•XFX0101 S16 DMS:51471 E CSID:717 534 26271 DURATION (mm•ss):03.22 PAGE 7116" RCVD AT 6125120071:21:40 PM ]Central Daylight Time]' SVR:A0001-00103•S129' DNIS:82595" CSID:' DURATION (mm•ss):05.18 ,JUN-21-2007 THU 02:27 Pit t FAX NO, 717 534 2627 , P. 08 17. As a result of the aforementioned collision and resulting injuries, Plaintiff Rhonda L. Reinford eontiuaues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the rantainder of her lifetime, and claim is made therefor. CLAIM IT R TIMOTHY REINFORA v VALERIE LAIR 18. Paragraphs 1 through 17 of plaintiffs' Complaint are incorporated herein by reference. 19. As a result of the aforementioned injuries sustained by his wife, Plaintiff Rhonda L. Reinford, Plaintiff R. Timothy Reinford has been and may in the future be deprived of the care. companionship, consortium, and society of his We, all of which will be to him great detriment, and claim is made therefor. CLAIM M RHONDA L. REINFORD ANA R TIMOTHY REINFORD V. VALERIL LAIR 20. Paragraphs 1 through 19 of Plaintiffs' Complaint are incorporated herein by reference. 21. Before the subject motor vehicle accident, Defendant Valerie Lair consumed alcoholic beverages, or other drugs, which caused her to become intoxicated. Z.;. n", d PAGE Silo I RCVD AT 6121120011:13:53 PM (Central Daylight Time] I SVR:A0116.M0101 W DNIS:51471 r CSID:717 51126271 DURATION (mm-ss):03.22 PAGE 8116"RCVO AT 6125120071:21:40 PM [Central Daylight lime]" SVR:A0001•XFX0103•5129' DNIS:825951 CSID:"DURATION (mm•ss):05.18 .J 21-2007 ITIU 02:27 PM L FAX NO. 717 534 2627 , P. 09 22. Defendant Valcrie Lair while impaired and under the influence of drugs and/or alcohol drove her vehicle at an excessive rate of speed, well in excess of the posted speed limit. 23. After consun-ing alcoholic beverages, or other drugs, Defendant Valerie Lair knew or should have /mown that she ryas severely intoxicated and unable to safely operate a motor vehicle. 24. Defendant Valerie Lair knew or should have known that her operation of a motor vehicle while intoxicated constituted outrageous conduct and a reckess indifference to the rights of others of the highway. 25. Defendant Valerie Lair's direct collision with p'laintiffs' vehicle displayed willfW, negligent and reckless indifference towards the rights of others on the highway, 26. Defendant Valerie Lair's conduct constitutes wanton and willful negligence, is outrageous and entitles plaintiffs to an award of punitive damages WHEREFORE, Plaintiffs Rhonda L. Relnford and R. Timothy Reinford demand judgment against Defendant Valerie Lair in an amount in excess of Fift r Thousand Dollars ($50,000,00), exclusive: of interest and costs, and in excess of any jurisdictional amount requiring compulsory arbitm ion. Front S i i17) N ,, 7281 aburg, P 17110 238- 91 Date: June 15, 2007 for Plaintifs s 353005 C V PAGE 9110 x RCVD AT 6121120011:1313 PM [Central Daylight Time]' SVRA011643101-S16' DMS:51411' CSID:117 534 26211 DURATION (mm•ss):03.22 PAGE 91161 RCVD AT 6125120071:21:40 PM [Central Daylight Timed I B R:A0001.00103.8129' DNIS:82395: CSID: I DURATION (mm-ss) 05.18 HIR-21-2007 M 02.28 PN E FAX NO. 717 534 2627 P. 10 VER?TCA?'IQ +l? We, RAONDA L. RIMFORD a;kit. '1':"lMOM itEINF0109 Plaintiffs, have read the foregoing PLAIN On' COMPLAINT and, dry hezeV swear or affirm tbat the facts set forth in the foregoing me true cad cox rect to the best of our lmowledge, Womation and belie: We undmtand that this Verification is made subject to the penal-des of IS Pa.C.S.A. Section 4904, relating to unswom falsification to authozlties. Witnm,,.r e Witness Dated: / / e 3$4575 PAGE 10110' RCVD AT 6121120071;13;53 PM [Centre Oa}IGG ?t Tlme?' SVR:A0146•XFX0141•S16' DN1S:51471: CSID:111534 2621' DURATION (mm•ss);03.22 PAGE 10f 16"RCVD AT 6125120071:21;40 PM (Central Daylight Time] I SVR:A0001-001034129' DNI8:8259V CSID: z DURATION (mm•ss):05.18 EXHIBIT "B" RHONDA L. REINFORD AND R. TIMOTHY REINFORD, HER HUSBAND, PLAINTIFFS V . IN THE COURT OF COMMON PLEAS CUMBERLAN COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3609 CIVIL TERM VALERIE LAIR, DEFENDANT JURY TRIAL DEMANDED DEPOSITION OF: VALERIE CLIBER TAKEN BY: PLAINTIFFS BEFORE: MARIA N. O-DONNELL, RPR NOTARY PUBLIC DATE: JANUARY 2, 2008, 9:26 A.M. PLACE: ANGINO & ROVNER, PC 4503 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA APPEARANCES: ANGINO & ROVNER, PC BY: RICHARD A. SADLOCK, ESQUIRE FOR - PLAINTIFFS GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS BY: DAVID E. COOK, ESQUIRE FOR - DEFENDANT ALSO PRESENT: RHONDA L. REINFORD R. TIMOTHY REINFORD DAVID CLIBER E IN - - 2080 Linglestown Road • Suite 103 • Harrisburg, PA 17110 717.540.0220 0 Fax 717.540.0221 • Lancaster 717.393.5101 2 1 7 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 'K' M 1 -- VALERIE CLIBER BY: MR. SADLOCK WITNESSES EXPMINTATTON 3 3 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 STIPULATION It 15 hereby stipulated by and between counsel for the respective parties that reading, signing, sealing, certification and filing are hereby waived; and that all objections except as to the form of the question are reserved to the time of trial. (Discussion held off the record.) VALERIE CLIBER, called as a witness, being duly sworn, testified as follows: i EXAMINATION BY MR. SADLOCK: Q Would you state your full name, please? A Valerie Cassel Cliber. Q At the time of this accident, you were known as Valerie Lair, is that right? A Yes. Q Was Lair at the time a married name or maiden name? A Married name. Q At the time, were you -- of this accident, were you married to Mr. Lair or divorced already? A Divorced. Q And you are giving your name now, you mentioned the name Cassel. Was that your maiden name') A That was my maiden name. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 Q You are now married to Mr. Cliber who is present iierc tod vua'y? i" A Yes. Yes. Q When did you and Mr. Cliber get married? A This August. MR. CLIBER: Fourth. THE WITNESS: I think it was the second. Whatever was Thursday that week. BY MR. SADLOCK: Q All right. 2007? A Yes. Q What is your current home address? A 1490 Brandt Avenue, New Cumberland. Q How long have you lived at that address? A Four years, I believe. Q Is that the address that you were residing on the date of this accident? A Yes, sir. Q And at time of the accident, did you reside with anyone at that address? A With Dave, yes. Q Dave being your husband, Mr. Cliber? A Yes, but he was not my husband at that time. Q How long have you and Mr. Cliber been together? A About five years. 1 L 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 k , 5 Q So sometime in 2003 or 2008, we're in 2000 Ucmuctxy, I just waist to -- A 2002 I believe, this is five, yes. Q How long has he resided with you again? A The whole time? Q Are you currently employed? A Yes. Q How so? A At Macy's. Q Which Macy's? A Capital City. Q How long have you worked there? A Since Christmas Eve. Q Of '07? I A This year, yes. i Q Prior to Macy's, where were you employed? A Pinnacle Health for a couple months, Psychological Associates. It was in Brady Hall. Q Okay. Was your actual employer Pinnacle Health or Psychological -- A Psychological Associates. Q You said for a few months? A Yes. Q Tell me what month you started and what month that you finished. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 6 A September 25th to December 14th. 12 Aiad VV a0 thut employment directly -In -r n1 I ;h Psychological Associates or through a temporary agency? A Through the hospital, through Pinnacle Health, yes. Q And what did you do at Psychological Associates? A I was a sectionary receptionist -- secretary receptionist. Q And why did you leave their employment in December? A Well, actually they let me go. I accidently sent out a form. It's against the HIPAA rules with the wrong patient, it really -- it was not a real good fit. I should have left myself before, but -- Q Prior to psychological Associates, where did you work? A ten years Q A Q A Q A Q I was laid off from Pealers Flowers. I was there Downsizing. All right. When were you laid off? June 4th. Of what year? This summer 107. '07? Yes. You started with them sometime back 197? 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 7 A '97, September 197. Q V-1at Uld you do for cealcrs? A I was a customer care manager, call center manager. Q Tell me the full extent of your education. A Well, four years of college, Millersville, teaching, B.S. in education, elementary education. Q When did you obtain that degree? A '78, '78. Q You had a teaching, I believe elementary education? A Yes, B.S., education. I had a dual major, early childhood and el ed. Q Were you ever employed in the education field? A No, not directly, not in a school district. I was -- I was a daycare director when we lived in the Poconos years ago. Q Prior to this case, were you ever named as a defendant to a lawsuit before? A Never. Q Other than this case since it was filed, have you been named as a defendant to a lawsuit? A No, sir. Q Do you recall the date for this accident? A It was October I think 21st or 22nd, 105. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 8 Q Prior to October 22 of 2005, were you involved in any uLliei accidents? A (Witness shaking head no). Q Is that a no? A I am sorry, no. Q That's okay. Since October 22, 2205, have you been involved in any motor vehicle accidents? A No. Q As a result of this accident, did you give any statements to anyone other than to your attorneys office such as an investigating police officer or your insurance company or the Reinfords' insurance company? A I -- maybe to the insurance company. I don't -- I honestly don't know. Q Okay. Was there a recorded statement given? MR. COOK: I don't recall one. I can doublecheck. THE WITNESS: No, I think maybe she just called to tell me what was happening or -- BY MR. SADLOCK: Q Okay. Other than for any charges that may have developed from this particular accident, have you ever been charged with any other crimes in the Commonwealth of Pennsylvania? A No, sir. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 9 Q All right. Convicted of any other crimes? A No. Q Any other traffic violations other than for this accident? A No, sir. Q Again, other than as it pertains to this accident, has your driver's license ever been suspended or revoked for any reason? A No, sir. Q Do you currently hold a Pennsylvania driver's license? A Yes, sir. Q Have you held a license from any other state other than Pennsylvania? A No, sir. Q When did you get your driver's license? A I think when I was seventeen, so I can't even think. 173, maybe seventy-two, seventy-three. Q What's your date of birth? A March 13th, 1956. Q And during -- when you were first studying to get your license, did you take driver's education? A Yes, in school. Q At that time, during driver's education, did you take or have any education or training as it pertains to • 10 1 L 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 driving after consuming alcoholic beverages? don' t kno:•? ma-1 rbe T don't know. Q Since that time, from the time that you got your license up to the date of this accident, had you seen any ads on T.V., seen any billboards or read any articles or aware in any way, shape or form about driving after consuming alcoholic beverages? A Yes, yes, yes. Q What was your understanding about driving after consuming alcoholic beverages? A That you shouldn't do it, you could hurt yourself, hurt somebody else. Q So prior to October 22, 2005, you were aware that driving under the influence of alcoholic beverages increases the likelihood or risk of injury to yourself and others? A Yes. Yes. Q Prior to October 22 of 2005, were you aware of the effects on an individual consuming alcohol in terms of ability to operate a motor vehicle? A Yes. Q Was that your understanding prior to October 22nd? A That you don; t have tiie reactions, and you are not yourself. 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Your ability to see, perceive and react is greatly effected? A Absolutely. Q Was it your understanding as well, again in October of 2005, that the more alcohol consumed, the greater effect on your ability to operate a motor vehicle safely? A Yes. Q Again, the more you consume, the ability to see, perceive and react decreases? A Correct. Q You were aware of that prior to October 22? A Correct. Q I believe that the accident, according to the police report, happened at about 8:39 in the evening. Is that your understanding? A Yes. Q Do your recall what day of the week October 22 was? A I believe it was a Saturday. Q Do you recall what you did that day prior to the accident? A Yes. Got up, had breakfast, did some cleaning, got my mom, went to a baby shower, came back, and I was doing cross word puzzles. He was -- we were watching 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 A G 'S 25 football. And -- YoU ,^+-;__Mr1 Irnil had a hahv shnWPr_ Where was ?J 1 lll.la tivaa.. ?a I 1 that baby shower? A Baughman Church in New Cumberland. Q Was that for a family member or friend? A Friend. Q Was there any alcoholic beverages served at the baby shower? A No, no. Q Allow me to finish my question. It's okay. It's all right. So far I haven't changed midstream, but occasionally you never know when I might start a question and change my mind in mid-question. You want to make sure that you hear the question. Again, so the court reporter only has to worry about taking one of us down at a time. Prior to leaving for the baby shower, had you consumed any alcoholic beverages? A No. Q You mentioned you had -- I think that you had breakfast that morning? A Yes. Q Do you recall what you had to eat? A Eggs, toast, bacon. n LTL, u -,i- t;,,,c Wa° the h?h?r chnunr? A I think -- I think it was around one. 13 l 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q What time did it end? A 'Three - i sh . Three, four we yo L iloiiie. Q You mentioned that you picked up and brought your mom to the shower, is that correct? A Yes. Q Did you take her back to your house or drop her off at her house? A No, I took her to her home. Q You continued then to your home? A Yes. Q Was your current husband at home when you got home? A I -- he wasn't my husband. Q I know that. A But yes, he was there. Q What did you do the rest of the day up until the time of the accident? A Up until the time of the accident, we were sitting watching football. I was doing crossword puzzles, and we had a couple glasses of wine. Q When you say a couple glasses of wine, can you -- A I have no idea. I have no idea. Q Were you drinking - was this wine from a bottle ur d box that -- A Yes, a box, a box, yes. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 14 Q White wine, red wine, do you know? A White. Q Again, do you know how many glasses that you had? A I have no idea. I have no idea. Q Had you consumed any other alcoholic beverages on October 22, 2205 other than wine? A Not to my recollection. Q Were you on any medication on the day of the accident? A Well, I have a regular medication that I take. I have Atenolol. I take Lexapro, Azichol for -- I have Crohn's disease, and whatever vitamins that I take. Q The other -- you mentioned one -- the drugs that you take for Crohn's disease. What do you take the other medications for? A I had panic attacks when my ex-husband and I first moved back here, so she gave me the betablocker, which is the Atenolol and the Lexapro which is a serotonin booster to stop all of the -- Q These are medications that you took on October 22, 2205? A I take them every day. Q Are they medications that you take in the morning? A Morning. 1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 15 Q Had you taken them then on that day? T Yes. Q On any of those medications that you take, was there any warnings about taking those medications and consuming alcoholic beverages? A No. No. Q Or any interactions between these drugs and alcohol? A No. Q Was Mr. Cliber also consuming wine? A No. Q What was he drinking, if anything at all? A He had beer. Q Did you have any beer? A No. Q Any hard alcoholic? A No. Q Gin, vodka, anything of that nature? A No. Q Just wine? A Just wine. Q The box that you were drinking from, had you just -- do you know how long that you had that box prior to -- A Nn; T have no idea, none, I have no idea. Q Had you just purchased it that day or -- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 16 A No. I -- no. I did not go to the store that day, no. Q You mentioned that you had breakfast in the morning. Did you have any other food of any kind up to the time of the accident? A Yes. There was tea sandwiches, vegetables, all kinds of stuff at the shower. I had no cake, but I ate other things. Q You said that you got home somewhere between three and four, is that correct? A Uh-huh. Q Is that a yes? A Yes. Q Prior to leaving your home and ultimately being involved in the accident, did you have anything to eat further at your home? A No, I did not. Q You mentioned that you were drinking wine. Were you drinking -- what type of glass were you using? A Just a little wine glass. Q Do you know how many ounces that glass held? A I have no idea. Q You don't recall how many glasses that you had? A No, I do not. Q You mentioned that Mr. Cliber was drinking beer. s 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Do you recall how much beer he had to drink while you were home? A I have no idea. I have no idea. Q Was there anyone else at your home that evening? A No. Q Obviously since you were involved in the accident there came a time period where you left your home that evening, is that correct? A Yes. Q What was your reason for leaving your home? A Really stupid. They kept flashing this Burger King commercial. And it wasn't that far, I felt fine, and I went. And I went into the Burger King to get the hamburgers. They said they did not have them. Then I pulled out on the road, was going home, and then that's.... Q What type of hamburger were you going for? A It's a kind -- this is so stupid. God. It's called a big angus burger, and it was a really good hamburger. Q They were sold out, they didn't have them? A She said they weren't carrying them. Q How far is the Burger King from your home in New Cumberland? A Less than a mile. Maybe a mile. Less than a mile. 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q And at that point -- what time was it when you left your home? A I wasn't paying attention. I don't know. A little bit after eight. 8:15, 20. I don't know. Q And had you been consuming wine that entire four hours since you had been home? A Well, off and on, yes. I was sitting watching football and -- Q Prior to October 22, 2005, how often did you consume wine? A A couple times a week. Q When you did drink, how much would you drink generally? A A couple, two, three glasses I guess. Q Two or three glasses two or three times per week? A When I was at home, yes. Q Prior to October 22 of 2005, had you ever yourself considered yourself intoxicated? A Probably in college. Q Any time more recent than that? A Not that I can think of, no. Q Those times back in college when you felt yourself intoxicated, how would you describe how you were teeling at that time'? A Well, you just had too much beer at a party, you 19 1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 just felt woozy and -- Q on Octoher 22; 2005, before you left your home to go to Burger King after consuming wine, were you slurring your speech at all? A No. Go ahead. Q Were you having any difficulty standing or walking? A No, sir. Q Although you don't know or don't recall how much wine that you consumed? A I do not. Q What was your blood-alcohol reading following the accident? A It's in the police report. Whatever it was that they said. I don't recall that. It's there somewhere. Q The police report indicates your blood-alcohol concentration was point 222. Does that refresh your recollection? A That's what they said it was, yes. Q Did you in any way contest that at any time? A I didn't think that you really had a right to do it. Q Are you aware that's approximately three times the level for intoxication? MR. COOK: I will object to the form of the 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 question simply because I think -- I am trying to remember when they amended the statute. BY MR. SADLOCK: Q well, if in fact the statute was amended at that time, we're saying point 08 was the level. That would have been approximately three times, correct? A From what you are saying, yes. Q If it was point 10, more than two times the limit, is that correct? A I guess. Q Before leaving your home on that evening, did you consider whether or not you should go given that you were drinking? A I did. I did not feel that there was anything wrong. Q You left your home alone? A Uh-huh. Q Is that yes? A Yes. Q Did Mr. Cliber make any effort to stop you from going because of your consuming alcohol? A No. Q But again, prior to leaving your home on that evening, you were aware of the effect of aicoiivl anu tiie ability to safely operate a vehicle? 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes, if I would have felt strange -- I don't drink and drive. If I am allowed to elaborate, I think if I would not have felt fine, I never would have gone for the hamburger or anything else. Q Do you -- do you ever drink out at bars or restaurants? A Back in the day, no more. Q When you say back in the day, when was the day? A Twenties, twenties, early. Q When your age was in the twenties? A Yes. Q Since then you do not go out to bars, restaurants or -- A We do -- if we -- we'll have a drink, but we don't really go out anywhere any more. Q Have any of your job changes in any way been associated with consumption of alcohol? A No, sir. Q What is your current height and weight? A Five-four, and I weigh too much. I don't have to tell you how much I weigh, do I? Q Yes, you do. A 165 maybe. O Any change in that from October 2005 to the present? Were you the same then as you are now? 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No, I have been gaining weight. Q How much would you weiyii -- or did you weigh , if you recall, on October 2005? A Twenty, maybe thirty pounds less. Q Tell me what you remember about the automobile accident of October 22, 2205. A I just remember pulling out of Burger King, and I pulled right on the street. And the next thing I saw was the vehicle. And I swerved to not hit it and then I hit it, and that's all. Q What street is the Burger King located on? A Bridge Street in New Cumberland. Q What street were you turning on to? A I was turning out of Burger King on to Bridge Street. Q Okay. The police accident report indicates the accident happened at the intersection of Walton Street and South Third Street. A Well, it's called Bridge Street. I don't know why they call it South Third. It's -- in Lemoyne would be Third Street, and New Cumberland, it's Bridge. Q All right. Coming out of the Burger King parking lot, would you have made a left turn or right turn? A RighL Luin. Q When you first got to the exit for Burger King, 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 did you have to stop before making the turn? A I slowed and Liere was no traffic, and I just pulled on the road. Q As you were pulling onto the road, did you see the Reinfords' vehicle? A I did not see -- I did not see the vehicle. Q How far did you travel before the accident happened? A It was about a block. Q Can you give me an estimate in terms of feet for that block or miles? A I have no idea. It was about maybe three or four hours. I -- Q In those three or four hours, did you see the Reinford vehicle? A At the very last moment, I had. I don't recall lights. I don't recall seeing anything. Q Mr. Reinford was driving a truck pulling a camper, is that correct? A That's what I understand, yes. Q And is it your testimony that you traveled three houses or a city block and never saw their vehicle until just prior to impact? A Yes. Q Was there anything obstructing your vision 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 through the windshield? A No. Q Anything other than the -- possibly the effect of alcohol effecting your ability to see or perceive their vehicle? A It was dark and it was rainy. That's -- until the vehicle was there. Q Did you have your headlights on when you left the Burger King? A Oh, yes. Q Low beam or high beam? A Regular, no, just regular lights. Q You said that it was raining. Was it -- how would you describe the rain? A Drizzle. It was warm and drizzly. Q With your windshield wipers going? A I don't think so. I don't think so. Q How fast were you traveling immediately prior to the accident? A Well, not that fast. Twenty, I don't know, twenty-five, I don't know. I don't normally drive very fast anyway. Q Did you have any food or beverages in the car? A I don't recall, no, because I didn't have my burgers, no, the money was laying on the -- 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Back in October 2005, did you smoke? A Yes. Q Did you have a cigarette lit just prior to the accident? A I don't remember. Q Was your radio on in the car? A I don't remember. Q Did you have a cell phone at that time? A I did have a cell phone. Q Were you talking on the cell phone prior to the accident? A No, sir. Q When had you last consumed alcohol prior to leaving your home to go to Burger King? Had you just finished a drink? A I don't remember. Q You mentioned that you were consuming wine from a box. Was the box -- how full was the box when you started? A I have no idea. Q Did you check it after the accident? A No, I didn't even go near it, no. Q Has there been any change in your drinking habit since this accident? A Yes. Q How so? 26 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Well, I hardly drink any more, and I would never ?- i7i rincr don't- do leclVe Illy 11(J115e. Yv'C dvii't go cut to us.a.aa...?. We do things that we would have done and take any kind of chances any more. Q I believe in some ads it talks about drinking and driving, it talks about impairment begins with the first drink. Have you heard that before yourself? A Yes. Q Did you hear that before October 22, 2005? A I am sure I have. I am sure I have. Q Did you give that any consideration before going out on October 22, 2005? A I didn't really think about it because I did not feel intoxicated. Q Even though you weren't aware of how many glasses of wine that you actually consumed? A No. Q Or what your blood-alcohol level was before leaving the house? A Correct. I Q Describe the accident for me, please. What happened? A I did already. I just came up on the truck and I hits. And I -- well, I tried to swei ve an' t11 I hit it again. That's all. At that point, I just went into shock. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 411 25 27 I remember nothing before after or anything. n ra + Inc . ,, F an I ,rch n c mn?si ni-r c.nc?n vnii hi 1- u YYC1 ?7 1.11G ll\..:-Lnfo dS v. ,h-i. -l l a me- r !ra.= ••rrerr l v... J it, or was it stationary? A I seemed to me to be I guess stationary. I mean, like I said, it just -- it all went into a blur. Q Did you strike the actual vehicle that Mr. Reinford was operating or the trailer? A The trailer. Q You hit the trailer first. Did you ever hit the vehicle that Mr. Reinford was driving? A When I bounced, it -- I guess when I turned, it hit up further a little bit. Q What happened then after the accident? A I sat in my car. The police officer came, and he said were you drinking and I said yes, I was. And he took me out of the car, and he wanted me to do the walk thing. And I said to him that I have a bad back and bad knees, that it wasn't going to really make a difference. And so then -- I don't remember in between, then he -- they handcuffed me and took me in the back of the car and took me to Carlisle. Q Did you actually perform the walk test? A I did it up there. I mean I was fine. I just jaid righ t i1oV?i if you ivuilt c tv, i arvuidn't do 'mot for I'^' Q Did you have any difficulty at the accident scene 28 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 remembering your telephone number or home address for the police officer? A No. Q Did you slur your words to the police officer? A Maybe I had, I don't know. I don't think I had, but -- Q Did you have any contact with Mr. or Mrs. Reinford at the accident scene? A No. Q Have you had any contact with them since that date to the present? A Not to my knowledge, I have not. Q You were charged with driving under the influence? A Yes, sir. Q You pled guilty to that? A Yes, sir. MR. COOK: Well, I will object to the form. I don't think that actually accurately reflects what occurred. There was an A.R.D. placement, which would not be the functional equivalent of a guilty plea. BY MR. SADLOCK: I Q Just so we're clear. You didn't contest the charge, is that correct? I A No. 29 1 G 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 L 3 25 Q For example, didn't proceed to trial? T T.T- ri avv . Q And your license was suspended, is that correct? A Yes. Q For a period of I believe it was sixty days? A Yes. Q Did you get your license back? A Yes. Q As part of the A.R.D. program you also had to attend DUI school and counseling, is that correct? A Yes, yes. Q Where did you attend that? A Oh, where was it? A church in Mechanicsburg. I can't remember the name of it. Q For how long did that program last? A Six weeks I believe. Q Other than that program, have you ever been yourself referred or by anyone else referred to attend an alcohol-type program? A No, sir. Q Or attend Alcoholics Anonymous or anything of that nature? A No, sir. 1..., a.. n rt.,. n ..: F .. ,.. A u Are you aware of anything t_11Q1. 1.11 . lZe-ML1/tu himself did in the operation of his vehicle that caused or 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 contributed to this accident? A I have no idea. MR. SADLOCK: Thank you, ma'am. I have no other questions. MR. COOK: I don't have any other questions. (Whereupon, the deposition was concluded at 10:00 a.m.) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 31 COUNTY OF DAUPHIN nn J J COMMONWEALTH OF PENNSYLVANIA : I, Maria N. O'Donnell, a Notary Public, authorized to administer oaths within and for the Commonwealth of Pennsylvania, do hereby certify that the foregoing is the testimony of VALERIE CLIBER. I further certify that before the taking of said deposition, the witness was duly sworn; that the questions and answers were taken down stenographically by the said Reporter-Notary Public, and afterwards reduced to typewriting under the direction of the said Reporter. I further certify the said deposition was taken at the time and place specified in the caption sheet hereof. I further certify that I am not a relative or employee or attorney or counsel to any of the parties, or a relative or employee of such attorney or counsel, or financially interested directly or indirectly in this action. I further certify the said deposition constitutes a true record of the testimony given by the said witness. IN WITNESS WHEREOF, I have hereunto set my hand this 2ND day of JANUARY, 2008. d 1;:)iAk;ti, `SAL k 1 I L i.iAXIA N. O'pprJ1•lEll M r a . O'Donnell , PR Notary Public Notary Public LSUS-7iJEHANNA T WPDAUPHIN COUNTY ommission Expires T'lay T 3 EXHIBIT "C" RHONDA L. REINFORD AND R. TIMOTHY REINFORD, HER HUSBAND, PLAINTIFFS V VALERIE LAIR, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAN COUNTY. PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3609 CIVIL TERM JURY TRIAL DEMANDED DEPOSITION OF: RHONDA L. REINFORD TAKEN BY: DEFENDANT BEFORE: MARIA N. O'DONNELL, RPR NOTARY PUBLIC DATE: JANUARY 2, 2008, 10:00 A.M. PLACE: ANGINO & ROVNER, PC 4503 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA APPEARANCES: ANGINO & ROVNER, PC BY: RICHARD A. SADLOCK, ESQUIRE FOR - PLAINTIFFS GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS BY: DAVID E. COOK, ESQUIRE FOR - DEFENDANT ALSO PRESENT: R. TIMOTHY REINFORD I EF 2080 Linglesto?wn Road • Suite 103 • Harrisburg, PA 17110 717.540.0220 • Fax 717.540.0221 • Lancaster 717.393.5101 Multi-Page`"` RHONDA L. REINFORD JAN UAK Y Y., LUU7 Page 2 Page 4 WITNESSES 1 As part of this process, and I think your counsel 2 NAME EXAM.NATLON 2 had indicated before, when you answer a question, I am 3 RHONDA L. REINPORD 3 going to assume that you heard the question and you 4 BY: MR. COOK 3 4 understood the question. Okay? Fair enough? 5 BY: MR. SADLOCK 72 5 A Right. Yes. 6 6 Q Again, one of the more important aspects of this 7 is, one, we not talk over each other because it certainly e 8 makes it easier for the stenographer to take everything 9 9 down. But secondly, verbal answers. It's certainly easier 10 10 to record yes or no than trying to indicate a nod of the 11 11 head. So if from time to time that does happen, I will try 12 12 and correct you or your counsel may try to correct you. 13 13 Okay? 14 14 A Okay. 15 15 Q Again, the same rules. This may take -- it will 16 16 take a little bit longer than Miss Cliber's deposition, but I, 17 if at any time you feel the need to stand up, get up, take 18 18 a break for any reason whatsoever, please let me know and I9 19 we can do that; okay? 20 20 A Thank you. 21 21 Q Sure. 22 22 Now, your full name? 23 23 A Rhonda Lee Reinford. 24 24 Q How do you spell the middle name? 25 25 A L-e-e. Page 3 I STIPULATION 2 It is hereby stipulated by and between counsel 3 for the respective parties that reading, signing, sealing, 4 certification and filing are hereby waived; and that all 5 objections except as to the form of the question are 6 reserved to the time of trial. 7 8 RHONDA L. REINFORD, called as a witness, being 9 duly sworn, testified as follows: 10 EXAMINATION 11 BY MR. COOK: 12 Q Okay. Mrs. Reinford, my name is David Cook. 1 13 represent Mrs. Lair, now Mr. Cliber in this matter. 14 You heard in part instructions before regarding 15 the deposition. Were you clear on those? 16 A Yes. 17 Q You understood those? 18 A Yes. 19 Q All right. As indicated, I am going to ask you 20 some questions. I will try to keep my voice up from time 21 to time because it is a smaller room, I may tend to drop 22 it, but if at any point you can't hear me, just let me 23 know. If you don't understand the question, let me know, 1 24 will be more than happy to rephrase or ask it a different 25 way. Page 5 1 Q Have you been known by any other names before 2 that? 3 A Ronnie. 4 Q You go by Ronnie as a short name for Rhonda, 5 correct? 6 A Yes. 7 Q Maiden name? 8 A Stehman. S-t-e-h-m-a-n. 9 Q Now, what's your date of birth? 10 A June 23, 1964. 11 Q And your current address? 12 A 227 Walton Street, Lemoyne, Pennsylvania. 13 Q And how long have you lived there, approximately? 14 A Six or seven years. 15 Q And who do you live there with, anybody else? 16 A Yes, my husband Timothy. 17 Q Okay. And during that six or seven-year period 18 besides your husband, does anyone else live there with you? 19 A My daughter, Miranda. 20 Q How old is Miranda? 21 A Nine. 22 Q She's from this marriage? 23 A Yes. 24 Q Do you currently have a driver's license? 25 A Yes. Page 2 - Page 5 rn ri'+TTro ?T 77D T/'?LTT T;IIT T7 7?TATAT i.' '71'7 GAA A'1 ?1A /^71'7 ZAP C1A7 RHOND4 L. REINFORD JANUARY 2, 2007 Multi-Page rat Page 6 1 Q About how long have you had that? 2 A Since I was 23. 3 Q Okay. Did you receive any driver's ed training 4 prior to getting your license that you recall, whether that 5 be maybe in high school or drivers ed class or maybe 6 through AAA or -- 7 A My father would take me out driving when I had my 8 pen-nit. 9 Q He wasn't like an instructor of any kind, just 10 dad knew how to drive, he had a license and he taught you; 11 fair enough? 12 A Yes. 13 Q After you got your license, do you remember 14 taking any other -- or any classes geared toward safe 15 driving or drivers ed or anything like that? 16 A No. 17 Q Has your license ever been suspended? 18 A No. 19 Q All right. Graduated from high school? 20 A Yes. 21 Q Which high school, which year? 22 A Cedar Cliff, 1983. 23 Q After Cedar Cliff, did you have any other 24 education or training? 25 A HACC. Page 7 1 Q When did you attend HACC? 2 A 1998 I believe. 3 Q Any degrees, certificates? 4 A CNA certificate. 5 Q That was awarded in 1997? 6 A '98 or '99. 7 Q I am assuming that was a specialized program that 8 you attended? 9 A Yes. 10 Q And you successfully completed that, I am 11 assuming, in order to get the certificate? 12 A Yes. 13 Q Any other -- HACC was the Harrisburg campus? 14 A No. I took the course at Masonic Homes in 15 Elizabethtown. 16 Q What did you have to do in order -- or as part of 17 this program? What were the requirements? 18 A I don't understand -- 19 Q Okay. 20 A -- what you are asking me. 21 Q Were there specialized classes that you had to 22 take as part of the CNA program at HACC? 23 A It was for the CNA course. And the teacher from 24 HACC would come to Masonic Home and teach the course to 25 several students. Page 6 - Page 9 Page 8 1 Q Okay. A different way I guess. Was it broken 2 down into say like a biology component or any 3 individualized aspects to it, or was it just one class that 4 this is what we learned during this time period? 5 A It's hard for me to recall back then. It's been 6 awhile. No, we just learned how to clean people up, you 7 know, hygiene. 8 Q Okay. Was most of it hands-on training, or was 9 there a classroom component? 10 A Mostly out of a book, some of it was hands on. 1 I Q Other than the program at HACC, did you have any 12 other education or classes that you attended? 13 A No. 14 Q Okay. All right. Have you ever been convicted 15 of a crime? 16 A No. 17 Q Charged with a crime? 18 A No. 19 Q I probably should have mentioned before some of 20 these questions certainly aren't meant to embarrass or to 21 pry, but as part of this process, we just need to ask; 22 okay? So -- 23 A Okay. 24 Q Ever in the military? 25 A No. Page 9 1 Q Okay. Now, about how long have you been married? 2 A Since November 1, 1997. 3 Q First marriage? 4 A No, sir. 5 Q Okay. Which marriage would it be? 6 A Second. 7 Q And prior husband? 8 A Brian Englehart. E-n-g-l-e-h-a-r-t. 9 Q Other than Miranda, any other children? 10 A No. 11 Q All right. Taking you back to before October of 12 2005, did you have any interests or hobbies, leisure 13 activities? 14 A Oh, my gosh. Skiing, tennis, sledding with my 15 daugh ter, art, gardening, a lot of activities. 16 Q Okay. Let's take those one at a time. Skiing, 17 how often would you do that? 18 A Not very often. 19 Q When you say not very often, about once a year? 20 A Yes, I haven't skied for awhile. 21 Q Okay. About how long before the accident would 22 you say was the last time? 23 A A couple years. 24 Q A couple years? 25 A Before I met him. HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 Multi-Page rM RHONDA L. REINFORD JANUARY 2, 2007 Page 10 1 Q Okay. How about tennis? 2 A Tennis we would play at the beach when we would 3 go on vacation. 4 Q Okay. Would that be once a year? 5 A Once a year, but -- well, we just got tennis 6 racquets after -- was it before or after the accident, and 7 I couldn't play. 8 MR. REINFORD: It was before the accident. 9 THE WITNESS: Okay. But I couldn't use my tennis 10 racquet. We got tennis racquets before the accident, I 11 couldn't recall, and I couldn't play any more after the 12 accident. 13 BY MR. COOK: 14 Q Okay. Was the time that you were at the beach 15 the only time that you really played tennis? 16 A Pretty much. 17 Q Okay. Now, when you went to the beach, was that 18 -- which beach are we talking about? 19 A Bethany. 20 Q And was this a yearly thing that you went? 21 A Yes. 22 Q Okay. Any other family or friends that were down 23 there or -- 24 A Yes. 25 Q Okay. You stayed at somebody elses house that Page 11 I had a house down there? 2 A Yes. 3 Q Friends, family? 4 A Yes. 5 Q Okay. 6 A Both. 7 Q Okay. Sledding? 8 A With my daughter. Every winter all of the time 9 whenever it snowed. 10 Q Well, let me back up for a second. You said 11 since the accident you don't play tennis any more? 12 A No. 13 Q Why is that? 14 A Because I can't. 15 Q Specifically what limits you from playing tennis? 16 A My body. 17 Q Okay. 18 A I hurt. 19 Q Feet, your ankles, your knees? 20 A My lower back, my thoracic area, my cervical 21 area. My hands go numb, my arms go numb when I grab 22 things . My hands tingle and burn. Walking long periods 23 hurts. Sitting long period hurts. Standing long periods 24 hurts. 25 Q We'll get to some of that in a little bit. Just Page 12 1 focus on the tennis part. 2 Lower back, thoracic cervical, hands and arms go 3 numb? 4 A Yes. 5 Q Is there anything else just related to tennis 6 that prevents you from playing tennis? 7 A I can't jump around, my reaction times. 8 Q Then sledding, what is it since the accident that 9 causes difficulty in sledding? 10 A Going down the hill. If we would wreck, that 1 I would make it worse. Climbing up the hill, I couldn't do 12 it. Well, yes, I have pain. 13 Q When you are talking about claiming up the hill, 14 what physically makes that difficult for you? 15 A I have nothing to hold on to. 16 Q Okay. Why is that necessary? 17 A Because it's hard for me to climb up things. My 18 lower back hurts very bad. My sciatic nerves hurt when I 19 take steps so I have to hold on to things in order to get 20 up steps. I would have to hold on to somebody in order to 21 get up a hill. 22 Q Okay. Is there any difficulty with your 23 involvement in art since the accident? 24 A Sitting long periods. 25 Q What kind of art would you be involved in? Page 13 1 A I paint and draw. 2 Q Then you mentioned gardening? 3 A Yes. 4 Q What physical problems do you have when you are 5 trying to garden? 6 Well, let me ask it a different way. What type 7 of gardening would you do? 8 A Pulling weeds. 9 Q Anything besides pulling weeds? 10 A No. 11 Q And so when you are pulling weeds, what physical 12 problems do you have that make that difficult for you now 13 as opposed to before? 14 A I have pain bending over. 15 Q Okay. Are there any other activities that you 16 were involved in before the accident that since the 17 accident are difficult or that you can't be involved in at 18 all? 19 A Yes. 20 Q What are those? 21 A Grocery shopping. 22 Q Okay. Anything else? 23 A I am too nervous right now, I can't answer. 24 Q Do you need to take a break? 25 A Yes. Page 10 - Page 13 RHONDA L. REINFORD Multi-Pager' JANUARY 2, 2007 1 MR. COOK: Okay. 2 (Brief recess.) 3 BY MR. COOK: 4 Q Are you ready? 5 A Yes. Page l4 1 A Yes. On the road, on the street. 6 Q Any time that you need to break, just let us 7 know, we will be more than happy to accommodate you. 8 A Thank you. 9 Q We left off with other activities, and you 10 mentioned grocery shopping. Is there any other activities 11 since the accident that are difficult for you or that you 12 can't be involved in? 13 A Housework. 14 Q Okay. Okay. Anything else? 15 A Laundry. That's the same thing. Bike riding. 16 Q Okay. 17 A I would teach the children in the neighborhood 18 and my daughter gymnastics, show them how to do it. I 19 can't do that any more, it's too much pain. It's painful 20 to do everything. 21 Q Let's cover grocery shopping first. What is it 22 that makes it difficult for you to go grocery shopping? 23 A Sometimes lifting heavy bags. If they're too 24 heavy, I will have someone else do it for me. I go to the 25 customer service and ask for them to load my truck. Page 15 1 Q Now, was this something that you were responsible 2 for or did prior to the accident? 3 A Yes. 4 Q Okay. 5 A I don't shop much any more. Timothy normally 6 does it now. 7 Q All right. Now, work and laundry. What 8 difficulties do you have there? 9 A With everything, I have pain. 10 Q When you talk about pain, specifically what -- 1 I A Running the vacuum. It's painful to do that. 12 Q What parts of your body are in pain? 13 A My lower back and my thoracic area. 14 Q Okay. The laundry, how is that? 15 A I can't lift the heavy baskets, Timothy does that 16 now. 17 Q Okay. So if he lifts the baskets, are you 18 otherwise able to do laundry? 19 A I can fold sometimes and not for very long. 20 Q You also mentioned bike riding. Prior to the 21 accident, about how often did you do that? 22 A Probably once a week. 23 Q Where would you typically ride? 24 A Around the neighborhood. 25 Q Paved streets? 2 Q And about how long would you ride? 3 A I don't recall. I never timed myself. 4 Q Okay. Did you go out for fifteen minutes, a half 5 hour, hour, just roughly? 6 A Probably two, three miles, maybe more. 7 Q Okay. Page 16 8 A Let's see. I could ride my bike from my street 9 on Walton Street all of the way down through New Cumberland 10 to the Giant, is that Old York, Fairview? I 1 MR. REINFORD: Yes. 12 THE wrrNEss: Down in New Cumberland, I could 13 ride my bicycle down and back. So that's probably more 14 than two miles, two or three miles. 15 BY MR. COOK: 16 Q Okay. Again, what makes it difficult now? 17 A The pain in my lower back and holding onto the 18 handle bars. My hands burn and fall asleep and I get pain 19 in my arms. They go numb. 20 Q Okay. All right. Now, at the time of the 21 accident, you were employed with Pinnacle? 22 A Yes, sir. 23 Q Is that correct? 24 How long had you been employed with Pinnacle? 25 A Since August of 2000. Page 17 1 Q Were you employed with anyone else during that 2 time period? 3 A No. 4 Q Was there any temp service or temp agency, 5 placement agency? 6 A I don't understand what you mean. 7 Q Okay. All right. I will show you -- this is a 8 copy of a W-2. 9 A Okay. 10 Q From 2005. Elite Staffing. 11 A Explain to me what you mean by the question. 12 Yes, I left Pinnacle and I went to Elite Staffing to take 13 care of a lady, and then I went back. 14 I didn't understand what you meant by -- about 15 the question. 16 Q That's part of what I was asking you is you were 17 -- what you are indicating is during that time period from 18 August of 2000 through the date of accident, you were 19 employed with Pinnacle? 20 A Right -- no. 21 Q Okay. 22 A I was employed with Pinnacle, I got hired in 23 August of 2000. 24 Q Okay. How long were you with Pinnacle? 25 A I don't recall. 'age 14 - Page 17 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 Multi-Pager` RHONDA L. REINFORD JANUARY 2, 2007 Page 18 1 Q Okay. Do you recall why you left Pinnacle? 2 A No, I really don't. 3 Q Do you recall why? That was -- that was the last 4 question. 5 MR. SADLOCK: Yes. 6 BY MR. COOK: 7 Q Okay. And you are indicating that you went to 8 Elite Staffing at some point in time to take care of -- was 9 it one patient or more than one patient? 10 A At first, it was more than one patient. 11 Q All right. Let me back up for a second. 12 A Okay. 13 Q Let me go through generally. You got your CNA in 14 1998 or 1999? 15 A Yes. 16 Q Where did you first work after that? 17 A Masonic Homes in Elizabethtown. 18 Q That's what, in 1999? 19 A Yes, sir. 20 Q And do you recall what you started at wage-wise 21 there? 22 A I think it was seven something an hour 23 Q Okay. 24 A During the course that we had to take. 25 Q Okay. Was that part of the class? Page 19 1 A Was what part of the class? 2 Q When you were working at Masonic Homes and you 3 were paid seven dollars an hour? Do you understand the 4 question? 5 A No. 6 Q Okay. Let me back up. 7 MR. REINFORD: May I interject? 8 BY MR. COOK: 9 Q I will clarify and see if I got it. 10 You indicated earlier that you took the classes 11 at HACC for the CNA? 12 A Yes. 13 Q That was at the Masonic Homes in Elizabethtown, 14 is that right? 15 A Yes. Yes. 16 Q Okay. Then you indicated that you are employed 17 at Masonic Homes in Elizabethtown? 18 A Yes. 19 Q All right. I guess what I am asking is -- 20 A Did they pay us while we were taking the course, 21 is that what you wondered? 22 Q Sure. Let's ask it that way first. 23 A Yes. 24 Q Okay. Is that what --when you were paid seven 25 dollars an hour? Page 20 1 A Yes. 2 Q Kind of like an internship I guess? 3 A I don't know if you would call it that. I 4 don't -- 5 Q After you completed the class, did you continue 6 to work at Masonic Homes? 7 A Yes. 8 Q Okay. All right. Was that at the same rate of 9 pay? 10 A No, it went higher. 11 Q Okay. Do you recall what it was? 12 A I think 9.20 an hour. 13 Q Do you recall approximately how long that you 14 were there at Masonic Homes? 15 A About a year. 16 Q Okay. 17 A And a half. 18 Q All right. Do you recall why you left? 19 A I wanted to make better money. 20 Q Okay. Did you find a position where you made 21 more money? 22 A Yes. 23 Q Where was that? 24 A Pinnacle Health Nursing and Support Services. 25 Q I am sorry, Pinnacle and -- Page 21 1 A Pinnacle Health Nursing and Supportive Services. 2 Q When you were there, what were your job 3 responsibilities? 4 A When I was where? 5 Q I am sorry, Pinnacle. 6 A Pinnacle. Taking care of patients, hygiene, 7 EKGs, vital signs, hemoccult, gastroccult tests, pushing, 8 pulling, lifting, standing, carrying heavy laundry bags. 9 Q All right. When you say pushing and pulling, 10 what did you have to push or pull? 11 A We had to push an EKG machine. We had to push 12 people in wheel chairs. We had to pull laundry bags. 13 Q Okay. You wouldn't happen to have any idea how 14 much an EKG machine weighed, would you? 15 A No. 16 Q Okay. All right. You also mentioned lifting. 17 What type of things would you have to lift? 18 A I don't recall. Lifting laundry bags. 19 Q During the time that you were at Pinnacle, was 20 there an average number of hours per week that you worked? 21 A It would fluctuate. 22 Q Why would it fluctuate? 23 A Because of being home with my daughter and my 24 husband to go to work. I don't -- I don't really recall. 25 Q Okay. Did you have one particular location that Page 18 - Page 21 TIT TlSTIT: C AT T2DTlST4T UnT T7 AT A T A T P 71 7-AZAn-n,),)ni71 7-1o1-,q1(11 RHONDA L. REINFORD JANUAR'f 2, 2007 Page 22 1 you were at all of the time, or were there different 2 locations at Pinnacle that you would go to during these 3 time periods? 4 A Yes. 5 Q Okay. Yes, you went to different locations, or 6 yes -- 7 A Yes, I went to different locations. 8 Q All right. Which different locations would you 9 go to? 10 A Osteopathic, Harrisburg Hospital, and Polyclinic. 11 Now this was all back when I first started with Pinnacle. 12 Q Okay. And why would you go from location to 13 location? 14 A Where ever help is needed, you would go. 15 Q Okay. 16 A They would direct you where to go. 17 Q Did you report to say one particular place, they 18 would direct you that day, or were there assignments that 19 would -- 20 A I would report to them that morning. 21 Q And you would go in that morning, they would say, 22 okay, you go to Harrisburg Hospital, or you would go to 23 Polyclinic or -- 24 A Now, I worked for the float pool. And when you 25 work for the float pool at Pinnacle at Harrisburg Hospital, Page 23 1 you go up to the floor, they tell you where to go in that 2 hospital. 3 Q Okay. 4 A If it was changed, they would call me at like 5 five o'clock in the morning and tell me where to go. If it 6 was changed, if they had enough staffing, they would say 7 hey, Ronnie, go to Osteopathic, you are needed there. So 8 that's what I would do. 9 Q Okay. So if I understand it correctly, unless 10 they call you at home, you went to Harrisburg Hospital 11 where they would then assign you somewhere at Harrisburg 12 Hospital? 13 A Yes. 14 Q Okay. If they wanted you to go to some other 15 location, they would call you at home, say don't come to 16 the hospital this morning? 17 A Yes. 18 Q Okay. Were there ever times when they would call 19 you and say we don't need anybody today? 20 A That was rare, very rare. 21 Q I am sorry, did you say there was a typical 22 number of hours a week that you worked? 23 A What did I work, about thirty hours a week. I 24 don't recall. 25 1 know that I was working full time for awhile. Page 22 - Page 25 Multi-Page ` A Page 24 1 I don't recall. Thirty to forty hours. I really don't 2 remember back in 2000 when I first started. 3 Q All right. What about as it got closer to 2003, 4 2004, 2005, always thirty hours then? 5 A Pretty much, yes. 6 Q Okay. 7 A What time is it? 8 Q About twenty of eleven. 9 A I have to take my medicine soon. 10 Q Do you want to take a break now? 11 A No, I have to take my medicine soon. 12 Q Okay. Was there ever a point in time that you 13 applied for unemployment compensation? 14 A Yes. 15 Q Okay. 16 A I don't remember when it was exactly, but I know 17 I did. 18 Q Okay. Do you recall a point in time maybe about 19 three weeks before the accident applying for unemployment 20 compensation? 21 A Yes. 22 Q Do you recall why that was? 23 A Census was low in the hospital. 24 Q What does that mean? 25 A It means that there is not a lot of patients in Page 25 1 the hospital at that time. 2 Q So because there aren't a lot of patients in the 3 hospital, they don't need as many employees. You were one 4 of the people that were I guess not being called in, is 5 that fair to say? 6 A Say that -- repeat that. 7 Q Okay. Because the number of patients was low? 8 A Right. 9 Q They didn't need as many staff at the hospital? 10 A Right. 11 Q Was it a temporary layoff or was it? 12 A Yes. 13 Q Okay. And did you ever go back? 14 A Yes. 15 Q Okay. Do you recall about when you went back? 16 A No. 17 Q When you did go back after the accident, what 18 were your duties at that point in time? 19 A I had to push a wheelchair. I just worked in 20 transport then after the accident. 21 Q Okay. Fair to say that transport would mean that 22 you would wheel a patient from one area of the hospital to 23 the other or from their room to maybe a testing area or 24 something along those lines? 25 A Yes. HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5I0I Multi-Pager" RHONDA L. REINFORD JANUARY 2, 2007 Page 26 I Q Okay. Did you have any other job 2 responsibilities at that time after the accident? 3 A Just transporting patients. 4 Q Okay. How long did you stay in that position? 5 A I don't recall. 6 Q Do you recall -- well, did that end at some 7 point? 8 A Yes, because I was in too much pain to do it any 9 more. 10 Q Did you receive any indication from any doctor as 11 to any restrictions for work after the accident? 12 A Yes. Yes. 13 Q Was your employer made aware of those 14 restric tions? 15 A Yes. 16 Q Did they make any effort to accommodate those 17 restric tions or place you in some type of position that 18 would fit within those restrictions? 19 A I don't recall. I don't. 20 Q Do you recall if you asked them to put you in a 21 position that would be in accordance with the restrictions? 22 A I believe I asked. I don't recall. 23 Q Okay. 24 A I was in just too much pain to do anything. 25 Q Was there ever a point in time that you were Page 27 1 injured while at work? 2 A As in? 3 Q Suffered any type of pain or anything else that 4 caused you to be of concern? 5 A Yes. 6 Q Okay. And do you recall approximately how many 7 times? 8 A Three times. 9 Q Okay. What were those three times? 10 A Once at Masonic Homes I had a lower back strain. 11 Q Okay. Now, when that happened, do you recall 12 what you were doing when that occurred? 13 A Yes. I was pushing -- do you want to know? 14 Q Yes. 15 A Okay. I was pushing a 300, 400 pound woman on a 16 stand-up lift. 17 Q I am going to ask. What is a stand-up lift? 18 A You have to put a strap around her back. She's 19 sitting in a wheelchair. You bring the machine up to her. 20 The platform of the machine rolls out. You put a strap 21 around her back and hook it to the machine. Then you push 22 levers and stuff, and it pulls her up slowly. 23 Q Okay. So it moves her from a sitting position? 24 A To standing position, yes. 25 Q Okay. Then once she's in a standing, he or she Page 28 I is in a standing position, what happens from there? 2 A Then I would have to push the machine over to the 3 toilet or the bed or where ever she had to go. 4 Q Okay. How in that process did you strain your 5 back or where in the process I guess? 6 A I was transporting her from the wheelchair on the 7 stand-up lift to the toilet. 8 Q Okay. So were you pushing her at the time or -- 9 I am trying to -- 10 A Yes, I was trying to transport her from the 11 wheelchair to the toilet. The wheelchair was here. The 12 toilet was right beside it. 13 Q Okay. Do you recall about what year that was or 14 where that was? 15 A 1999 at Masonic. 16 Q Was it earlier in the time period that you were 17 at Masonic or later? 18 A I don't recall. 19 Q Okay. Did you miss any work as a result of that 20 incident? 21 A No. 22 Q Okay. Did you seek any medical treatment as a 23 result of the incident? 24 A In-house at Masonic. 25 Q Is that just one visit or was it -- Page 291 1 A No, several. 2 Q Does it require any physical therapy or any -- 3 A No. 4 Q What was the second incident -- just before we 5 get on to the second incident, was there any workers' 6 compensation claim ever filed? 7 A No, no, I made a full recovery, went right back 8 to work. 9 Q Okay. 10 A I worked light duty for them. I1 Q Okay. 12 A So I was never off of work actually. 13 Q Okay. So while you are there, you went to get 14 in-house treatment, presumably one of the doctors told you 15 that you should be on light duty? 16 A Yes. 17 Q Okay. Then you informed them that you should be 18 on light duty, they accommodated that request? 19 A Yes. 20 Q Do you recall about how long that you were on 21 light duty? 22 A No. 23 Q Day, week, month? 24 A I don't recall, a week or two. 25 Q The second incident? Page 26 - Page 29 . 7 nnin_u'r milli T7 AT A T A T F 77 7_U(1_A77A/717_10Z_C i /il RHONI?A L. REINFORD JANUARY 2, 2007 Multi-Page "" ' Page 30 1 A A lower back strain I think at -- when I worked 2 for Pi nnacle. 3 Q How did that occur? 4 A I don't recall. 5 Q Okay. 6 A I think pulling a patient up in bed, yes. 7 Q Did you miss any work as a result of that? 8 A I don't remember. I don't think so. 9 Q Do you recall if you were given any restrictions 1o as a result of that? 11 A Yes, I was put on light duty. I remember that. 12 Q Was there any follow-up treatment as a result of 13 that? 14 A At Pinnacle Employee Health. 15 Q About how long did you treat as a result of that? 16 A I think -- how long did I what? It's hard to 17 hear. 18 Q How long did you treat? 19 A How long did I treat? 20 Q At Pinnacle Employee Health as a result of the 21 strain? 22 A How long did they treat me? 23 Q Yes. 24 A About three weeks. 25 Q Did you miss any work? Page 31 1 A No. 2 Q Third incident? 3 A A wrist strain. 4 Q Okay. Do you recall -- I am sorry. The second 5 one, the low back strain, do you recall about when that 6 was? 7 A 2002. 1 can't, I don't remember. 8 Q Okay. And the wrist strain, do you recall about 9 when that was? 10 A It was after 2002. 11 Q Do you recall how that happened? 12 A Locking a wheelchair. 13 Q All right. Did you miss any work as a result of 14 that? 15 A No. 16 Q Any treatment as a result of that? 17 A They x-rayed it and gave me a brace, then put me 18 on light duty. 19 Q Do you remember about how long that you would 20 have been on light duty? 21 A Probably a week. 22 Q Okay. All right. Prior to this incident, you 23 didn't know Miss Lair or Miss Cliber at all? 24 A No. 25 Q Okay. Can you tell me about the incident, what Page 32 1 you remember from it? 2 A About the accident? 3 Q Yes. 4 A I remember a mist. And we were driving up Third 5 approaching Walton Street. And Tim put his turn signal on. 6 And we were waiting for a car to come. There was an 7 on-coming car coming, and we were waiting for that car to 8 come. And I remember our truck jerking, and I twisted 9 toward him. And I said I think someone hit us. And as 10 soon as he said I think you are right, the only thing I 11 heard was squealing of tires and a crashing into the side 12 of our truck. 13 Q What happened, if anything, as a result of the 14 vehicle striking the side of the truck? 15 A What do you mean what happened? 16 Q Okay. Did anything happen to you? 17 A My body flew. I was twisted toward Timothy. He 18 was on my left side. 19 Q Okay. 20 A And my whole body flew. I wasn't holding onto 21 anything, and my glasses flew off. I don't recall, you 22 know, exactly what happened. I just remember my body -- 23 Q Just so I understand correctly, you are sitting 24 in the passenger seat? 25 A Yes. Page 33 1 Q All right. You heard something I guess off to 2 your left or behind you to the left? 3 A Uh-huh. 4 Q Or just behind you? 5 A I heard it off to our left side. 6 Q Okay. And then you turned twisting towards him', 7 A I twisted toward him to talk to him. 8 Q Okay. 9 A Because I felt the impact on the back of the to camper. I 1 Q Okay. You were wearing a seat belt at that 12 point? 13 A Yes, sir. 14 Q That also included a shoulder belt? 15 A Yes. 16 Q All right. Then there was the impact, and 17 that -- had you turned back prior to the impact, or were 18 you still? 19 A I was still twisted toward him. 20 Q Okay. Did you see anything in the side of your 21 mirror? 22 A When? 23 Q Prior to the I guess what we will call the second 24 impact? 25 A No. I didn't even think to look at a mirror. Page 30 - Page 33 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 Multi-Page TM RHONDA L. REINFORD JANUARY 2, 2007 Page 34 1 Q Okay. 2 A I was looking at my husband. 3 Q Regarding the trailer itself, does it have its 4 own set of brake lights and -- 5 A I am not the person to ask for that. 6 Q Okay. 7 A You would have to ask my husband. 8 Q Okay. Did you see the other vehicle before 9 impact? 10 A No, because I was looking at him. 11 Q Well, either impact, the first time that you 12 heard something hit? 13 A It was dark outside. 14 Q The back? 15 A And misty, so if I -- I didn't even think to look 16 at the outside left side if that's what you are referring 17 to. I didn't even think to look out the window, I just 18 thought someone bumped the back of our camper and that we 19 should find out what happened. 20 Q Okay. 21 A So-- 22 Q After the accident, did you get out of the car? 23 A Yes, I did. 24 Q Okay. And what happened once you got out? 25 A I walked around to Valerie to see if she was Page 35 1 okay. 2 Q Okay. And what happened once you got back there? 3 A She was just sitting in her car mumbling 4 something. I don't know what it was. I think it was oh, 5 my God. I tried several times to ask her if she was okay. 6 Q Okay. 7 A And I just pushed her head back to see if she was 8 okay. I lifted up her hair actually just to see maybe if 9 she was bleeding or anything. 10 Q Was she slumped forward in any manner? 11 A Yes. 12 Q Was it just that her head was down, or was her 13 body more forward, or how would you describe that? 14 A No, she just looked like she was upset about what 15 happened or being in an accident. She was just upset I 16 believe. 17 Q All right. 18 A But I could hardly understand what she was 19 saying. 20 Q Okay. Now, at some point in time, the police 21 arrived, is that correct? 22 A Yes. 23 Q Were you still there when they arrived? 24 A I believe so, yes. 25 Q Do you know who called the police? Page 36 1 A A neighbor on the comer of Third and Walnut -- 2 Walton, pardon me. 3 Q Did you make any statements to the police 4 officer? 5 A I don't remember. 6 Q There is a videotape of the accident that 7 happened that night. Do you have any knowledge as to who 8 took that? 9 A Yes. 10 Q Who took that? 11 A Timothy. 12 Q Is there a video camera in the vehicle to the 13 best that you recall? 14 A Yes. 15 Q Now, did you go to the hospital that night? 16 A No. 17 Q All right. Did you tell the -- as best as you 18 recall telling the officer that you were feeling any pain 19 or any injuries? 20 A I don't recall, I don't. 21 Q To the best that you recall, did any part of your 22 body strike any part of the inside of the passenger 23 compartment of the vehicle? 24 A I cannot remember, honestly. 25 Q When is the first time that you recall feeling Page 37 1 any pain or discomfort as a result of this accident? 2 A I think it was a day or two after. 3 Q Okay. 4 A But I thought it was a normal thing just being in 5 an accident, you feel kind of roughed up a little bit, but 6 that's all I -- 7 Q Was this the first motor vehicle accident that 8 you were involved in? When I say involved in, I don't 9 mean just that you were a passenger in a vehicle that may 10 have been hit or driver in a vehicle that may have been 11 hit, you may have been a driver that was -- and/or 12 passenger that was -- that hit another vehicle, any of 13 those? 14 A I know that I was in an accident, but I can't 15 remember when it was, but I wasn't hurt at all. 16 Q Do you remember ballpark about when that was? 17 A No, I don't, no. 18 Q More or less than ten years before this? 19 A I think less than ten years, I think. 20 Q More or less than five? 21 A I don't know. 22 Q Okay. Do you remember what the circumstances of 23 the accident were? 24 A No. 25 Q Or if you were a driver or passenger? Page 34 - Page 37 v i1"N1 ViT T;4-1T -1-7 1T A'T AT T: '71^1 CAA 71-1'1n7^71^7 '11V9 C1 n1 RHOND4 L. REINFORD Multi-Page""" JANUARY 2, 2007 Page 38 Page 40 1 A Let me think. I don't know. I can't remember. 1 A I don't remember. 2 Q All right. Is there any -- strike that. Okay. 2 Q Okay. What treatment did you then receive after 3 So a day or two after the accident you start to feel some 3 you went for this MRV 4 pain or discomfort? 4 A Physical therapy. A Yes. 5 Q Okay. And who prescribed the physical therapy? 6 Q All right. First you just attribute that to 6 A My doctor, Dr. Bush. 7 being in an accident? 7 Q Dr. Bush. And where did he send you for physical 8 A Yes. Yes. 8 therapy? 9 Q When is the first time that you go for any type 9 A Drayer Institute. 10 of treatment? 10 Q Do you recall about how long that you treated 11 A I think it was a week after the accident, a week 1 I there? 12 and a day or week and two days. 12 A No. Weeks at a time, I can't remember. 13 Q A week or so? 13 Q Did you go once a week, twice a week, a couple 14 A Yes. Yes. 14 times a week? 15 MR. COOK: Off the record. 15 A I think I went three times a week. 16 (Discussion held off the record.) 16 Q Do you recall what activities that they had you 17 BY MR. COOK: 17 perform or what type of treatment that you received as part 18 Q All right. So who do you go to see? 18 of physical therapy? 19 A For? 19 A I know that I had to do stretches, things like 20 MR. SADLOCK: The first visit. 20 that. I know they would massage my neck and they did some 21 THE WITNESS: Oh, for doctor -- Dr. William 21 kind of electrical thing that I would hold. I don't know. 22 Bush. 22 Like -- I don't recall what it was called. 23 BY MR. COOK: 23 Q Okay. That's fine. 24 Q Okay. And when you get there, what do you tell 24 The stretches, what part of your body was that 25 him is bothering you? 25 directed toward, if you know? Page 39 Page 41 1 A My lower back and my neck and pretty much I A My neck, my whole spine. 2 cervical, thoracic and lumbar. 2 Q Okay. All right. 3 Q Were those the words that you used? 3 And the electrical part, what area of your body 4 A Pain. I don't know. I don't remember. 4 was that geared toward? 5 Q Okay. 5 A My -- the middle of my back and my neck. 6 A My neck, my upper back and my lower back hurt. 6 Q Did those treatments seem to make any difference? 7 Q And do you recall what type of treatment that he 7 A No. 8 prescribed at that point or what happened after that? 8 Q Was that something that you discussed with them? 9 A An MRI. 9 A With who? 1o Q Do you recall where that was done? 10 Q Well, either with the physical therapist or with 11 A Tristan Associates in Camp Hill. 11 Dr. Bush? 12 Q Do you recall about how long after that first 12 A I don't remember. I talked -- yes, I did, I 13 visit with Dr. Bush that was that was done? 13 talked to Dr. Bush about it. 14 A Do I recall -- pardon, I didn't -- 14 Q Do you recall if Dr. Bush prescribed some other 15 Q I am sorry, about how long after your first visit 15 type of treatment? 16 with Dr. Bush was the MRI done at Tristan? 16 A Yes, there were several. I -- yes, he did. 17 A Probably immediately, as soon as they could get 17 Q Okay. Do you recall what any of those were? 18 me in. 18 A Injection, injection -- darn it. Epidural 19 Q Do you have any bruising, do you recall? 19 injection, injection shots. 20 A I don't recall. 20 Q Do you recall about how many of those that you 21 Q Do you recall what the results of the MRI were as 21 had? 22 you understood them? 22 A I had to go in twice for it. 23 A I remember reading the paper. 23 Q Did that seem to make any difference? 24 Q Did any doctor ever discuss them with you, 24 A No. 25 discuss the results with you? 25 Q Do you recall if you received any medications? 'age 38 - Page 41 HUGHES ALBRIGHT FOLTZ NATALE 717-5401-0220/717-393-5101 Multi-Page T*N4 RHONDA L. REINFORD JANUARY 2, 2007 Page 42 1 A At that point -- when, before or after the shots? 2 Q Well, let's do it that way. 3 A After the shots, I believe they put me on 4 medicine. 5 Q Okay. And do you recall what that was? 6 A Yes. 7 Q What was that? 8 A Hydrocodone. 9 Q And about how long did you take that? 10 A I still take it. 11 Q All right. While we're on that subject, what 12 medicines are you currently taking? 13 A Right now, today? 14 Q Yes. 15 A Hydrocodone. 16 Q Okay. Prior to the injections, were you 17 receiving different medications? 18 A No. 19 Q Okay. 20 A I don't remember. Some -- darn it, it was -- did 21 he have me on -- 22 MR. SADLOCK: It's okay. It's fine. If you don't 23 remember, that's fine. 24 THE WITNESS: Okay. 25 Sorry. Page 43 1 BY MR. COOK: 2 Q That's probably one of the things that I probably 3 should have mentioned to you earlier, if you don't know, 4 that's okay. 5 A Okay. 6 Q It's not -- 7 A I am sorry. 8 Q It's not a test. 9 A I am not saying it mean towards you. I don't -- 10 1 am mad at myself because I don't remember. 11 Q We don't want you to guess. 12 A Okay. 13 Q What you recall is what you recall. 14 A Okay. 15 Q We certainly understand it's been awhile. 16 A Yes. 17 Q Some of the things may not be freshest in your 18 mind, but -- 19 A Well, no, not when you have pain every single 20 day, you can't remember some -- I know I am on Oxycodone. 21 I am not taking it presently today because I ran out, but I 22 take -- pick it up today. 23 I normally take Oxycodone as well, but I have to 24 pick it up today, and a muscle relaxer that I have to pick 25 up today as well. Page 44 1 Q These medications, are they prescribed by -- 2 A Doctor -- now one of them, the Hydrocodone was 3 prescribed by Dr. Bush at first. 4 Q Okay. 5 A And then after seeing him, he said well, instead 6 of trying the drugs because I said I didn't want to take 7 the medication, he told me to go to Dr. Momen or Dr. Braun. 8 Q Okay. What practice are they with? 9 A Susquehanna Pain Management I believe. 10 1 have a headache. 1 I Q All right. When you went there, what happens? 12 A To Susquehanna? 13 Q Yes. 14 A That's when I -- they tried to get -- they gave 15 me the shots. 16 Q Okay. 17 A They didn't work. So after that, Dr. Maximilian 18 Braun told me to go see a specialist, Dr. Stuart Hartman. 19 There he re-prescribed the hydrocodone. And it wasn't 20 working for me, so then he prescribed the Oxycodone as well 21 with the muscle relaxer because I get spasms. 22 Q Was there ever a point in time that you were off 23 the hydrocodone? 24 You said prescribed, that's why I asked? 25 A Yes. Page 45 1 Q Did he just renew the prescription, or was there 2 a time that you stopped taking it? 3 A I don't remember not taking it. 4 Q Okay. 5 A I don't know. 6 Q Just so I am clear, I think that you said earlier 7 that these three medications you take on a daily basis? 8 A Yes. 9 Q Okay. All right. 10 Is there any devices that they had given you? 11 You mentioned at one point in time that there was an 12 electronic stimulation -- 13 A Oh. 14 Q --that you tried? 15 A I asked my doctor about a lower back brace. He 16 said yes, go ahead and use it when you feel necessary. 17 Q Okay. Did you then get a lower back brace? 18 A Yes. 19 Q Do you recall about when? 20 A No, I don't. 21 Q Okay. 22 A It was early on, but I don't remember. 23 Q Okay. Do you recall about how often that you 24 would use it? 25 A No. Page 42 -Page 45 -----------_..._- Ak i r. -71-_<wn_fV 1n1.7i? '2n2 CInI RHONQA L. REINFORD Multi-Page"" JANUARY 2, 2007 Page 46 Page 48 I Q All right. 1 A So I go to Stuart Hartman. 2 A I would have it -- 2 Q Okay. 3 Q All right. Just as needed? 3 A I don't remember the last time that I went to see 4 A I don't remember. I don't know. I take it on 4 Dr. Bush. 5 and off and on and off. 5 Q Okay. What about Dr. Hartman? 6 Q All right. Was it something that you would wear 6 A The last time that I saw him was -- thank you, 7 every day at least once a day? 7 right before Christmas -- before Thanksgiving of 2007. 8 A Probably, yes. 8 Q All right. 9 Q Is it something that you still do? 9 A November something. 10 A I haven't worn it for awhile. 10 Q Do you see Dr. Hartman on a regular basis? I 1 Q When you say awhile -- 11 A Yes. 12 A Well, I gained weight. It doesn't fit. 12 Q How often? 13 Q Is that a year, two years ago, six months ago, 13 A Once a month normally. 14 roughly? 14 Q Has he given you any prognosis or -- in other 15 A I don't know. 15 words, what does he expect will happen in the future? 16 Q Is there a point in time when you were confined 16 A He wanted me to take -- he wants me to take some 17 to bed? 17 kind of pain management physical therapy. I think that's 18 A I was -- I don't know. I know there was times I 18 what it is called, don't quote me on it. 19 know that I couldn't get out of bed. 19 Q Okay. 20 Q Do you recall approximately how many times that 20 A But I cannot afford to pay for it. So he can't 21 would happen? 21 do it until I can afford to pay for it. That's all I know. 22 A Maybe around ten. I don't -- or I don't know. 22 Q Has the issue of surgery ever come up? 23 Q Did any doctor ever tell you to, since the 23 A No. 24 accident, limit your work activities? 24 Q All right. Has Dr. Hartman told you what this 25 A Yes. 25 physical therapy would entail? Page 47 1 Q Okay. And which doctor or doctors? 2 A Dr. William Braun -- I mean Dr. William Bush. 3 Q Okay. 4 A And Dr. Stuart Hartman. 5 Q Okay. Do you recall what restrictions that they 6 had given? 7 A No, no lifting, pulling, pushing. They were -- 8 wrote out two separate ones. I didn't really read the 9 second one. I read the one. I just told you about what 10 Dr. Bush said. 11 Q Do you recall when the most recent one was? 12 A When it was? 13 Q Yes. 14 A Not too long ago. In '07. I don't recall when I 15 sent -- l6 MR. SADLOCK: That's fine. 17 THE WITNESS: You -- okay. It wasn't more than 18 five months. I don't remember. 19 BY MR. COOK: 20 Q When was the last time that you treated with Dr. 21 Bush? 22 A He sent me to Dr. Hartman, a specialist. 23 Q Okay. 24 A Dr. Bush is just a family doctor. 25 Q Right. Page 49 1 A No. 2 Q Or what it would be about? 3 A No. 4 Q Has he indicated how long that would last? 5 A No. 6 Q All right. What about riding in a car, does that 7 present any problems? 8 A Yes. 9 Q Okay. What type of limitations do you have? 10 A Going long distances. I 1 Q Now, for certain people, long distance would mean 12 different things. 13 A Uh-huh. 14 Q What would you qualify or consider to be a long 15 distance? Are we talking five miles, five hundred miles? 16 A I would say more than an hour and a half, two 17 hours. 18 Q Is that the same for sitting? 19 A Yes. 20 Q Have you sought any other employment other than 21 through Pinnacle since the accident? 22 A No. 23 Q Why°is that? 24 A I was in pain a lot. I didn't quit Pinnacle. 25 Q Okay. Have you ever discussed going back with Page 46 - Page 49 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 Multi-Page TM RHONDA L. REINFORD IAATITAUV') '7nn7 Page 50 1 some other job duties other than the ones that you talked 2 about before with the transportation? 3 A I have never discussed -- you mean with my 4 supervisor? 5 Q Yes. 6 A I don't know. I think we talked about it here 7 and there. 8 Q And who was your supervisor? 9 A Tracy Brietigan. 10 Q Do you know how to spell the last name? 11 A B-r-i-e-t-i-g-a-n. 12 Q Okay. And was she at the hospital or -- 13 A She's at Poly. That's where she's located. 14 Q At Poly? 15 A Polyclinic, yes. 16 Q Is there -- has any doctor ever told you that 17 it's not expected that you are going to recover from some 18 of these injuries? 19 A Dr. Hartman says chronic pain only gets worse 20 with time, so I never really asked as of yet because I just 21 don't feel like I should. 22 Q Has any doctor ever told you that the pain would 23 diminish or go away over time? 24 A No. 25 Q Do you recall if Dr. Hartman said anything else Page 51 1 about your condition and what to expect in the future other 2 than the pain increasing? 3 A No, I don't. 4 Q Okay. 5 A I just -- I don't. 6 Q In other words, has he said anything about 7 physical restrictions or -- 8 A We didn't even get to that. 9 Q Okay. In the complaint that you had filed, there 10 is an indication in there that as a result of this, you had I I suffered embarrassment. Do you recall that? 12 A Uh-huh. 13 Q Okay. Could you explain to me how this would 14 result in embarrassment? 15 A Wait. 16 Certain times when I would go pick up my 17 medication at Rite Aid, they would say stuff out loud in 18 front of other people while I was there. And having 19 trouble with the doctor and trying to have him call in the 20 medication. And I didn't know how things worked because I 21 have never been sick or on medication before. We were 22 having trouble trying to converse with the doctor and Rite 23 Aid, and they just treated me so -- 24 Q Were these payment-type issues or just what other 25 -- I am trying to figure out, the people -- type of things Page 52 1 that the people at Rite Aid would say. 2 A They would say well, don't you know that you have 3 to have a prescription for this, or I said no, I never -- I 4 never came in here for medication, I don't know what it is 5 like. 6 And also just trying -- like when you are going 7 to try and cross the parking lot to get into a Wal-Mart 8 say, and people expect you to walk fast and you can't. 9 It's just a lot of incidents. 10 Q Okay. Well, besides the walking, can you think 11 of -- and the Rite Aid, can you think of anything else? 12 A Just being out, people staring at me because I 13 walk slow. Sometimes I use a cane. 14 Q Anything else? 15 A There could be more, but right now, I don't 16 recall. 17 Q Has there been any emotional distress as a result 18 of this incident? 19 A Yes. 20 Q Could you explain to me what emotional stress 21 that you have or what set it off, or -- if you need to take 22 a minute, we can take a minute, that's fine. 23 A Yes. 24 (Brief recess.) 25 BY MR. COOK: Page 53 1 Q Are you all set? 2 A Yes. 3 Q Where did I leave off? 4 MR. SADLOCK: Emotional distress. 5 BY MR. COOK: 6 Q I don't remember the question exactly, but I 7 think it was somewhere along the lines of what types of 8 things cause you to have emotional distress that are 9 related to this accident. 10 A Constant pain. 11 Q Okay. 12 A That's a big factor. Me not being in a very good 13 mood too often because I am in pain so much all of the time 14 causes me to be mean to my husband, and that's put a big 15 strain on our marriage. 16 Q Okay. 17 A Is it okay to say what I said earlier? 18 MR. SADLOCK: You are answering the question, 19 whatever -- 20 MR. REINFORD: Maybe not in such detail, but -- 21 THE WITNESS: I don't care. 22 My relations with my husband since this accident, 23 I can't have an orgasm. It's just not the same. 24 BY MR. COOK: 25 Q Yes. Do you still have intimacy or relations? -------- - _ - Ywrr r4-1i T7 XYATA1 17 -71-7-GAA-n77A1'71'7_7nZ-C1n1 Page 50 - Page 53 RHONDA L. REINFORD JANUARY 2, 2007 ` Multi-Page""' Page 54 1 A Very rare. 2 Q Has that changed since before the accident? 3 A I don't understand what you are asking me. 4 Q Okay. Nobody likes to ask these questions -- 5 A !i's okay, go ahead, be blatantly honest. 6 Q The frequency in which you had intimacy or 7 relations, whatever you want to call it, prior to the 8 accident, has that changed since the accident? 9 A Yes. 10 Q Okay. 11 A Tenfold. 12 Q All right. All right. 13 Now, the medical bills, were they -- was there a 14 point in time that there were any coverage issues regarding 15 medical bills? 16 A Yes. 17 Q Okay. When did that happen? 18 A I don't know. 19 Q Roughly? 20 MR. SADLOCK: Her Pip coverage exhausted. There 21 is no health insurance. 22 BY MR. COOK! 23 Q So at the time that your Pip coverage had ended, 24 there was -- you didn't have any other health insurance? 25 A No. Page 55 1 Q Okay. When you were previously working for 2 Pinnacle, did you have health insurance? 3 A No. 4 Q Okay. Was there a point in time prior to the 5 accident that either you or your husband had health 6 insurance? 7 MR. REINFORD: Before we were married. 8 THE WITNESS: Yes, I had health insurance before. 9 BY MR. COOK: 10 Q Okay. Was that through Pinnacle or was that -- i 1 A No, no. 12 Q Was that a result of some other employer or -- 13 A Another employer. 14 Q Before you started at Pinnacle? 15 A I had health coverage when working with Total 16 Exposition, Exposition Concepts. 17 Q Was that before you went to HACC? 18 A Yes, a year before. 19 Q Okay. 20 A I had health coverage while working at Masonic 21 Homes. Page 56 1 A We're not quite sure yet. 2 Q Okay. Are there any other future expenses that 3 you are aware of or might anticipate as a result of this 4 incident and/or your treatment? 5 A Now, a doctor's point of view, I can't give you, 6 but from what Dr. Hartman says, I will have probably 7 on-going pain management therapy. And I don't know how 8 long I will be on the medication, if it's -- you know, it's 9 been two years now. 10 Q Back to the meds. Has there been any change in 11 the dosage? 12 A Yes. 13 Q That you are aware of? 14 A Yes, yes. 15 Q Do you know what medications the dosage was 16 changed? 17 A The hydrocodone, that was upped to two tablets 18 every four to six hours instead of one. 19 Q Okay. The Oxycodone? 20 A Yes. I believe that was five milligrams when 21 first prescribed, then he upped it. 22 Q When you say he, you mean -- 23 A Oh, Dr. Stuart upped it to fifteen. 24 MR. SADLOCK: Hartman. 25 THE WITNESS: Dr. Hartman, did I say that? Page 57 1 MR. SADLOCK: You said his first name. I wanted 2 to clarify that. 3 THE WITNESS: I am sorry. Thank you. 4 BY MR. COOK: 5 Q Do you recall about when that was? 6 A It wasn't too long ago. Within the past three 7 months maybe. 8 Q Back to the Hydrocodone, do you remember who 9 upped that and when? 10 A Dr. Hartman upped it last year sometime. 11 Q Okay. All right. 12 Are there any other medications that you have 13 taken where the dosage has been increased during this since 14 the accident? 15 A Say it again, I am sorry. 16 Q I am sorry. 17 Since the accident, have there been any other 18 medications that you are on that were prescribed by a 19 doctor related to pain that have been increased or the 20 dosage has been changed? 21 A Just those two, and the muscle relaxer, instead 22 Q Do you anticipate or has any doctor anticipated 22 of taking that every eight hours, I am supposed to take it 23 any major medical expense? When I say major medical, 23 every six hours. 24 meaning other than maybe an office visit or the physical 24 Q Okay. 25 therapy that you talked about? 25 A I never got to finish the emotional stress part, 'age 54 - Page 57 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 Multi-Page M RHONDA L. REINFORD JANUARY 2, 2007 Page 58 Page 60 l but -- 1 A After the accident? 2 Q Okay. We can go back to that if you want to. 2 Q Before the accident, I mean just generally the 3 A Well, sometimes he has to dress me or undress me 3 layout. 4 to go somewhere, and that's a little bit embarrassing to me 4 A Oh, my husband in the driver's seat, me in the 5 because it makes me feel like some kind of -- what do you 5 passenger seat, my daughter behind me. 6 want to call it, invalid. 6 Q Is there a bench seat back there? 7 Q Okay. 7 A Yes. She was in a car seat. 8 A I don't want to -- I can't walk fast any more. I 8 Q You mentioned that there were three dogs at the 9 used to be able to fast walk. They were always telling me 9 time of the accident. There are now two. 10 slow down, slow down. Now, I can't. They have to wait for 10 A Yes. 11 me now. I I Q Okay. What difficulties do you have taking care 12 Q Okay. About how often would you say that you -- 12 of them? 13 that he has to help you dress or undress? 13 A Getting them into the tub, grooming them. 14 A I mean that is a daily occurrence. 14 Q What type of dogs? 15 Q Is it a once a week occurrence, is it a monthly 15 A I have a large Australian Shepherd Collie, and a 16 occurrence, yearly? 16 small Pappian Border Collie mix. I can't walk the large 17 A Well, he helps me with my coat. It's probably 17 one any more. 18 once a month. 18 Q Have there been any financial difficulties as a 19 Q Okay. 19 result of this accident? 20 A He'll get mad though when I try and do it myself, 20 A Yes. 21 but I can't. 21 Q Okay. What can you tell me about that? 22 Q Is it just the coat, or is it -- 22 A Having trouble paying our mortgage, having 23 A No, it's down to underwear and everything, 23 trouble getting groceries, people calling us all of the 24 putting it -- putting those on for me. 24 time from collection agencies. 25 MR. REINFORD: And not for relations either. 25 Q Okay. Page 59 Page 61 1 BY MR. COOK: 1 A Getting our daughter clothing that she needs for 2 Q There was something else in there that I wanted 2 school or shoes. It goes on. 3 to ask you about, but I can't remember what it is now. 3 Q All right. Has there been any change other than 4 You had mentioned before things like laundry and 4 your employment, your financial circumstances since the 5 vacuuming. Is there anything else around the house that 5 time of the accident? 6 has become difficult? 6 A What do you mean? Any changes in me? 7 A Yes, I used to rearrange the furniture and pull 7 MR. SADLOCK: No, in the family income other than 8 dressers and couches out to vacuum behind it. I used to 8 your not being able to work, that's what he's asking. 9 rake the leaves in the front yard and keep the landscape 9 THE WITNESS: Well, we don't have a lot of money. 10 looking well, maintaining my car. 10 The church has to help us. They give us gift cards for 1 I Q What would you do there? I I Giant and Weis Markets and stuff. 12 A Vacuum it out and wash it. 12 BY MR. COOK: 13 Q Okay. 13 Q Which church? 14 A I can't do that. 14 A What's the name? 15 Q All right. 15 MR. REINFORD: West Shore Evangelical Free 16 A Tim plants the vegetable garden because I can't 16 Church. 17 anymore, taking care of my dogs. 17 BY MR. COOK: 18 Q Okay. How many dogs do you have? 18 Q I guess what I am asking is, has there been -- 19 A At the time of the accident, we had three that 19 well, let me back up. Prior to the accident -- 20 were in the truck with us. I have two now. 20 A Uh-huh. 21 Q Okay. On that issue, was there anybody else in 21 Q -- both you and your husband were working? 22 the truck at the time of the accident? 22 A Yes. 23 A My daughter. 23 Q Is that correct? 24 Q And how would you describe the inside of the 24 A Yes. Yes. 25 truck? 25 Q And both relatively full-time positions? ------ - - - -`r"n lr^lr .i.., uA•rel P Page 58 - Page 61 KHgJ IJA L. KEINYUKD JANUARY 2, 2007 4 ' Multi-Page ` " Page 62 1 A Yes. 2 Q Is that correct? 3 A Yes. 4 Q Is your husband's position an hourly position, a ' salai-y position, a wiiunission position 6 A Hourly. 7 Q If you know? 8 A Well, hourly. 9 Q Okay. And roughly, did he bring home the same 10 amount every week, bi-weekly, monthly, whatever it turned 11 out to be? 12 A Yes, I think. 13 Q Okay. To your knowledge, has there been any 14 change in that salary, income or amount that he brought 15 home since the time of the accident? 16 A Yes, there has been changes. 17 Q Okay. Was it more or was it less than what he 18 was making prior to the accident? 19 A I believe it was less. 20 Q Okay. Maybe these questions could be directed to 21 him anyway. But was there a period of time where there 22 were any layoffs? 23 A No, I don't think so. 24 Q Okay. Any bankruptcies? 25 A No. Page 63 1 Q Any unexpected financial burdens, damage to the 2 house that needed to be repaired, mortgage payment went up? 3 A I don't -- there are a couple times when we -- 4 was it when our roof needed repaired? I don't remember. I 5 know we couldn't afford to -- the siding was starting fall 6 off, but I think Tim nailed it back up. There is other 7 stuff, but I can't remember what it is. He takes care of 8 that. 9 Q Okay. 10 A I try not to worry myself with it because I have 11 enough on my mind. 12 Q I am going to show you here -- well, we will go 13 back to 2001. 14 A Yes. 15 Q These are W2s. 16 A Uh-huh. 17 Q You will note -- look at the top categories here. 18 A Uh-huh. 19 Q For example, 2002, I am trying to read upside 20 down, If I get them wrong, let me know. About 19,000, 21 that was from Pinnacle? 22 A Yes. Tim was laid off, so I was working extra at 23 that time. 24 Q Okay. And then 2003, about twenty-one 25 A Yes. I was still working extra. Page 64 Q And in 2004, it goes down to seven thousand 2 something. 3 A Yes. What do you want to know? 4 Q Okay. 5 A Tile difference'! 6 Q The amount? 7 A 5,442. 8 Q Just doing the rough math, you would agree that's 9 probably about twelve or thirteen thousand for the year? 10 A I don't know. Probably. Thank you. Yes. 1 I Q You would also agree that would be less than the 12 nineteen and the twenty-one in the previous years, correct? 13 MR. SADLOCK: We can stipulate that in 2004 the 14 combined total 12,000 is less than 19 and 21, but it's also 15 in line with 2001 where Pinnacle in 2001 was 12,000. 16 BY MR. COOK: 17 Q Okay. So is it then fair to say that that is 18 typically -- the 12,000, 13,000 is typically where you were 19 at per year unless you worked more and worked overtime as 20 you did in 2002 and 2003? 21 A I don't know. 22 Q Do you know why 2004 would have been less than 23 the previous years? 24 A Was Miranda was in kindergarten that year? 25 That's why -- I know there was a year that I had to -- we Page 65 1 could not afford -- 2 MR. REINFORD: Miranda was in kindergarten. 3 THE WITNESS: She was in AM kindergarten. I had 4 to get off work at a certain time and get home to her that 5 year. 6 BY MR. COOK: 7 Q And 2005 -- 8 MR. SADLOCK: Combined total 2005 about 12,000 as 9 well. 10 BY MR. COOK: 11 Q Okay. 12 A So it went up from then to -- I haven't looked at 13 these for a long time. After she went to first grade, then 14 I started working more again. 15 Q Do you remember about when she went to first 16 grade? 17 A I think it was -- she's in fourth grade now. 18 What year did she start first grade? 19 MR. REINFORD: '03,'03. 20 THE WITNESS: 2003. 21 MR. REINFORD: Fall of 2003. 22 THE WITNESS: Oh. 23 BY MR. COOK: 24 Q So it was in 2003 she went back to first grade 25 that you started to work more? ?age 62 -Page 65 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 Multi-Pager"` RHONDA L. REINFORD JANUARY 2, 2007 Page 66 Page 68 1 A When she attended school in first grade -- now it 1 insurance company? 2 all depends. I know that I could work longer hours because 2 A I talked to a police officer that stopped by. 3 she was in school full time. 3 Q All right. Do you know how soon after the 4 Q Do you have any other thought as to 2005, the 4 accident the officer stopped by? 5 twelve thousand dollars, thirteen thousand dollar range? 5 A No, 1 don't recall. 6 A Any thought as to why? 6 Q Are we talking within the day of the accident, 7 Q Yes. 7 the night of the accident, next day? 8 MR. SADLOCK: Compared to what, because again 8 A Well, we talked to officers the night of the 9 that's consistent with other years? 9 accident. 10 BY MR. COOK: 10 Q Okay. When this officer stopped by, do you 11 Q Okay. Well, let me put it a different way. 11 remember which officer it was? 12 Would you agree that would be an average year without any 12 A Ambrose. 13 overtime or -- 13 Q Do you recall why they stopped by? 14 A No. No. 14 A What was that? Something about to give me the 15 Q Okay. Why would you say it would not bean 15 accident report. 16 average year? 16 Q The report had been completed at that point in 17 A Well, let's do the math. I -- 17 time. You didn't have any statements to add to it, is that 18 Q I mean other than given the fact that we're 18 -- do I understand that correctly? 19 talking about October of 2005 being the time of the 19 A I do not recall. I don't recall what we talked 20 accident. No? Okay. 20 about, I just remember him giving me the accident report. 21 A Sorry. 21 Q In one of the answers to the interrogatories, it 22 Q That's okay. 22 talks about medications and restrictions. You mentioned 23 Do you have any plans to seek any other 23 that you cannot go on motorcycle rides with your husband. 24 education, any other type of job training, seek some other 24 A True. 25 type of job? 25 Q Okay. Had you done that prior to? Page 67 Page 69 1 A Well, I am going to try and do my art work as 1 A Oh, yes. 2 much as I can, but that varies. It depends on the day. 2 Q About how often? 3 Q Okay. 3 A Probably once a week. 4 A And I am going to try to sell it at an art 4 Q Did you have your own bike or -- 5 gallery. 5 A No. I always rode on the back of his. 6 Q All right. Any other thoughts for employment? 6 Q Okay. Would that also -- on thirteen, if you are 7 A No, not as of yet. 7 looking. 8 Q Okay. 8 You said once a week. Would that be all year or 9 A I can't tell you because I haven't had what I 9 just during the spring, summer? 10 believe the proper physical therapy, so.... 10 A Not in winter. 11 Q Okay. 11 Q Okay. 12 A I haven't even reached that yet. 12 A We would go on trips down to Virginia and back. 13 Q When you say the proper physical therapy, what do 13 Q All right. About how often would that happen? 14 you think that entails or where does that get you? 14 A Oh, my gosh, we went up to New York too. Several 15 A Well, I think since Dr. Hartman is a specialist 15 times up to Lake George for a motorcycle trip together. We 16 and he's done -- he has worked with these type of patients 16 would do it every year. 17 such as me, he might know better how to help me. I 17 Q About once a year you are down to Virginia, about 18 don't -- 18 once a year you go up to New York? 19 Q Okay. Other than to your attorney, do you recall 19 A Yes. Correct. 20 making any statements to anyone else about this incident -- 20 Q All right. In response to seventeen, you talked 21 A As in? 21 about how you worked for a manager at her office for a few 22 Q Did you talk to anybody else about this, whether 22 days a week here and there. 23 it be -- 23 A Here and there. 24 A Family. 24 Q Is that the -- I can't remember her name now. 25 Q Okay. Police officers that responded, any 25 But for Pinnacle -- Page 66 - Page 69 TIT Tel I I T70 A 7 T1T111l-TT'1- T:/IT -1-7 LT A T A T ti '71'7 CAA A117A/'71'7 Zn'2 C1 Al RHONIVA L. REINFORD JANUARY 2, 2007 . Multi-Page ""` Page 70 1 A Tracy Brietigan. 2 Q Is that what you're referring to? 3 Do you want to see it? 4 A What do you mean is that what I am referring to? 5 what does that have to do with -- oh, oh. 6 Q Counsel has it there. 7 When you did return to work either on a full time 8 or part-time basis, state whether the return has been to 9 full time or part-time employment. And the response was 10 worked for my manager at her office a few days a week here 11 and there. 12 A When she would need off for a doctors appointment 13 for her child or like two days over Christmas, but there 14 was a couch in the office that I could lay down that she 15 agreed to, and a phone right by the couch, and that's what 16 I would do. 17 Q When you say she, you are referring to -- 18 A Tracy would refer -- yes. 19 Q Okay. All right. In the complaint that was 20 filed, there was a count for punitive damages in there. It 21 was alleged that my client had operated her motor vehicle 22 while intoxicated, and that constituted outrageous conduct 23 and reckless indifference. Okay. 24 Other than the alcohol issue, are you aware of 25 any other outrageous conduct or driving on her part that Page 71 1 particular night? 2 A On her driving, I don't know her, no. 3 Q Well, I guess that's part of my question. I mean 4 you didn't see any other driving, you didn't see her 5 driving at all that night, is that fair to say? 6 A Yes. 7 Q Okay. Do you know of any other witnesses to this 8 incident, accident, other than maybe your husband, your 9 daughter, and my client? 10 A You mean who saw it happen? 11 Q Yes. 12 A I don't recall. There were so many people out 13 there, but I don't remember who saw it or -- I don't know. 14 Q To the best of your knowledge, no one has come 15 forward and -- that you know by name and said I saw this 16 accident happen? 17 A Wasn't there a big guy that was -- we're on Third 18 Street facing Bridge toward New Cumberland, wasn't there a 19 big, tall guy in his early twenties? 20 MR. REINFORD I don't know. 21 THE WITNESS: That said he saw -- 22 MR. SADLOCK: Only if you recall. 23 MR. REINFORD: Only if you recall. 24 THE WITNESS: Yes, I remember a guy saying 25 something, but I didn't -- I was just too upset at the Page 72 1 time, and I can't remember his name or anything. 2 BY MR. COOK: 3 Q Okay. You hadn't seen him before or didn't know 4 him? 5 A No. 6 Q From before? 7 A No, no. I couldn't even tell you his name, I 8 don't remember. 9 Q Okay. That's all I have. Thank you. 10 A Thank you. 11 MR. SADLOCK: I have a couple though. 12 THE WITNESS: Okay. 13 BY MR. SADLOCK: 14 Q In describing the circumstances immediately 15 following the accident, I believe your testimony was that 16 you did go back to the defendant's car, is that correct? 17 A Yes, I did. 18 Q And I think that your testimony was that you 19 described her as being slumped over. What did you mean by 20 that? 21 A She was mumbling, and I think she was saying oh, 22 my God, oh, my God. And I kept saying are you okay, are 23 you okay. And it was like I wasn't even there. And then I 24 said look at me. And when she looked at me, she -- it's 25 like she looked through me, like she couldn't see me, like Page 73 1 her eyes were crossed or something. 2 Q Glassy eyed? 3 A Yes. 4 Q Could you detect an odor of alcohol about her? 5 A Yes. 6 Q How would you describe the odor of alcohol about 7 her? 8 A Strong. 9 Q You also mentioned in your direct testimony that 10 you had -- it was hard to understand what she was saying. 11 What do you mean by that? 12 A She was slurring her speech. It was like she had 13 marbles in her mouth. She was saying oh, my God. That's 14 what I thought that she was saying. 15 Q Was it apparent then for that period of time that 16 you were with her at her car that she had been drinking? 17 A Yes, there is no doubt about that. 18 Q Did you see her at any time get out of her 19 vehicle? 20 A No, because my daughter was hysterical, and I 21 wanted to remove her from the situation, but I believe my 22 husband saw her. 23 Q Did he ever tell you what he saw in terms of her 24 ability to walk at the scene? 25 A I believe he told me that she couldn't even Page 70 - Page 73 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 U Multi-Page`' RHONDA L. REINFORD JANUARY 2, 2007 Page 74 1 complete the sobriety test, that they just put her in the 2 car and -- 3 Q You also mentioned that you saw one of the police 4 officers sometime after the accident. Is that correct? 5 A Yes. 6 Q When he gave you a copy of the police report? 7 A Yes. 8 Q Did that officer or any officer either at the 9 scene of the accident or any time thereafter provide you 10 with any information regarding the defendant's condition on 11 the night of the accident? 12 A Yes. 13 Q Okay. Do you recall who that officer was? 14 A Todd Ambrose. 15 Q What did he tell you? 16 A That she could not remember her phone number or 17 her address. 18 Q Because of what? 19 A Because she was so intoxicated. 20 Q Is there anything else that you remember about 21 her condition, the defendant's condition on the night of 22 the accident that you observed yourself or that was 23 commented to you that we haven't already talked about, 24 either any other comments or observations that you made? 25 A No. I do have a friend -- well, not a friend, I Page 75 1 know a lady who works at West Shore Plaza Liquor Store. 2 And I went in there not too long ago. I would say it was 3 about a month ago. I was babysitting a little girl. I 4 went in to get a wine box, a wooden wine box. She said 5 Ronnie, how are you doing. And I said well, you know, we 6 talked about that. And she said did you hear Valerie got a 7 job at Pinnacle. 1 said oh, okay. She said she mentioned 8 that she still comes in there and purchases liquor. And I 9 said I will pray for her. I got my box and left. 10 Q How much time did you actually spend at the other 11 defendant's car after the accident? 12 A Probably about a minute. 13 Q But it was clear to you in that minute, that she 14 was intoxicated? 15 A Yes. 16 MR. sADLOCK: Okay. Thank you. I have no other 17 questions. 18 BY MR. COOK: 19 Q Okay. I want to back up for a second. 20 A I thought we were through? 21 Q So close. 22 A Okay. 23 Q When you initially were indicating about going 24 back to the car and what my client looked like, I did look 25 up as I was taking notes, I saw it appeared that you had Page 76 1 your head down with your hands on your face? 2 A Yes. 3 Q Okay. The intoxication issue, I mean have you 4 been around people that were intoxicated before? 5 A Yes. 6 Q Okay. How often would you say that would occur? 7 A Well, we would get people in the hospital in 8 toxicology. So I worked with a lot of people that had 9 alcoholic problems and drug abusers. I would have to do 10 one on ones with them and stay with them for eight hours a 11 day, so there is no doubt in my mind. 12 Q Okay. Would they come in intoxicated? 13 A Some do. 14 Q Did you tell anybody at the scene, like the 15 police officer, that you thought that she had been drinking 16 or that she was intoxicated? 17 A Did I tell anyone? Yes, I did. 18 Q Do you recall who you told? 19 A Officer Ambrose. 20 Q Do you recall what you said to him? 21 A No. I said I believe that she was drinking, 22 there is alcohol on her breath, I can smell it. 23 Q Okay. 24 A I think -- I pretty much explained what I said to 25 you, what I said to Mr. Sadlock just a couple minutes ago, Page 77 1 that's what I pretty much told him too, that's what I saw. 2 Q Okay. Okay. You smelled alcohol, slurring 3 speech -- 4 A Yes. 5 Q -- that kind of stuff? 6 Okay. Now I am done. 7 A Okay. 8 (Whereupon, the deposition was concluded at 9 12:06 p.m.) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 T NY Tf'TTT7C% A T ""IO?TT'T TAT T7 1TA-VAT T. '71'7 CAA f1'1 1A I"1'7 ?A'f C1 Al Page 74 - Page 77 RHONDA L. REINFORD ` Multi-Page JANUARY 2, 2007 Page 78 1 COUNTY OF DAUPHIN 2 : SS 3 COMMONWEALTH OF PENNSYLVANIA : 4 I, Maria N. O'Donnell, a Notary Public, authorized to 5 administer oaths within and for the Commonwealth of 6 Pennsylvania, do hereby certify that the foregoing is the 7 testimony of RHONDA L. REINFORD. 8 I further certify that before the taking of said 9 deposition, the witness was duly sworn; that the questions 10 and answers were taken down stenographically by the said 11 Reporter-Notary Public, and afterwards reduced to 12 typewriting under the direction of the said Reporter. 13 I further certify the said deposition was taken at 14 the time and place specified in the caption sheet hereof. 15 I further certify that I am not a relative or 16 employee or attorney or counsel to any of the parties, or a 17 relative or employee of such attorney or counsel, or 18 financially interested directly or indirectly in this 19 action. 20 I further certify the said deposition constitutes 21 a true record of the testimony given by the said witness. 22 IN WITNESS WHEREOF, I have hereunto set my hand 23 this 2ND day of JANUARY, 2008. 24 Maria N. O'Donnell, RPR 25 Notary Public Page 78 -Page 78 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 EXHIBIT "D" a • RHONDA L. REINFORD AND R. TIMOTHY REINFORD, HER HUSBAND, PLAINTIFFS V VALERIE LAIR, DEFENDANT IN THE COURT OF COMMON PLEAS Zvi i?i''.itLAly COULV T Y , PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3609 CIVIL TERM JURY TRIAL DEMANDED DEPOSITION OF: R. TIMOTHY REINFORD TAKEN BY: DEFENDANT BEFORE: MARIA N. O-DONNELL, RPR NOTARY PUBLIC DATE: JANUARY 2, 2008, 12:07 P.M. PLACE: ANGINO & ROVNER, PC 4503 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA APPEARANCES: ANGINO & ROVNER, PC BY: RICHARD A. SADLOCK, ESQUIRE FOR - PLAINTIFFS GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS BY: DAVID E. COOK, ESQUIRE. FOR - DEFENDANT son Fwl' lix- w 20130 Linglestown Road • Suite 103 • Harrisburg, PA 17110 717.540.0220 9 Fax 717.540.0221 • Lancaster 717.393.5101 Multi-Pap TM R. TIMOTHY REINFORD JANUARY 2, 2008 page 2 Page 4 L WITNESSES 1 Q Currently employed? 2 NAME EXAMINATION 2 A Am I? Yes. 3 R. TIMOTHY REINFORD 3 Q Okay. Where are you employed? 4 6Y: MR. COOK 3 4 A Employed at Snyders Paint Store. 5 6Y: MR. SACLOCK 12 5 Q How long have you been there? 6 6 A Since the end of May '07. 7 Q What's your job title there? 8 8 A Clerk. 9 9 Q What are your job responsibilities there? 10 10 A Daily store activities, mixing paint, delivering II 11 paint, picking up paint. 12 12 Q Is that hourly? 13 13 A Yes. 4 14 Q How much an hour? 15 15 A Geez. I believe I am at eight dollar an hour. 16 16 Q Okay. By the way, before I get too far into 17 17 this, you sat here through two -- at least two separate le 18 sets of instructions on depositions? 19 19 A I understand the instructions, yes. 20 20 Q I don't need to explain them to you again, 21 21 correct? 22 22 A Correct. 23 23 Q Thank you. 24 24 Prior to working at Snyders, where were you 25 25 employed? Page 3 Page 5 1 STIPULATION 1 A Prior to working at Snyders, I was employed at 2 It is hereby stipulated by and between counsel 2 Velocity Cycles. 3 for the respective parties that reading, signing, sealing, 3 Q How long were you there? 4 certification and filing are hereby waived; and that all 4 A I was at Velocity Cycles from October of '04 to 5 objections except as to the form of the question are 5 March of '06. 6 reserved to the time of trial. 6 Q Okay. Was that an hourly position? 7 7 A That was an hourly position. 8 R. TIMOTHY REINFORD, called as a witness, being 8 Q Okay. About how much an hour? 9 d uly sworn, testified as follows: 9 A I believe I was at nine dollars an hour. 10 EXAMINATION 10 Q Okay. Was there any employment between March of 11 BY MR. COOK: 11 '06 and May '07? 12 Q State your full name for the record. 12 A I am a private drum teacher. 13 A Certainly. Raymond Timothy Reinford. 13 Q And about I guess lessons once a week? 14 Q Date of birth? 14 A Yes. I have about thirty students. 15 A 11-20-65. 15 Q Now, just so we're clear, is that constant? I 16 Q First marriage? 16 mean is -- has that been since say '05 till the present 17 A Yes. 17 or -- 18 Q Do you have any other children? 18 A Currently. I have thirty students. 19 A Yes. 19 Q Okay. 20 Q Okay. How many? 20 A I don't know how you want me to word it. When 1 21 A One son. 21 started, I probably had about fifteen or twenty, that was 22 Q What's his name? 22 May of '06. 23 A Eli. 23 Q That's what I am looking for. 24 Q What's his day of birth? 24 Now, all right. So March '06, you are no longer 25 A April 7th, 1993. 25 employed by Velocity Cycles? Page 2 - Page 5 WWWTl1WWV- 1 • W W V%Y 1WWT TAW Tr11TA TA W T -71 r! LIA A/1AAI?91?'t 1A1 C1 Al R. TIMQTHY REINFORD Multi-Pager"` JANUARY 2, 2008 - Page 6 1 A Correct. 2 Q And did you choose to leave? Did they close up 3 shop? Did they downsize? 4 A I was giving -- I was told that I was -- I should 5 leave, I was fired. 6 Q Did they say why? 7 A No, he didn't. 8 Q Okay. So between March of '06 and May '06, did 9 you work anywhere? 10 A No, I did not. 11 Q May '06, you started drum lessons? 12 A Correct. 13 Q Started with about fifteen students, now up to 14 about thirty. Once a week lessons? 15 A Once a week lessons. 16 Q Half an hour duration? 17 A Half an hour. 18 Q And how much for a half hour? 19 A $15. 20 Q Okay. Do you do these evening, weekend or during 21 the day? 22 A Mostly weekday evenings, afternoon evenings. 23 Q All right. Do you currently have a drivers 24 license? 25 A Yes, sir. Page 7 1 Q About how long have you had it? 2 A Since I was sixteen. 3 Q Without making me do the math, about when would 4 that be? 5 A Seven -- '80, '811 probably got it. 6 Q Ever been suspended, revoked? 7 A No. 8 Q Any moving vehicle violations? 9 A Speeding tickets when I was younger, yes. 10 Q All right. Any within say the last five years? 11 A No, sir. 12 Q Okay. The camper that was attached to this, to 13 your truck, it was your truck, correct? 14 A It was my father's truck. 15 Q Okay. 16 A My father's camper. 17 Q Okay. Did that have lights on it, on the back of 18 it? 19 A Yes. 20 Q Were they hooked up? 21 A Oh, yes. 22 Q You need to hook them up, right? 23 A Yes. 24 Q Did you check to make sure they were operational 25 before you left? Page 8 1 A Yes. 2 Q Where were you guys coming from? 3 A We were coining home from Chincoteague, Virginia. 4 Q Coming back from Virginia. All right. 5 About how far from your home were you when this 6 accident occurred? 7 A I was turning onto our street, so that would be 8 less than a quarter mile. 9 Q What do you remember about the accident? 10 A Well, I was sitting at -- in my lane waiting to 11 turn left onto our street. And I was waiting for traffic 12 to pass so that I could make that left turn. And I was -- 13 as I was sitting there, we felt a little jar to the camper. 14 My wife turned to me and said I think somebody just hit us. 15 I said I think you are right. My intention was then to 16 turn onto our street, pull off to the side and get out and 17 see what all happened. 18 As I proceeded to make my left turn after the 19 traffic cleared, from what I remember, just a smashing 20 sound, being jolted, and realized that somebody hit us. 21 Q Okay. That was on your left-hand side, on the 22 driver's side? 23 A Coming from my left-hand side, driver's side, 24 yes. 25 Q That's while you were in the process of making Page 9 1 the left? 2 A Correct. 3 Q Okay. There was mention about a videotape. You 4 had taken the video? 5 A Yes, yes, I did. 6 Q That was at the scene of the accident? 7 A That's correct. 8 Q About how long after the accident? 9 A Probably within five minutes. 10 Q Okay. What else do you remember about the 11 accident or after the accident happened? Well, let me back 12 up. Let me ask you, after you felt what we will call the 13 second impact -- 14 A Right. 15 Q As you are trying to make a left-hand turn -- 16 A Yes. 17 Q What was the first thing that you remember doing? 18 A Trying to get out of my seat and realizing that I 19 could not get out. The impact literally tilted my seat. 20 Obviously, the car was right there. I could not get out my 21 door. I was making sure that my wife and my daughter were 22 okay. And the next thing that I recall is being outside of 23 the vehicle, so I must have climbed out the passenger side. 24 Q Okay. And do you remember observing anything 25 once you were outside? ?age6-Page 9 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 A 4 Multi-Page R. TIMOTHY REINFORD JANUARY 2, 2008 Page 10 Page 12 1 A Yes, I remember looking at our truck, noticing 1 to that. At this point, yes, I am a dollar less than hour 2 that our truck was actually pushed quite a few feet from 2 than what I was at Velocity Cycles. 3 the impact point. I remember noticing how severe the 3 Q Do you know about how long that you collected 4 damage was on my driver's door. 4 unemployment? 5 Q Let me stop you there for a second. When you say 5 A Six months. 6 it was pushed a few feet -- 6 Q Okay. All right. 7 A Correct. 7 Do you know anybody else other than the police 8 Q What did you observe that caused you to believe 8 officers who responded or who were there at the accident 9 that the vehicle had been pushed? 9 scene that night other than your wife and your daughter? 10 A When I was turning on to our street where the 10 A I know there were bystanders that came out of the I 1 truck ended up, if I would have continued going straight, I 11 accident. 12 would have went right into a telephone pole. So my truck 12 Q Okay. Are you aware of anybody else that saw the 13 was actually pushed to where I couldn't have continued 13 accident? 14 straight. 14 A No, I am not. 15 Q Okay. Had you seen the other vehicle at any 15 MR. COOK: Okay. That's all I have. 16 time, at any point in time? 16 BY MR. SADLOCK: 17 A No time. 17 Q Did you have any contact with the defendant at 18 Q Prior to looking out your driver's side window 18 the accident scene? 19 and seeing it -- 19 A No, I did not. 20 A I did not see the vehicle prior to impact. 20 Q Did you observe her at any time at the accident 21 Q --against your car? 21 scene? 22 As far as things around the house, have they 22 A No, I did not. 23 changed at all since the accident? 23 Q Okay. Because your wife I think had some 24 A Yes. 24 testimony that you may have seen her walking around or 25 Q Okay. How so? 25 doing field sobriety tests? Page 11 Page 13 1 A I have to do a lot more of the household chores. 1 A No, I didn't see that at all. 2 Q Okay. What kind of chores do you have to do now 2 MR. SADLOCK: Okay. Thank you. 3 that you didn't have to do before? 3 (Whereupon, the deposition was concluded at 4 A I do all of the laundry. I do most of the 4 12:20 p.m.) 5 vacuuming and cleaning, getting our daughter off to school, 5 6 grocery shopping, maintaining the vehicles, maintaining the 6 7 house. 7 8 Q Would you agree the number of arguments have 8 9 increased since the accident? 9 10 A I would agree. 10 11 Q Okay. Would you say that they're focused on 11 12 particular issues, or are they just -- could be anything? 12 13 A Arguments are majority about finances. 13 14 Q Any particular issue? 14 15 A Whether it be like a mortgage payment or car 15 16 payment, money that we used to have before to do certain 16 17 things we can't do now. It would be lack of money to make 17 18 our normal monthly payments on things. 18 19 Q Okay. If I am correct in this, your I guess 19 20 income has gone down probably about a dollar an hour or so 20 21 from the time that you left Velocity Cycles to your current 21 22 position. Does that sound about right? 22 23 A That sounds -- that year that I was laid off or 23 24 left, was fired from Velocity Cycles, I collected 24 25 unemployment and actually maintained a salary, it was equal 25 Page 10 - Page 13 R. TIMOTHY REINFORD ' Multi-Page`'"` JANUARY 2, 2008 Page 14 1 COUNTY OF DAUPHIN 2 : SS 3 COMMONWEALTH OF PEN- SYLVANIA : 4 I, Maria N. O'Donnell, a Notary Public, authorized to 5 administer oaths within and for the Commonwealth of 6 Pennsylvania, do hereby certify that the foregoing is the 7 testimony of R. TIMOTHY REINFORD. 8 I further certify that before the taking of said 9 deposition, the witness was duly sworn; that the questions 10 and answers were taken down stenographically by the said 11 Reporter-Notary Public, and afterwards reduced to 12 typewriting under the direction of the said Reporter. 13 I further certify the said deposition was taken at 14 the time and place specified in the caption sheet hereof. 15 I further certify that I am not a relative or 16 employee or attorney or counsel to any of the parties, or a 17 relative or employee of such attorney or counsel, or 18 financially interested directly or indirectly in this 19 action. 20 1 further certify the said deposition constitutes 21 a true record of the testimony given by the said witness. 22 IN WITNESS WHEREOF, I have hereunto set my hand 23 this 2ND day of JANUARY, 2008. 24 Maria N. O'Donnell, RPR 25 Notary Public o Page 14 - Page 14 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 a v • 4 r ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and NO. 07-3609 CIVIL TERM R. TIMOTHY REINFORD, Plaintiffs V. CIVIL ACTION - LAW VALERIE LAIR, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 1-/' day of January, 2008, I, David E. Cook, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the Motion for Partial Summary Judgment, by overnight mail, addressed to the party or attorney of record as follows: Richard A. Sadiock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: DAVID E. COOK, ESQUIRE Supreme Court I.D. No. 78318 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Valerie Lair ±7 ' G. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-3609 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/03/2008 MC o4f& A Afor DEFENDANT R1.51 133-H DE11-0729067 14524-L21 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CASE NO: 07-3609 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HARRISBURG HOSPITAL PINNACLE EMPLOYMENT RECORDS TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS,on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/14/2007 CC: MICHAEL SCHEIB, ESQ. - Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 133-H DB02-0382191 14524-CO1 r COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 VS. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL PINNACLE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RMER **** at The MCS Groff Inc 1601 Market Street Suite 800, P ilad p ia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above.. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESQ. ADDRESS: 110 S. NORTHERN WAY YORK PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: la?0'7 / dx Seal of the Court BY THE COURT: P othonotary/Clerk, Civil *Vision Deputy 14524-21 1 • EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL PINNACLE 111 S. FRONT STREET HARRISBURG, PA 17101 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 10-01-2000 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 U.49S 133-H SU10-0715438 14524-L21 r ?? ? a' <'', a ? ? `?°? ANGINO & ROVNER, P.C. Richard A.Sadlock Esquire Attorney ID# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 Phone: (717) 238-6791 Fax: (717) 238-5610 Attorneys for Plaintiffs: E-mail: rsadlock u,angino-rovner.com Rhonda and R Timothy Reinford RHONDA L. REINFORD and R. TIMOTHY REINFORD, her husband, Plaintiffs V. VALERIE LAIR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3609 Civil Term JURY TRIAL DEMANDED PLAINTIFFS' RESPONSE TO DEFENDANT'S MOTION FOR PARTIAL SUMMARY JUDGMENT AND NOW comes the Plaintiffs, Rhonda L. and R. Timothy Reinford, by and through his attorneys, Angino & Rovner, P.C., and hereby files the following response to the Defendant's Motion for Partial Summary Judgment. Plaintiffs' Complaint speaks for itself. 2. Plaintiffs' Complaint speaks for itself. 3. Plaintiffs' Complaint speaks for itself. By way of amplification, the Police Accident Report for the instant accident is attached hereto as Exhibit A. 4. Plaintiffs' Complaint speaks for itself. By way of amplification, Plaintiffs' Complaint includes a claim for punitive damages because, at the time of the accident, the Defendant's BAC was .222. 5. Plaintiffs' Complaint speaks for itself. 6. Plaintiffs' Complaint speaks for itself. 7. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Defendant's conduct was outrageous. Further, Defendant acted with reckless indifference to the rights of Plaintiffs in causing the instant motor vehicle accident. 8. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, in the instant action, Defendant's conduct of operating her vehicle with a BAC of .222 is sufficient ground for allowing punitive damages. 9. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Plaintiffs can show that Defendant's conduct was outrageous and therefore sufficient to warrant punitive damages. Specifically, Defendant's BAC was .222. See, Exhibit A. By her own admission, Defendant was aware that driving while under the influence of alcoholic beverages increases the likelihood or risk of injury. See, Defendant's Deposition attached hereto as Exhibit B, p, 10, lines 3-17. Additionally, Defendant admitted, as of the date of the instant accident, that the consumption of alcoholic beverages affects the ability to operate 374043 2 a motor vehicle. Specifically, Defendant admitted, "That you don't have the reactions, and you are not yourself" See, Exhibit B, at p. 10, lines 18-25. Defendant also admitted in her deposition that the consumption of alcohol would absolutely effect one's ability to see, perceive, and react. See, Exhibit B at p. 11, lines 1-11. Defendant admitted to drinking wine from approximately 3:00 or 4:00 p.m. (see, Exhibit B p. 13, lines 1-2) until approximately 8:15 p.m. See, Exhibit B, p. 18, lines 1-4. Defendant does not specifically recall how many glasses of wine she had or how large the wine glass was that she was using. See, Exhibit B, p. 16, lines 18-24. 10. Denied. By way of amplification, the Defendant cannot specifically identify how much alcohol she had to drink on the date of the accident. See, Exhibit B, p. 16, lines 23-24. 11. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Defendant is not an expert. Further, a BAC of .22 clearly indicates that Defendant was in fact significantly intoxicated and greatly impaired when she left her residence. 12. Defendant's deposition testimony regarding the distance from her home to Burger King speaks for itself. 13. Admitted. 14. It is admitted that Defendant traveled approximately one block prior to the accident. By way of amplification, Defendant admitted that in that entire block she never saw Plaintiffs' truck or camper until just prior to impact. See, Exhibit B, p. 23, lines 21-24 and p. 23, line 17. 374043 3 15. Denied. By way of amplification, Defendant stated that she did not know her travel speed. See, Exhibit B, p. 24, line 21. 16. Admitted. 17. Admitted. 18. Denied. By way of amplification, as previously indicated herein, Defendant never saw Plaintiffs' vehicle and camper until just prior to impact. See, Exhibit B, p. 23, lines 4-6 and 14-17. 19. Defendant's averment is a blatant mischaracterization of Defendant's testimony. In fact, Defendant's testimony is that she hit Plaintiffs' vehicle, then tried to swerve and then hit the vehicle again. See, Exhibit B, p. 26, lines 23-25. 20. Plaintiffs' deposition testimony speaks for themselves. 21. Plaintiffs' deposition testimony speaks for themselves. 22. Plaintiffs' deposition testimony speaks for themselves. 23. Plaintiffs' deposition testimony speaks for themselves. 24. Plaintiffs' deposition testimony speaks for themselves. 25. Plaintiffs' deposition testimony speaks for themselves. 26. Plaintiffs' deposition testimony speaks for themselves. 27. While Plaintiffs may not have seen Defendant's vehicle prior to impact, it is clear Mrs. Reinford saw the Defendant immediately following the accident. Upon approaching the Defendant's vehicle, Mrs. Reinford observed Defendant mumbling, glassy-eyed, slurring her speech, slumped over, and giving a strong odor alcoholic beverages. See, Defendant's Exhibit C, 374043 4 p. 72, lines 18-25 and p. 73, lines 1-17). Further, Mrs. Reinford spoke with the investigating officer shortly after the accident. The investigating officer advised Mrs. Reinford that, immediately following the accident while still at the accident scene, Defendant could not remember her home telephone number or address because of her level of intoxication. See, Defendant's Exhibit C, p. 74, lines 13-19. 28. Admitted. 29. Denied. By way of amplification, Plaintiff testified that Defendant's consumption of alcohol was outrageous. See, ¶ 27 herein. 30. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, attached hereto as Exhibit C are copies of photographs of the property damage sustained by Plaintiffs. In fact, this was a significant impact. Further, it is hard to believe that in one block, Defendant could not see Plaintiffs' vehicle. 31. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, Defendant's own knowledge regarding the affects the alcohol consumption, the fact that Defendant never saw a large pick-up truck towing a large camper prior to impact, and Defendant's slurred speech, glassy-eyes and odor of alcohol are all facts to be considered. 32. See ¶ 31 herein. 374043 5 33. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, as previously indicated herein, Defendant's conduct, admissions, actions, inactions, and failure to react, are all sufficient factors to impose punitive damages herein. 34. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, as previously acted herein, Defendant's conduct, admissions, actions, inactions, and failure to react, are all sufficient factors to impose punitive damages herein. 35. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, as previously acted herein, Defendant's conduct, admissions, actions, inactions, and failure to react, are all sufficient factors to impose punitive damages herein. 36. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, as previously acted herein, Defendant's conduct, admissions, actions, inactions, and failure to react, are all sufficient factors to impose punitive damages herein. 37. Defendant's averment is a conclusion of law to which no responsive pleading is required. To the extent the averment may be deemed factual, it is hereby specifically denied. By way of amplification, as previously acted herein, Defendant's conduct, admissions, actions, inactions, and failure to react, are all sufficient factors to impose punitive damages herein. 374043 6 WHEREFORE, Plaintiffs respectfully request Your Honorable Court deny Defendant's Motion for Partial Summary Judgment. Date: January 15, 2008 374043 7 Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiffs C 'IIONWEALTH OF PENNSYLVANbi POLICE ACCIDENT REPORT l- W REPORTABLE 0 NON - REPORTABLE ? PENNDOT USE ONLY POLICE INFORMATION ACCIDENT LOCATION 1. INCIDENT NUMBER 2005-4056 20. COUNTY CODE Cumberland 21 2. AGENCY NAME WEST SHORE REGIONAL POLICE DEPARTM 21. MUNICIPALITY CODE Lemoyne 403A 3. STATION/ WSRPD 4. PATROL CIT -j ZONE PRINCIPAL ROADWAY INFORMATION 5. I VES I -JATOR Hard AM OSE ADGE 32 5 22. ROUTE NO. OR - UMBER STREET NAME South 3rd Street BADGE 32-1 NUMB R 23. SPEED 24. TYPE 25. ACCESS 25 E ?.INVESTIGATION 8. RIVAL LIMIT HIGHWAY CONTROL I DATE 10/22/20 T E 20:39 INTERSECTING ROAD: ACCIDENT INFORMATION 26. ROUTE NO. OR Walton Street STREET NAME 9. ACCIDENT DATE 10/22/2005 10. DAY OF W EEK Saturda 27. SPEED 28. TYPE 29. ACCESS 25 1 11 S OF 20 :39 y 12. NUMBER LIMIT HIGHWAY CONTROL DAY OF UNITS 2 IF NOT AT INTERSECTION: 13. #KILLED 0 14. #INJURED 0 15. PRN. PROP. 30. CROSS STREET OR ACCIDENT Y ? N ® SEGMENT MARKER 16. DID VEHICLE HAVE TO BE 17. VEHICLE DAMAGE 31. DIRECTION 32 DISTANCE REMOVED FROM THE SCENE? 0 - NONE UNIT 1 1 - LIGHT 21 FROM SITE N S E W . FROM SITE 0.00 33. DISTANCE WAS UNIT 1 ® UNIT 2 2 - MODERATE 3 - SEVERE UNIT 2 MEASURED ESTIMATED Y N ? Y ? N ® 34 CONSTRUCTION P . RINCIPAL INTERSECTING 35. TRAFFIC ZONE CONTROL 18. HAZARDOUS MATERIALS Y ? ® 19. PENNDOT DEVICE E] N PROPERTY Y 11 N DO UNIT # 1 UNIT # 2 36. LEGALLY Y PARKED? ? N ® 37. REG. DPB-6256 PLATE 38. STATE PA 36. LEGALLY Y N 37. REG. 38. STATE PARKED? 11 PLATE WR2517M PA 39. PA TITLE OR OUT-OF-STAT E VIN 55389018901 LA 39. PA TITLE OR 51 374494901 OUT-OF-STATE VIN 40. OWNER Valerie Lair A 40. OWNER Donald Reinford 41. OWNER ADDRESS 1490 Brandt Ave 41. OWNER ADDRESS 411 Dogwood Lane 42. CITY, STATE & ZIPCODE New Cumberland, PA 17070 42. CITY, STATE & ZIPCODE Lebanon, PA 17042 43. YEAR 2 001 44. MAKE Mazda 43. YEAR 1998 44. MAKE Chevrolet 45. MODEL - (NOT 46. INS. BODY TYPE) TRIBUTE LX Y ® N ? LINK ? 45. MODEL -(NOT 46. INS. SILVERADID BODY TYP E) Y ($ N ? LINK ? 47. BODY TYPE 48. SPECIAL 49. VEHICLE 06 USA 0 01 47. BODY 48. SPECIAL 49. VEHICLE 50 GE OWNERSHIP TYPE USAGE 16 OWNERSHIP 02 50. INITIAL IMPACT POINT 51. VEHICLE 52. TRAVEL 01 STATUS 0 0 50. INITIAL IMPACT 51. VEHICLE 52. TRAVEL 09 SPEED POINT STATUS 0 SPEED 0 53. VEHICLE GRADIENT 54. DRIVER 55. DRIVER I PRESENCE I CO 2 53. VEHICLE 54. DRIVER 55. DRIVER 1 NDITION GRADIENT PRESENCE I CONDITION 1 56 DRIVER NI IMRFR 17388645 57. STATE I 'A 56. DRIVER 57. STATE 20 864 657 NI IMRFR PA 58. DRIVER NAME Valerie Lair 58. DRIVER NAME Ray Reinford 59. DRIVER ADDRESS 1490 Brandt Ave 59. DRIVER ADDRESS 227 Walton Street 60. CITY, STATE & ZIPCODE New Curnberlalld PA 17070 60. CITY, STATE Lemo PA 17043 yne, & ZIPCODE 61. SEX r 62 . DATE OF 03/13/1956 63. PHON 7 1 BIRTH 7) 877-3251 61. SEX 62. DATE OF 63. PHONE M BIRTH 11/20/1965 (717) 774-9595 64 COMrJ VEH ( 11 fJ Y 65 DRIVER C CLA 64. COMM VEH 65. DRIVER - d - -- SS _ Y ? N L`Sl CLASS C/M 67. CARRIER 67. CARRIER 68. CARRIER 68 CARRIER ADDRESS . ADDRESS 69. CITY, STATE 69. CITY STATE & ZIPCODE , & ZIPCODE 70. USDOT # ICC# PUC# 70. USDOT # ICC# PUC# 72. VEH. 73. CARGO 74 GVWR CONFIG. BODY TYPE . 72. VEH. 73. CARGO 74. GVWR 75. NO. OF 76. HAZARDOUS 77 RELEASE OF H CONFIG. BODY TYPE AXLES . AZMAT 75. NO. OF 76. HAZARDOUS 77 RELEASE OF HAZMAT MATERIALS Y ? N 14 LINK ? AXLES MATERIALS . Y ? N N LINK ? 1-4 2-4 XX REFER TO OVERLAY SHEETS ,M1 REPORTABLE IN NON - REPORTABLE E3 PENNDOT USE ONLY INCIDENT INCIDENT COUNTY MUNICIPAL NUMBER 2005-4056 DATE 10/22/2005 CODE 21 CODE 403A 82 PERSON INFORMATION USE OVERLAY #2 SHEET FOR CODES A B C D E F G NAME ADDRESS H I J K L M 87. NARRATIVE: On Saturday, October 22, 2005 at 2039 hours, I was dispatched to a reported traffic accident at the intersection of South 3rd Street and Walton Street in the Borough of Lemoyne. On arrival, I found that the accident had involved two (2) vehicle's. Both vehicle's were still parked on the roadway and both appeared to have extensive damage. A request was made at this time for the Fire Department, Fire Police and an ambulance to respond to the scene. The driver of Unit #1 was still sitting in her vehicle and I asked if she had been injured in the accident. The driver found to be a Valerie Lair stated she was not injured. I then collected a vehicle registration card and vehicle insurance card and was advised by Lair that she did not have her driver's license with her. I then questioned Lair regarding the accident . Lair stated, "we were both traveling this way (motioned South on 3rd Street) and 1 don't know what happened after that". While speaking with Lair, I detected a strong odor of alcoholic beverage on her breath as she spoke. I ler eyes were bloodshot and glassy and her speech was slurred when she spoke. I then spoke with the driver of Unit #2 found to be a Ray Timothy Reinford. Reinford provided this officer with his driver's license, vehicle registration card and Insurance. I then questioned Reinford in regards to the accident. Reinford while pulling a 1997 Terry Camper was making a left hand turn off of South 3rd Street onto Walton Street when lie felt something hit his camper. Reinford said all of a sudden a vehicle struck the side of his pickup truck. Reinford stated, he had his left turn signal on at the time. In conducting the accident investigation, this officer attempted to conduct standerd field sobriety tests on Valerie Lair. Due to Lair's level of intoxication testing was terminated. Valerie Lair was placed Under Arrest for suspected driving under the influence of alcohol and transported to the Cumberland County Booking Center. Lair was advised of implied consent and submitted to a breath test which resulted in .222 % BAC. Unit # 1 vehicle was towed from the scene by Ken's Service Center. INFORMATION COMPANY INSURANCE COMPANY INFORMATION UNIT I POLICY UNIT POLICY NO NO 89. VIOLATIONS INDICATED 90. SECTION NUMBERS (ONLY IF UNIT UNIT 91. PROBABL 92. TYPE 93. RESULTS ? NO TEST 91. PROBABLE 92. TYPE 93. RESULTS USE TEST USE TE ST UNIT ? REFUSE 0. _ _°? ?UNK UNIT 0. _ -% COMMONWEALTH OF PENNSYLVANIA PAR CONTINUATION SHEET ? NO TEST 94.INVESTIGATION ? REFUSE COMPLETE? ? LINK YES ? NO E] 4-4 E X?t ? i3l T RHONDA L. REINFORD AND R. TIMOTHY REINFORD, HER HUSBAND, PLAINTIFFS V VALERIE LAIR, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAN COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3609 CIVIL TERM JURY TRIAL DEMANDED DEPOSITION OF: VALERIE CLIBER TAKEN BY: PLAINTIFFS BEFORE: MARIA N. O'DONNELL, RPR NOTARY PUBLIC DATE: JANUARY 2, 2008, 9:26 A.M. PLACE: ANGINO & ROVNER, PC 4503 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA APPEARANCES: ANGINO & ROVNER, PC BY: RICHARD A. SADLOCK, ESQUIRE FOR - PLAINTIFFS GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS BY: DAVID E. COOK, ESQUIRE FOR - DEFENDANT ALSO PRESENT: RHONDA L. REINFORD R. TIMOTHY REINFORD DAVID CLIBER H,rq hes Alb jrjf)t 2080 Linglestown Road • Suite 103 • Harrisburg, PA 17110 717.540.0220 • Fax 717.540.0221 • Lancaster 717.393.5101 Multi-Page VALERIE CLIBER 1ATKTTTADV n nnnn -3. ?vvo Page 2 Page 4. I WITNESSES 1 Q You are now married to Mr. Cliber who is resent 2 NAME EXAMINATION p 2 here today? 3 VALERIE CLIBER 3 A Yes. Yes. 4 BY: MR. SADLOCK 3 4 Q When did you and Mr. Cliber get married? 5 5 A This August. 6 6 MR. CLIBER: Fourth. 7 THE WITNESS: I think it was the second. B 8 Whatever was Thursday that week. 9 9 BY MR. SADLOCK: 10 10 Q All right. 2007? II 11 A Yes. 12 12 Q What is your current home address? 13 13 A 1490 Brandt Avenue, New Cumberland. 14 14 Q How long have you lived at that address? 15 15 A Four years, I believe. 16 16 Q Is that the address that you were residing on the 17 17 date of this accident? 1B 18 A Yes, sir. 19 19 Q And at time of the accident, did you reside with 20 20 anyone at that address? 21 21 A With Dave, yes. 22 22 Q Dave being your husband, Mr. Cliber? 23 23 A Yes, but he was not my husband at that time. 24 24 Q How long have you and Mr. Cliber been together? 25 25 A About five years. Page 3 1 STIPULATION 2 It is hereby stipulated by and between counsel 3 for the respective parties that reading, signing, sealing, 4 certification and filing are hereby waived; and that all 5 objections except as to the form of the question are 6 reserved to the time of trial. 7 (Discussion held off the record.) 8 VALERIE CLIBER, called as a witness, being duly 9 sworn, testified as follows: 10 EXAMINATION 11 BY MR. SADLOCK: 12 Q Would you state your full name, please? 13 A Valerie Cassel Cliber. 14 Q At the time of this accident, you were known as 15 Valerie Lair, is that right? 16 A Yes. 17 Q Was Lair at the time a married name or maiden 18 name? 19 A Married name. 20 Q At the time, were you -- of this accident, were 21 you marred to Mr. Lair or divorced already? 22 A Divorced. 23 Q And you are giving your name now, you mentioned 24 the name Cassel. Was that your maiden name? 25 A That was my maiden name. Page 5 1 Q So sometime in 2003 or 2008, we're in 2000 2 January, I just want to -- 3 A 2002 I believe, this is five, yes. 4 Q How long has he resided with you again? 5 A The whole time? 6 Q Are you currently employed? 7 A Yes. 8 Q How so? 9 A At Macy's. to Q Which Macy' s? 11 A Capital City. 12 Q How long have you worked there? 13 A Since Christmas Eve. 14 Q Of ' 07? 15 A This year, yes. 16 Q Prior to Macy's, where were you employed? 17 A Pinnacle Health for a couple months, 18 Psychological Associates. It was in Brady Hall. 19 Q Okay. Was your actual employer Pinnacle Health 20 or Psychological -- 21 A Psychological Associates. 22 Q You said for a few months? 23 A Yes. 24 Q Tell me what month you started and what month 25 that you finished. Page 2 - Page 5 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 VALERIE CLIBER JANUARY 2, 2008 Multi-Page"` Page E 1 A September 25th to December 14th. 2 Q And was that employment directly through 3 Psychological Associates or through a temporary agency? 4 A Through the hospital, through Pinnacle Health, 5 yes. 6 Q And what did you do at Psychological Associates? 7 A I was a sectionary receptionist -- secretary 8 receptionist. 9 Q And why did you leave their employment in 10 December? 11 A Well, actually they let me go. I accidently sent 12 out a form. It's against the HIPAA rules with the wrong 13 patient, it really -- it was not a real good fit. I should 14 have left myself before, but -- 15 Q Prior to psychological Associates, where did you 16 work? 17 A I was laid off from Pealers Flowers. I was there 18 ten years. Downsizing. 19 Q All right. When were you laid off? 20 A June 4th. 21 Q Of what year? 22 A This summer '07. 23 Q '07? 24 A Yes. 25 Q You started with them sometime back '97? Page 7 1 A '97, September '97. 2 Q What did you do for Pealers? 3 A I was a customer care manager, call center 4 manager. 5 Q Tell me the full extent of your education. 6 A Well, four years of college, Millersville, 7 teaching, B.S. in education, elementary education. 8 Q When did you obtain that degree? 9 A '78, '78. 10 Q You had a teaching, I believe elementary 11 education? 12 A Yes, B.S., education. I had a dual major, early 13 childhood and el ed. 14 Q Were you ever employed in the education field? 15 A No, not directly, not in a school district. I 16 was -- I was a daycare director when we lived in the 17 Poconos years ago. 18 Q Prior to this case, were you ever named as a 19 defendant to a lawsuit before? 20 A Never. 21 Q Other than this case since it was filed, have you 22 been named as a defendant to a lawsuit? 23 A No, Sir. 24 Q Do you recall the date for this accident? 25 A It was October I think 21st or 22nd, '05. ?age 6 - Page 9 Page 8 1 Q Prior to October 22 of 2005, were you involved in 2 any other accidents? 3 A (Witness shaking head no). 4 Q Is that a no? 5 A I am sorry, no. 6 Q That's okay. Since October 22, 2205, have you 7 been involved in any motor vehicle accidents? 8 A No. 9 Q As a result of this accident, did you give any 10 statements to anyone other than to your attorneys office 11 such as an investigating police officer or your insurance 12 company or the Reinfords' insurance company? 13 A I -- maybe to the insurance company. I don't -- 14 I honestly don't know. 15 Q Okay. Was there a recorded statement given? 16 MR. COOK: I don't recall one. I can 17 doublecheck. 18 THE WITNESS: No, I think maybe she just called 19 to tell me what was happening or -- 20 BY MR. SADLOCK: 21 Q Okay. Other than for any charges that may have 22 developed from this particular accident, have you ever been 23 charged with any other crimes in the Commonwealth of 24 Pennsylvania? 25 A No, sir. 1 Q All right. Convicted of any other crimes? 2 A No. 3 Q Any other traffic violations other than for this 4 accident? 5 A No, sir. 6 Q Again, other than as it pertains to this 7 accident, has your driver's license ever been suspended or 8 revoked for any reason? 9 A No, sir. 10 Q Do you currently hold a Pennsylvania driver's 11 license? 12 A Yes, sir. 13 Q Have you held a license from any other state 14 other than Pennsylvania? 15 A No, sir. 16 Q When did you get your driver's license? 17 A I think when I was seventeen, so I can't even 18 think. '73, maybe seventy-two, seventy-three. 19 Q What's your date of birth? 20 A March 13th, 1956. 21 Q And during -- when you were first studying to get 22 your license, did you take driver's education? 23 A Yes, in school. 24 Q At that time, during driver's education, did you 25 take or have any education or training as it pertains to Page 9 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 Multi-Page' VALERIE CLIBER IAXTFTADV n nnnn Page 10 1 driving after consuming alcoholic beverages? 2 A I don't know, maybe. I don't know. 3 Q Since that time, from the time that you got your 4 license up to the date of this accident, had you seen any 5 ads on T.V., seen any billboards or read any articles or 6 aware in any way, shape or form about driving after 7 consuming alcoholic beverages? 8 A Yes, yes, yes. 9 Q What was your understanding about driving after 10 consuming alcoholic beverages? 11 A That you shouldn't do it, you could hurt 12 yourself, hurt somebody else. 13 Q So prior to October 22, 2005, you were aware that 14 driving under the influence of alcoholic beverages 15 increases the likelihood or risk of injury to yourself and 16 others? 17 A Yes. Yes. 18 Q Prior to October 22 of 2005, were you aware of 19 the effects on an individual consuming alcohol in terms of 20 ability to operate a motor vehicle? 21 A Yes. 22 Q Was that your understanding prior to October 23 22nd? 24 A That you don't have the reactions, and you are 25 not yourself. Page 11 1 Q Your ability to see, perceive and react is 2 greatly effected? 3 A Absolutely. 4 Q Was it your understanding as well, again in 5 October of 2005, that the more alcohol consumed, the 6 greater effect on your ability to operate a motor vehicle 7 safely? 8 A Yes. 9 Q Again, the more you consume, the ability to see, 10 perceive and react decreases? 11 A Correct. 12 Q You were aware of that prior to October 22? 13 A Correct. 14 Q I believe that the accident, according to the 15 police report, happened at about 8:39 in the evening. Is 16 that your understanding? 17 A Yes. 18 Q Do your recall what day of the week October 22 19 was? 20 A I believe it was a Saturday. 21 Q Do you recall what you did that day prior to the 22 accident? 23 A Yes. Got up, had breakfast, did some cleaning, 24 got my mom, went to a baby shower, came back, and I was 25 doing cross word puzzles. He was -- we were watching ?? 11a1 4? L.VVO Page 12 1 football. And -- 2 Q You mentioned you had a baby shower. Where was 3 that baby shower? 4 A Baughman Church in New Cumberland. 5 Q Was that for a family member or friend? 6 A Friend. 7 Q Was there any alcoholic beverages served at the 8 baby shower? 9 A No, no. 10 Q Allow me to finish my question. It's okay. It's 11 all right. So far I haven't changed midstream, but 12 occasionally you never know when I might start a question 13 and change my mind in mid-question. You want to make sure 14 that you hear the question. Again, so the court reporter 15 only has to wont' about taking one of us down at a time. 16 Prior to leaving for the baby shower, had you 17 consumed any alcoholic beverages? 18 A No. 19 Q You mentioned you had -- I think that you had 20 breakfast that morning? 21 A Yes. 22 Q Do you recall what you had to eat? 23 A Eggs, toast, bacon. 24 Q What time was the baby shower? 25 A I think -- I think it was around one. Page 13 1 Q What time did it end? 2 A Three-ish. Three, four we got home. 3 Q You mentioned that you picked up and brought your 4 mom to the shower, is that correct? 5 A Yes. 6 Q Did you take her back to your house or drop her 7 off at her house? 8 A No, I took her to her home. 9 Q You continued then to your home? 10 A Yes. 11 Q Was your current husband at home when you got 12 home? 13 A I -- he wasn't my husband. 14 Q I know that. 15 A But yes, he was there. 16 Q What did you do the rest of the day up until the 17 time of the accident? 18 A Up until the time of the accident, we were 19 sitting watching football. I was doing crossword puzzles, 20 and we had a couple glasses of wine. 21 Q When you say a couple glasses of wine, can you -- 22 A I have no idea. I have no idea. 23 Q Were you drinking - was this wine from a bottle 24 or a box that -- 25 A Yes, a box, a box, yes. Page 10 - Page 13 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 VALERIE CLIBER Multi-Page"` JANUARY 2, 2008 Page 14 1 Q White wine, red wine, do you know? 2 A White. 3 Q Again, do you know how many glasses that you had? 4 A I have no idea. I have no idea. 5 Q Had you consumed any other alcoholic beverages on 6 October 22, 2205 other than wine? 7 A Not to my recollection. 8 Q Were you on any medication on the day of the 9 accident? 10 A Well, I have a regular medication that I take. I 11 have Atenolol. I take Lexapro, Azichol for -- I have 12 Crohn's disease, and whatever vitamins that I take. 13 Q The other -- you mentioned one -- the drugs that 14 you take for Crohn's disease. What do you take the other 15 medications for? 16 A I had panic attacks when my ex-husband and I 17 first moved back here, so she gave me the betablocker, 18 which is the Atenolol and the Lexapro which is a serotonin 19 booster to stop all of the -- 20 Q These are medications that you took on October 21 22,2205? 22 A I take them every day. 23 Q Are they medications that you take in the 24 morning? 25 A Morning. Page I6 A No. I -- no. I did not go to the store that 2 day, no. 3 Q You mentioned that you had breakfast in the 4 morning. Did you have any other food of any kind up to the 5 time of the accident? 6 A Yes. There was tea sandwiches, vegetables, all 7 kinds of stuff at the shower. I had no cake, but I ate 8 other things. 9 Q You said that you got home somewhere between 10 three and four, is that correct? 11 A Uh-huh. 12 Q Is that ayes? 13 A Yes. 14 Q Prior to leaving your home and ultimately being 15 involved in the accident, did you have anything to eat 16 further at your home? 17 A No, I did not. 18 Q You mentioned that you were drinking wine. Were 19 you drinking -- what type of glass were you using? 20 A Just a little wine glass. 21 Q Do you know how many ounces that glass held? 22 A I have no idea. 23 Q You don't recall how many glasses that you had? 24 A No, I do not. 25 Q You mentioned that Mr. Cliber was drinking beer. Page 15 1 Q Had you taken them then on that day? 2 A Yes. 3 Q On any of those medications that you take, was 4 there any warnings about taking those medications and 5 consuming alcoholic beverages? 6 A No. No. 7 Q Or any interactions between these drugs and 8 alcohol? 9 A No. 10 Q Was Mr. Cliber also consuming wine? i l A No. 12 Q What was he drinking, if anything at all? 13 A He had beer. 14 Q Did you have any beer? 15 A No. 16 Q Any hard alcoholic? 17 A No. 18 Q Gin, vodka, anything of that nature? 19 A No. 20 Q Just wine? 21 A Just wine. 22 Q The box that you were drinking from, had you just 23 -- do you know how long that you had that box prior to -- 24 A No, I have no idea, none, I have no idea. 25 Q Had you just purchased it that day or -- 'age 14 - Page 17 Page 17 1 Do you recall how much beer he had to drink while you were 2 home? 3 A I have no idea. I have no idea. 4 Q Was there anyone else at your home that evening? 5 A No. 6 Q Obviously since you were involved in the accident 7 there came a time period where you left your home that 8 evening, is that correct? 9 A Yes. 10 Q What was your reason for leaving your home? 11 A Really stupid. They kept flashing this Burger 12 King commercial. And it wasn't that far, I felt fine, and 13 I went. And I went into the Burger King to get the 14 hamburgers. They said they did not have them. Then I 15 pulled out on the road, was going home, and then that's.... 16 Q What type of hamburger were you going for? 17 A It's a kind -- this is so stupid. God. It's 18 called a big angus burger, and it was a really good 19 hamburger. 20 Q They were sold out, they didn't have them? 21 A She said they weren't carrying them. 22 Q How far is the Burger King from your home in New 23 Cumberland? 24 A Less than a mile. Maybe a mile. Less than a 25 mile. HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 Multi-Page"` VALERIE CLIBER VA1TTTA 7fV n nnnn Page 18 1 Q And at that point -- what time was it when you 2 left your home? 3 A I wasn't paying attention. I don't know. A 4 little bit after eight. 8:15, 20. I don't know. 5 Q And had you been consuming wine that entire four 6 hours since you had been home? 7 A Well, off and on, yes. I was sitting watching 8 football and -- 9 Q Prior to October 22, 2005, how often did you 10 consume wine? 11 A A couple times a week. 12 Q When you did drink, how much would you drink 13 generally? 14 A A couple, two, three glasses I guess. 15 Q Two or three glasses two or three times per week? 16 A When I was at home, yes. 17 Q Prior to October 22 of 2005, had you ever 18 yourself considered yourself intoxicated? 19 A Probably in college. 20 Q Any time more recent than that? 21 A Not that I can think of, no. 22 Q Those times back in college when you felt 23 yourself intoxicated, how would you describe how you were 24 feeling at that time? 25 A Well, you just had too much beer at a party, you Page 19 1 just felt woozy and -- 2 Q On October 22, 2005, before you left your home to 3 go to Burger King after consuming wine, were you slurring 4 your speech at all? 5 A No. Go ahead. 6 Q Were you having any difficulty standing or 7 walking? 8 A No, sir. 9 Q Although you don't know or don't recall how much 10 wine that you consumed? 11 A I do not. 12 Q What was your blood-alcohol reading following the 13 accident? 14 A It's in the police report. Whatever it was that 15 they said. I don't recall that. It's there somewhere. 16 Q The police report indicates your blood-alcohol 17 concentration was point 222. Does that refresh your 18 recollection? 19 A That's what they said it was, yes. 20 Q Did you in any way contest that at any time? 21 A I didn't think that you really had a right to do 22 it. 23 Q Are you aware that's approximately three times 24 the level for intoxication? 25 MR. COOK: I will object to the form of the a?v?u?i G? GVVO Page 20 1 question simply because I think -- I am trying to remember 2 when they amended the statute. 3 BY MR. SADLOCK: 4 Q Well, if in fact the statute was amended at that 5 time, we're saying point 08 was the level. That would have 6 been approximately three times, correct? 7 A From what you are saying, yes. 8 Q If it was point 10, more than two times the 9 limit, is that correct? 10 A I guess. 11 Q Before leaving your home on that evening, did you 12 consider whether or not you should go given that you were 13 drinking? 14 A I did. I did not feel that there was anything 15 wrong. 16 Q You left your home alone? 17 A Uh-huh. 18 Q Is that yes? 19 A Yes. 20 Q Did Mr. Cliber make any effort to stop you from 21 going because of your consuming alcohol? 22 A No. 23 Q But again, prior to leaving your home on that 24 evening, you were aware of the effect of alcohol and the 25 ability to safely operate a vehicle? Page 21 1 A Yes, if I would have felt strange -- I don't 2 drink and drive. If I am allowed to elaborate, I think if 3 I would not have felt fine, I never would have gone for the 4 hamburger or anything else. 5 Q Do you -- do you ever drink out at bars or 6 restaurants? 7 A Back in the day, no more. 8 Q When you say back in the day, when was the day? 9 A Twenties, twenties, early. 10 Q When your age was in the twenties? 11 A Yes. 12 Q Since then you do not go out to bars, restaurants 13 or -- 14 A We do -- if we -- we'll have a drink, but we 15 don't really go out anywhere any more. 16 Q Have any of your job changes in any way been 17 associated with consumption of alcohol? 18 A No, sir. 19 Q What is your current height and weight? 20 A Five-four, and I weigh too much. I don't have to 21 tell you how much I weigh, do I? 22 Q Yes, you do. 23 A 165 maybe. 24 Q Any change in that from October 2005 to the 25 present? Were you the same then as you are now? HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 Page 18 - Page 21 VALERIE CLIBER JANUARY 2, 2008 Multi-Page Page 22 1 A No, I have been gaining weight. 2 Q How much would you weigh -- or did you weigh, if 3 you recall, on October 2005? 4 A Twenty, maybe thirty pounds less. 5 Q Tell me what you remember about the automobile 6 accident of October 22, 2205. 7 A I just remember pulling out of Burger King, and I 8 pulled right on the street. And the next thing I saw was 9 the vehicle. And I swerved to not hit it and then I hit 10 it, and that's all. 11 Q What street is the Burger King located on? 12 A Bridge Street in New Cumberland. 13 Q What street were you turning on to? 14 A I was taming out of Burger King on to Bridge 15 Street. 16 Q Okay. The police accident report indicates the 17 accident happened at the intersection of Walton Street and 18 South Third Street. 19 A Well, it's called Bridge Street. I don't know 20 why they call it South Third. It's -- in Lemoyne would be 21 Third Street, and New Cumberland, it's Bridge. 22 Q All right. Coming out of the Burger King parking 23 lot, would you have made a left turn or right turn? 24 A Right turn. 25 Q When you first got to the exit for Burger King, Page 23 1 did you have to stop before making the turn? 2 A I slowed and there was no traffic, and I just 3 pulled on the road. 4 Q As you were pulling onto the road, did you see 5 the Reinfords' vehicle? 6 A I did not see -- I did not see the vehicle. 7 Q How far did you travel before the accident 8 happened? 9 A It was about a block. 10 Q Can you give me an estimate in terms of feet for 11 that block or miles? 12 A I have no idea. It was about maybe three or four 13 houses. I -- 14 Q In those three or four houses, did you see the 15 Reinford vehicle? 16 A At the very last moment, I had. I don't recall 17 lights. I don't recall seeing anything. 18 Q Mr. Reinford was driving a truck pulling a 19 camper, is that correct? 20 A That's what I understand, yes. 21 Q And is it your testimony that you traveled three 22 houses or a city block and never saw their vehicle until 23 just prior to impact? 24 A Yes. 25 Q Was there anything obstructing your vision Page 24 1 through the windshield? 2 A No. 3 Q Anything other than the -- possibly the effect of 4 alcohol effecting your ability to see or perceive their 5 vehicle? 6 A It was dark and it was rainy. That's -- until 7 the vehicle was there. 8 Q Did you have your headlights on when you left the 9 Burger King? 10 A Oh, yes. 11 Q Low beam or high beam? 12 A Regular, no, just regular lights. 13 Q You said that it was raining. Was it -- how 14 would you describe the rain? 15 A Drizzle. It was warm and drizzly. 16 Q With your windshield wipers going? 17 A I don't think so. I don't think so. 18 Q How fast were you traveling immediately prior to 19 the accident? 20 A Well, not that fast. Twenty, I don't know, 21 twenty-five, I don't know. I don't normally drive very 22 fast anyway. 23 Q Did you have any food or beverages in the car? 24 A I don't recall, no, because I didn't have my 25 burgers, no, the money was laying on the -- Page 25 1 Q Back in October 2005, did you smoke? 2 A Yes. 3 Q Did you have a cigarette lit just prior to the 4 accident? 5 A I don't remember. 6 Q Was your radio on in the car? 7 A I don't remember. 8 Q Did you have a cell phone at that time? 9 A I did have a cell phone. 10 Q Were you talking on the cell phone prior to the 11 accident? 12 A No, sir. 13 Q When had you last consumed alcohol prior to 14 leaving your home to go to Burger King? Had you just 15 finished a drink? 16 A I don't remember. 17 Q You mentioned that you were consuming wine from a 18 box. Was the box -- how full was the box when you started? 19 A I have no idea. 20 Q Did you check it after the accident? 21 A No, I didn't even go near it, no. 22 Q Has there been any change in your drinking habit 23 since this accident? 24 A Yes. 25 Q How so? ?age 22 - Page 25 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 Multi-Page TM VALERIE CLIBER Page 26 1 A Well, I hardly drink any more, and I would never 2 even leave my house. We don't go out to dinner. We don't 3 do things that we would have done and take any kind of 4 chances any more. 5 Q I believe in some ads it talks about drinking and 6 driving, it talks about impairment begins with the first 7 drink. Have you heard that before yourself? 8 A Yes. 9 Q Did you hear that before October 22, 2005? 10 A I am sure I have. I am sure I have. 11 Q Did you give that any consideration before going 12 out on October 22, 2005? 13 A I didn't really think about it because I did not 14 feel intoxicated. 15 Q Even though you weren't aware of how many glasses 16 of wine that you actually consumed? 17 A No. 18 Q Or what your blood-alcohol level was before 19 leaving the house? 20 A Correct. 21 Q Describe the accident for me, please. What 22 happened? 23 A I did already. I just came up on the truck and I 24 hits. And I -- well, I tried to swerve and then I hit it 25 again. That's all. At that point, I just went into shock. Page 27 1 I remember nothing before after or anything. 2 Q Was the Reinfords' vehicle moving when you hit 3 it, or was it stationary? 4 A I seemed to me to be I guess stationary. I mean, 5 like I said, it just -- it all went into a blur. 6 Q Did you strike the actual vehicle that 7 Mr. Reinford was operating or the trailer? 8 A The trailer. 9 Q You hit the trailer first. Did you ever hit the 10 vehicle that Mr. Reinford was driving? 11 A When I bounced, it -- I guess when I turned, it 12 hit up further a little bit. 13 Q What happened then after the accident? 14 A I sat in my car. The police officer came, and he 15 said were you drinking and I said yes, I was. And he took 16 me out of the car, and he wanted me to do the walk thing. 17 And I said to him that I have a bad back and bad knees, 18 that it wasn't going to really make a difference. And so 19 then -- I don't remember in between, then he -- they 20 handcuffed me and took me in the back of the car and took 21 me to Carlisle. 22 Q Did you actually perform the walk test? 23 A I did it up there. I mean I was fine. I just 24 said right now if you want me to, I couldn't do it for you. 25 Q Did you have any difficulty at the accident scene JANUARY 2, 2008 Page 28 1 remembering your telephone number or home address for the 2 police officer? 3 A No. 4 Q Did you slur your words to the police officer? 5 A Maybe I had, I don't know. I don't think I had, 6 but -- 7 Q Did you have any contact with Mr. or Mrs. 8 Reinford at the accident scene? 9 A No. 10 Q Have you had any contact with them since that 11 date to the present? 12 A Not to my knowledge, I have not. 13 Q You were charged with driving under the 14 influence? 15 A Yes, sir. 16 Q You pled guilty to that? 17 A Yes, sir. 18 MR. COOK: Well, I will object to the form. I 19 don't think that actually accurately reflects what 20 occurred. There was an A.R.D. placement, which would not 21 be the functional equivalent of a guilty plea. 22 BY MR. SADLOCK: 23 Q Just so we're clear. You didn't contest the 24 charge, is that correct? 25 A No. Page 29 1 Q For example, didn't proceed to trial? 2 A No. 3 Q And your license was suspended, is that correct? 4 A Yes. 5 Q For a period of I believe it was sixty days? 6 A Yes. 7 Q Did you get your license back? 8 A Yes. 9 Q As part of the A.R.D. program you also had to 10 attend DUI school and counseling, is that correct? 11 A Yes, yes. 12 Q Where did you attend that? 13 A Oh, where was it? A church in Mechanicsburg. I 14 can't remember the name of it. 15 Q For how long did that program last? 16 A Six weeks I believe. 17 Q Other than that program, have you ever been 18 yourself referred or by anyone else referred to attend an 19 alcohol-type program? 20 A No, sir. 21 Q Or attend Alcoholics Anonymous or anything of 22 that nature? 23 A No, sir. 24 Q Are you aware of anything that Mr. Reinford 25 himself did in the operation of his vehicle that caused or Page 26 -Page 29 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 VALERIE CLIBER Multi-Page TM JANUARY 2, 2008 Page 30 1 contributed to this accident? 2 A I have no idea. 3 MR. SADLOCK: Thank you, ma'am. I have no other 4 questions. 5 MR. COOK: I don't have any other questions. 1 6 (Whereupon, the deposition was concluded at 7 10:00 a.m.) 8 9 13 14 15 16 17 18 19 20 21 22 23 24 25 1 COUNTY OF DAUPHIN 2 : SS Page 31 3 COMMONWEALTH OF PENNSYLVANIA : 4 I, Maria N. O'Donnell, a Notary Public, authorized to 5 administer oaths within and for the Commonwealth of 6 Pennsylvania, do hereby certify that the foregoing is the 7 testimony of VALERIE CLIBER. 8 I further certify that before the taking of said 9 deposition, the witness was duly sworn; that the questions 10 and answers were taken down stenographically by the said 11 Reporter-Notary Public, and afterwards reduced to 12 typewriting under the direction of the said Reporter. 13 I further certify the said deposition was taken at 14 the time and place specified in the caption sheet hereof. 15 I further certify that I am not a relative or 16 employee or attorney or counsel to any of the parties, or a 17 relative or employee of such attorney or counsel, or 18 financially interested directly or indirectly in this 19 action. 20 I further certify the said deposition constitutes 21 a true record of the testimony given by the said witness. 22 IN WITNESS WHEREOF, I have hereunto set my hand 23 this 2ND day of JANUARY, 2008. 24 Mana N. O'D-11, RPR 25 Notary Public Page 30 - Page 31 HUGHES ALBRIGHT FOLTZ NATALE 717-540-0220/717-393-5101 )EX?il 13??C F ¦ t t 0 .l x 4 r i i f .?+yh i 100 0 C F y T r A- C I VA , ' .' 'w ea 7 R?'? f 7 ??? ?'?' F ? u ?d ? ? ?.. # _ ' ,w ? rr y ?` ." ?.;-`.. ?. .r,;a ? i k Rl :' ry S4R S - ?. ?' ,x u??n F .. #.. J ., i` .. ? P,, is N 'Y ?? ???: Rg•.+ C' k ?. i 1°,. ?? i. ?4 A FGY r ?Y? I i ?f lpY ?s a• 1 4 f + r. a , y ? f m "r ?R r 3 1 ra..w; y ?x yy i f f n E t I 1 "If I { 4 1 ' t. r i" -. # 4 r ? f ? • ' r j r t 4 ? XI 1 J' ' f 7 ? ,.gyp ?, a' r 'f?(,.JVV A N? Y ' ? t t J R ? Zn r ? ?. ,. ra r `w t 1w CERTIFICATE OF SERVICE I, Marcy L. Brymesser, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFFS' RESPONSE TO DEFENDANT'S MOTION FOR PARTIAL SUMMARY JUDGMENT on the following via postage prepaid, first class United States mail, addressed as follows: David E. Cook, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402-3737 ZA `44A Mar L. Brymesser Date: January 15, 2008 ??,a c:. c::a '+? .. ?'ZT ?_ ,? ?yi2 C? 1 '° _ ? ?; '? 1. ? ? ,,. ° rf$ .. {? r i <`t L? ?? CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 3KINAL IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/09/2008 t `/? on be a of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R1.51 133-H DE11 14524 -L11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CASE NO: 07-3609 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations ] TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/20/2007 CC: MICHAEL SCHEIB, ESQ. - Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 133-H DE02-0382589 14524 -COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE HARRISBURG HOSPITAL WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTIAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING & BILLING & BILLING & BILLING & BILLING & BILLING R1.49S 133-H DE02-0382589 14524-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 VS. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MUTUAL BENEFIT INSURANCE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: _ **** SEE ATTACHED RIDER **** at The MCS row. m., 1601 Market Street. Suite 800, Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESQ. ADDRESS: 110 S. NORTHERN WAY XORK. PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 012008 Date: 0 ' / U 7, Seal of the Court BY THE URT: Proth otary/Clerk, sion Deputy 14524-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MUTUAL BENEFIT INSURANCE 409 PENN STREET PO BOX 577 HUNTINGDON, PA 16652 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. POLICY #M0239328 Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 10-01-2000 to 10-01-2005. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 Date of Loss: 10/22/2005 R1.49S 133-H SU10-0715730 14524-Lll CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 M r., INA IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/09/2008 / on beha1 of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R1.51 133-H DE11 14524-L12 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CASE NO: 07-3609 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/20/2007 CC: MICHAEL SCHEIB, ESQ. Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 133-H DE02-0382589 14524-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * * * at _ The MCS Croup Inc.. 1601 Market Street, Suite 800. Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESQ. ADDRESS: 110 S. NORTHERN WAY YOH& PA 17402 TELEPHONE: f215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 0 8 2008 Date: ?p?-Gt ?'? , aQ07 Seal of the Court BY THE URT Prot notary/Cler lion Deputy 14524-12 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL PINNACLE HEALTH SYSTEM 111 SOUTH FRONT ST. HARRISBURG. PA 17101 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 10-01-2000 to 10-01-2005. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.49S 133-H SU10-0715732 14524-L12 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 iNAL IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/09/2008 i MICHAEL SCHEIB, ESQ. ?_ Attorney for DEFENDANT R1.51 133-H Dsll 14524-L13 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF : RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CASE NO: 07-3609 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ) TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/20/2007 CC: MICHAEL SCHEIB, ESQ. - Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 133-H DE02-0382589 14524-COl >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE HARRISBURG HOSPITAL WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTIAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING & BILLING & BILLING & BILLING & BILLING & BILLING R1.49S 133-H DE02-0382589 14524-COI COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for WILLIAM B. BUSH. M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Grout. Inc.. 1601 Market Street. Suite 800, Philadeln ia• PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESQ. ADDRESS: 110 S. NORTHERN WAY YOB, PA 17402 TELEPHONE: 215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: -Defendant BY THE C T: Prothon /Clerl ivi on iD JAN 0 2008 Deputy Date: 7 Seal of the Court 14524-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WILLIAM B. BUSH, M.D. 5100 LANCASTER STREET HARRISBURG, PA 17111 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from: 10-01-2000 to 10-01-2005. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.49S 133-H SUIO-0715734 14524-L13 173101NAL ! CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-3609 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/09/2008 owl' of 5/L ) r MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R1.51 133-H DE11 14524-L14 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CASE NO: 07-3609 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/20/2007 CC: MICHAEL SCHEIB, ESQ. - Any questions regarding this matter, contact R1.49S 133-H MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02 -0382589 14524-Col >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE HARRISBURG HOSPITAL "WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTIAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING R1.49S 133-H DE02-0382589 14524-COI COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 VS. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for H RTM N REHAB, ASSOCIATES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS GMU. Inc.. 1601 Market Street. Suite 500. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESQ. ADDRESS: 110 S. NORTHERN WAY YORK. PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE CO T: Prothon tart'/Cler D' sion JAN 0 8 2008 Date: /':?, '1&0 7 Deputy Seal of the Court 14524-14 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARTMAN REHAB. ASSOCIATES 4TH & WILLOW STREET 3RD FLOOR LEBANON, PA 17046 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from: 10-01-2000 to 10-01-2005. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.49S 133-H SO10-0715736 14524-L14 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/09/2008 S on? beh f f MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R1.51 133-H DE11 14524 -L15 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CASE NO: 07-3609 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/20/2007 CC: MICHAEL SCHEIB, ESQ. Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 133-H D902-0382589 14524 -CO1 >>> LOCATION LIST a« PAGE: 1 LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE HARRISBURG HOSPITAL WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTIAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING R1.49S 133-H DE02-0382589 14524-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DRAYER PHYSICAL THERAPY INSTPT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc., 1601 Market Street. Suite 800, Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESQ. ADDRESS: 110 S. NORTHERN WAY YORK, PA 17402 TELEPHONE. (215) 246-0900 SUPREME COURT 1D #: ATTORNEY FOR: Defendant JAN 0 9 208 Date: ba&Z /!/ ,V647 Seal of the Court BY THE ?C?RT: Prothon tary/Clerk, 0ion Deputy 14524-15 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DRAYER PHYSICAL THERAPY INSTIT 8205 PRESIDENTS DRIVE FIRST FLOOR HUMMELSTOWN, PA 17036 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from: 10-01-2000 to 10-01-2005. Subject : RONNIE REINFORD 227 WALTON STREET, LMWYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.49S 133-H SUIO-0715738 14524-L15 CERTIFICATE a7'rINAL PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-3609 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/09/2008 on beha f f w MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R1.51 133-H DE11 14524-L16 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CASE NO: 07-3609 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/20/2007 CC: MICHAEL SCHEIB, ESQ. Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 133-H DE02-0382589 14524-CO1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE HARRISBURG HOSPITAL WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTIAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS & BILLING MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING R1.49S 133-H DE02-0382589 14524-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for TRTST AN A S AT S (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at _ The MCS Group. Inc.. 1601 Market Street. Suite 800, Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESQ. ADDRESS: I 10 S. NORTHERN WAY _YORK. PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE CO T: Prothon Lary/Clerk 1 . ion 9 2008 Deputy Date: Lzz= /// a O 4 7 Seal of the Court 14524-16 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: TRISTIAN ASSOCIATES 4349 CARLISLE PIKE CAMP HILL, PA 17011 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from: 10-01-2000 to 10-01-2005. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.49S 133-H SU10-0715740 14524-L16 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 • ?,7iriNA? IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/09/2008 / Zcp on behit lf f " i MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R1.51 133-H DEll 14524-L17 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF : RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CASE NO: 07-3609 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/20/2007 CC: MICHAEL SCHEIB, ESQ. - Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 133-H DE02-0382589 14524-CO1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE HARRISBURG HOSPITAL WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTIAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING & BILLING & BILLING & BILLING & BILLING & BILLING R1.49S 133-H DE02-0382589 14524-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 VS. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HFALTHSOUTH REHAB (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MC ro ro In 1601 Market Street Suite 800, Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESO ADDRESS: 110 S. NORTHERN WAY YORK, PA 17402 TELEPHONE: _215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 0 9 2008 Date: 0 2,CtiJc.(r? /?/ a2O0 7 Seal of the Court BY THE CO T: Prothon /Clerl 4ion Deputy 14524-17 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH REHAB 175 LANCASTER BLVD P.O. BOX 2016 MECHANICSBURG, PA 17055 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from: 10-01-2000 to 10-01-2005. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.49S 133-H SU10-0715742 14524-L17 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 AW ,7?riNAi. IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/09/2008 S (5n be :1?- MICHAEL SCHEIB ESQ. Attorney for DEFENDANT R1.51 133-H DE11 14524-L18 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CASE NO: 07-3609 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations J TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/20/2007 CC: MICHAEL SCHEIB, ESQ. - Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 133-H DE02-0382589 14524-COl >>> LOCATION LIST « < - PAGE: 1 LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE HARRISBURG HOSPITAL WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTIAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING & BILLING & BILLING & BILLING & BILLING & BILLING R1.49S 133-H DE02-0382589 14524-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 VS. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * * * at The MCS Groi Inc., 1601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESQ. ADDRESS: 110 S. NORTHERN WAY YORK. PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JAN 0 9`2/008 Date: D 7 '?z dd Seal of the Court BY THE CO T: Prothon tary/Clerk, 1 ' on Deputy 14524-18 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL MEDICAL RECORDS 111 S. FRONT STREET HARRISBURG, PA 17101 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: from: 10-01-2000 to 10-01-2005. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 209-62-0329 Date of Birth: 06-23-1964 R1.49S 133-H SU10-0715744 14524-L18 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 7K. INA IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/09/2008 C on beh f f ` MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R1.51 133-H DEll 14524-L19 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 VS. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RiT)ER **** at The MCS Group, Inc 1601 Market Street. Suite 800. Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESQ. ADDRESS: 110 S. NORTHERN WAY YORK. PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE CO T: Prothono /Clerk, Ci *'vis- 9 Date: jO4 7 Deputy Seal of the Court 14524-19 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL BILLING RECORDS Ill S. FRONT STREET HARRISBURG, PA 17101 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all billing, insurance claims, payments, outstanding and/or delinquent invoices, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: from: 10-01-2000 to 10-01-2005. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 209-62-0329 Date of Birth: 06-23-1964 R1.49S 133-H SU10-0715746 14524-L19 H 460. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 C,7/ r-1 iNA? IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 01/09/2008 S on behal o MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R1.51 133-H DE11 14524-L20 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CASE NO: 07-3609 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009,21 i Note: see enclosed list of locations ) TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 12/20/2007 CC: MICHAEL SCHEIB, ESQ. - Any questions regarding this matter, contact MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.49S 133-H DE02-0382589 14524-COI >>> LOCATION LIST c<¢ PAGE: 1 LOCATION NAME RECORDS REQUESTED MUTUAL BENEFIT INSURANCE HARRISBURG HOSPITAL WILLIAM B. BUSH, M.D. HARTMAN REHAB. ASSOCIATES DRAYER PHYSICAL THERAPY INSTIT TRISTIAN ASSOCIATES HEALTHSOUTH REHAB HARRISBURG HOSPITAL HARRISBURG HOSPITAL ORTHOPAEDIC INSTITUTE OF PA INSURANCE EMPLOYMENT MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS BILLING ONLY MEDICAL RECORDS & BILLING & BILLING & BILLING & BILLING & BILLING & BILLING R1.49S 133-H DE02-0382589 14524-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHOPAEDIC INSTITUTE OF PA (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTA HED RIDER **** at The M Group, Inc 1601 Market Street, Site 800, Philad lphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESO ADDRESS: _110 S. NORTHERN WAY -YORK. PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE CO JAN 0 9 2008 Prothono /Clerk, Date: ?cP.CQ?Is-CrC?t / y 02667 Deputy Seal of the Court 14524-20 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPAEDIC INSTITUTE OF PA 3399 TRINDLE ROAD CAMP HILL. PA 17011 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire medical and billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis or treatment pertaining to: Dates Requested: from: 10-01-2000 to 10-01-2005. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.49S 133-H SU10-0715748 14524-L20 ?-, -?,.? :'?a > ?? .. --., _ s? .._n r.? ANGINO & ROVNER, P.C. Richard A. Sadlock Esquire Attorney JD# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 Phone: (717) 238-6791 Fax: (717) 238-5610 Attorneys for Plaintiffs: E-mail: rsad lock t aangino-rovner.corn Rhonda and R Timothy Reinford RHONDA L. REINFORD and R. TIMOTHY REINFORD, her husband, Plaintiffs V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3609 Civil Term VALERIE LAIR, Defendant JURY TRIAL DEMANDED PLAINTIFFS' MOTION FOR A STATUS CONFERENCE AND NOW, come Plaintiffs Rhonda L. Reinford and R. Timothy Reinford, by and through their counsel, Angino & Rovner, P.C., to respectfully request Your Honorable Court to schedule a Status Conference in the above-captioned action for the following reasons: This action is a result of motor vehicle accident that occurred on October 22, 2005. 2. The Complaint was filed on June 18, 2007 and served on the Defendant by the Sheriff on June 20. 2007. 3. On July 16, 2007, Plaintiffs forwarded Interrogatories and Request for Production of Documents to Defendant. 4. As of the filing of the instant Motion, Defendant has not yet responded to Plaintiffs' Request for Production of Documents. 5. Plaintiffs and Defendant have been deposed. 6. Counsel for Plaintiff and Defendant believe it is in all parties' interests to have the Court set deadlines for the completion of all discovery and also set a date or term for trial. 7. Plaintiffs are represented by Richard A. Sadlock, Esquire of Angino & Rovner, P.C., 4503 North Front Street, Harrisburg, PA 17110,(717)238-6791. 8. Defendant is represented by Michael B. Scheib, Esquire, Griffith, Strickler, Lerman, Solymos & Calkins, 110 South Northern Way, York, PA 17402-3737, (717) 757-7602. WHEREFORE, Plaintiffs respectfully request Your Honorable Court to schedule a Status Conference for the purposes of establishing discovery deadlines and a trial date. Respectfully submitted, ANGINO & $,pW"fiUW:C. loch . Sadlo , squire I. o. 47 R50#.. bI wont Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiffs Date: February 12, 2008 376525 CERTIFICATE OF SERVICE I, Marcy L. Brymesser, an employee of Angino & Rovner, P.C., hereby certify that a true and correct copy of the foregoing PLAINTIFF'S MOTION FOR A STATUS CONFERENCE was served via United States first-class mail, postage prepaid, upon the following: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402-3737 Marcy L. Brymesse ?0 Date: February 12, 2008 r 4_ - r c : f o :.: ` .+ __ :x0 ANGINO & ROVNER, P.C. Richard A. Sadlock Esquire Attorney ID# : 47281 4503 North Front Street Harrisburg, PA 171 10-1708 Phone: (717) 238-6791 Fax: (717) 238-5610 Attorneys for Plaintiffs: E-mail: rsadlock(&,,angino-rovner.com Rhonda and R. Timothy Reinford RHONDA L. REINFORD and R. TIMOTHY REINFORD, her husband, Plaintiffs V. VALERIE LAIR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3609 Civil Term JURY TRIAL DEMANDED PLAINTIFFS' SUPPLEMENTAL MOTION FOR A STATUS CONFERENCE AND NOW, come Plaintiffs Rhonda L. Reinford and R. Timothy Reinford, by and through their attorneys, Angino & Rovner, P.C., and submit the following additional paragraphs to Plaintiffs' Motion for a Status Conference: 9. On October 25, 2007, a discovery motion was argued in front of Judge Kevin A. Hess. 10. On February 19, 2008, February 20, 2008, and February 21, 2008, Plaintiffs' counsel had contact with Defendant's counsel, and it is Plaintiffs' understanding that Defendant's counsel does not concur with the filing of this Motion for a Status Conference. WHEREFORE, Plaintiffs respectfully request Your Honorable Court to schedule a Status Conference for the purposes of establishing discovery deadlines and a trial date. Respectfully submitted, ANGINO & R Offd A. Sadl . No. 472840 46Q&# !F"ront Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiffs Date: February 21, 2008 376525 CERTIFICATE OF SERVICE I, Marcy L. Brymesser, an employee of Angino & Rovner, P.C., hereby certify that a true and correct copy of the foregoing PLAINTIFF'S SUPPLEMENTAL MOTION FOR A STATUS CONFERENCE was served via United States first-class mail, postage prepaid, upon the following: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402-3737 ar y . Brymesser Date: February 21, 2008 r ri ?. r • PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matter for the next Argument Court.) CAPTION OF CASE (entire caption must be stated in full) Rhonda L. Reinford and R. Timothy Reinford, Plaintiffs vs. Valerie Lair, Defendant No. 07-3609 , - Term 1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): Motion for Partial Summary Judgment of Defendant, Valerie Lair 2. Identify all counsel who will argue cases: (a) for plaintiffs: Richard A. Sadlock, Esq., 4503 N. Front St., Harrisburg, PA 17110 (Name and Address) (b) for defendants: Michael B. b..:ieib, Esq., David E. Cook, Esq., (Name and Address) 110 S. Northern Way, York, PA 17402 3. 1 will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: Print your name Date: Feb. 26, 2008 Attorneyfor Defendant, Valerie Lair INSTRUCTIONS: 1. Two copies of all briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) before argument. 2. The moving party shall file and serve their brief 12 days prior to argument. 3. The responding party shall file their brief 5 days prior to argument. 4. If argument is continued new briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) after the case is rellsted. Please note that this matter has been assigned to the Honorable Kevin A. Hess. David E. Cook, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and R. TIMOTHY REINFORD, Plaintiffs V. VALERIE LAIR, Defendant NO. 07-3609 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 26 h day of February, 2008, I, David E. Cook, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the foregoing Praecipe to List for Argument, by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: DAVID E. COOK, ESQUIRE Supreme Court I.D. No. 78318 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Valerie Lair _ .-wry Y ?1 r FEB 14 2008 A'g ANCINO & ROVNER, P.C. Richard A. Sadlock Esquire Attorney 1D# : 47281 4503 North Front Street Harrisburg, PA 17110-1708 Phone: (717) 238-6791 Fax: (717) 238-5610 Attorneys for Plaintiffs: E-mail: rsadlock(ci)angino-rovner.com Rhonda and R. Timothy Reinford RHONDA L. REINFORD and R. TIMOTHY REINFORD, her husband, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. VALERIE LAIR, Defendant NO. 07-3609 Civil Term JURY TRIAL DEMANDED ORDER AND NOW, this day of .mod, 2008, upon consideration of el- Plaintiffs Motion for Status Conference, IT IS HEREBY ORDERED a Status Conference is scheduled for / AOV k at 3.'00 o'clock in Courtroom No. BY THE COURT: J. Dist ' ution: • Richard A. Sadlock, Esquire, Angino & Rovner, P.C., 4503 North Front Street, Harrisburg, PI 17110, (717) 238-6791, fax (717) 238-5610; rsadlock@angino-rovner.com • ichael B. Scheib, Esquire, Griffith, Strickler, Lerman, Solymos & Calkins, 110 South Northern Way, York. PA 17402-3737; (717) 757-7602; fax (717) 757-3783; Mscheib@gslsc.com 3 762? ... ' ,.... .... 5 1. yr ??.r ?'? : ? ??? ?? ?? ???Z ?? ? :; ?:. ws ,?w ? ;;; ? ?., ?}w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and NO. 07-3609 CIVIL TERM R. TIMOTHY REINFORD, Plaintiffs V. CIVIL ACTION - LAW VALERIE LAIR, Defendant JURY TRIAL DEMANDED PRAECIPE TO WITHDRAW MATTER FROM ARGUMENT COURT Please withdraw the above-captioned case from the April 16, 2008 Argument Court list. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: DAVID E. COOK, ESQUIRE Supreme Court I.D. No. 78318 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Valerie Lair IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and NO. 07-3609 CIVIL TERM R. TIMOTHY REINFORD, Plaintiffs V. CIVIL ACTION - LAW VALERIE LAIR, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 31" day of March, 2008, I, David E. Cook, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the foregoing Praecipe to Withdraw Matter from Argument Court, by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By. DAVID E. COOK, ESQUIRE Supreme Court I.D. No. 78318 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Valerie Lair a K M CD E`a? _. z •? ,? PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matter for the next Argument Court.) ------------------------------------------------ CAPTION OF CASE (entire caption must be stated in full) Rhonda L. Reinford and R. Timothy Reinford, Plaintiffs vs. Valerie Lair, No. 07-3609 Term 1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): Motion for Partial Summary Judgment of Defendant, Valerie Lair 2. Identify all counsel who will argue cases: (a) for plaintiffs: Richard A. Sadlock, Esq., 4503 N. Front St., Harrisburg, PA 17110 (Name and Address) (b) for defendants: Michael B. Scheib, Esq., David E. Cook, Esq., (Name and Address) 110 S. Northern Way, York, PA 17402 3. 1 will notify all parties in writing within two days that this case has been listed for argument. 4. Date: March 31, 2008 Print your name Attorneyfor Defendant, Valerie Lair INSTRUCTIONS: 1. Two copies of all briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) before argument. 2. The moving party shall file and serve their brief 12 days prior to argument. 3. The responding party shall file their brief 5 days prior to argument. 4. If argument is continued new briefs must be flied with the COURT ADMINISTRATOR (not the Prothonotary) after the case Is relisted. Defendant Please note that this matter has been assigned to the Honorable Kevin A. Hess. David E. Cook, Esquire r , i 1- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and NO. 07-3609 CIVIL TERM R. TIMOTHY REINFORD, Plaintiffs V. CIVIL ACTION - LAW VALERIE LAIR, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 31St day of March, 2008, I, David E. Cook, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the foregoing Praecipe for Listing Case for Argument, by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: DAVID E. COOK, ESQUIRE Supreme Court I.D. No. 78318 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Valerie Lair ?,., . -o ? ? ? .r ?. ?` . a? ??' ? '? RHONDA L. REINFORD and R. TIMOTHY REINFORD, Plaintiff V VALERIE LAIR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3609 CIVIL TERM JURY TRIAL DEMANDED IN RE: CASE MANAGEMENT CONFERENCE ORDER OF COURT AND NOW, this 17th day of April, 2008, following conference with counsel, the following case management order is entered: 1. All discovery shall be concluded in this case within thirty days after the Court's resolution of the pending motion for partial summary judgment. 2. Counsel for the defendant will advise counsel for the plaintiff within thirty days of today as to whether he will seek an independent medical examination. If an independent medical examination is conducted, the expert's report will be furnished to counsel for the plaintiff within thirty days of the examination, and, in any event, no later than August 1, 2008. 3. Counsel are authorized to list this case for the September 2008 trial term. ? Richard A. Sadlock, Esquire For the Plaintiff David E. Cook, Esquire For the Defendant :bg By the Court, vim A. Hess, J. ?s?? ' 1 o r PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (X) for JURY trial at the next term of civil court () for trial without a jury CAPTION OF CASE (entire caption must be stated in full) RHONNIE L. REINFORD and R. TIMOTHY REINFORD, her husband Plaintiffs VS. VALERIE LAIR, (check one) (X) Civil Action - Law () Appeal from arbitration (other) The trial list will be called August 19, 2008. Trials commence on September 15, 2008. Defendant Pretrials will be held on August 27, 2008 (Briefs are due S days before pretrials) No. 07-3609 Civil Term Indicate the attorney who will try case for the party who files this praecipe: Richard A. Sadlock, Esquire, Angino & Rovner, P.C., 4503 North Front Street, Harrisburg, PA 17110 Indicate trial counsel for other parties if known: Michael B. Scheib, Esquire/David E. Cook, Esquire Griffith, Strickler, Lerman, Solymos & Calkins, 110 South Northern Way, York, PA 17402-3737 00000- This case is ready for trial. Signed: - 5?5 1 - Print Name: i . adlock. Esquire Date: May 9, 2008 Attorney for Plaintiffs 382565 CERTIFICATE OF SERVICE I, Kathy A. Toney, an employee of the law firm of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFFS' PRAECIPE LISTING CASE FOR TRIAL on the following via postage prepaid, first class United States mail, addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402-3737 Kathy A. ney Date: May /, 2008 353005 (? t7 cNa -rt M ?rn RHONDA L. REINFORD AND IN THE COURT OF COMMON PLEAS OF R. TIMOTHY REINFORD, CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS V. VALERIE LAIR, DEFENDANT 07-3609 CIVIL TERM ORDER OF COURT AND NOW, this day of August, 2008, following a pretrial conference and on the motion of plaintiffs for a continuance, opposed by defendant, the motion IS GRANTED. The case is removed from the September trial term. The case shall be relisted by counsel when at issue. chard A. Sadlock, Esquire For Plaintiffs X chael B. Scheib, Esquire For Defendant Court Administrator :sal J iii; t.r A ` c ? rl 8S : WY LZ OAV ROOZ :i? JO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and NO. 07-3609 CIVIL TERM R. TIMOTHY REINFORD, Plaintiffs V. CIVIL ACTION - LAW VALERIE LAIR, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this day of 2008, I, Michael B. Scheib, Esquire, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the Defendant's Answer to Plaintiffs' Interrogatories Directed to Valerie Lair Set II, by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By:-i4-Ai?-, I MICHAEL B. SCHEIB, ESQUIRET Supreme Court I.D. No. 63868 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Valerie Lair ?. 7 ao L ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and R. TIMOTHY REINFORD, Plaintiffs V. VALERIE LAIR, Defendant NO. 07-3609 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this ---a-- day of , 2008, I, Michael B. Scheib Esquire a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the response of Defendant Valerie Lair to Plaintiffs' Request for Production of Documents - Set II, by United States Mail, postage prepaid, addressed to the party or attorney of record as follows: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS r By: MICHAEL B. SCHEIB, ESQUIRE Supreme Court I.D. No. 63868 110 South Northern Way York, PA 17402-3737 (717) 757-7602 Attorney for Defendant, Valerie Lair tit CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 10/22/2008 MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R1.90 144-H DE11-0789964 14524-L22 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- COURT OF COMMON PLEAS TERM, CASE NO: 07-3609 VALERIE LAIR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 MASONIC LODGE NURSING HOME EMPLOYMENT TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/30/2008 MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT CC: MICHAEL SCHEIB, ESQ. - Any questions regarding this matter, contact RICHARD A. SADLOCK, ESQ. 4503 NORTH FRONT STREET HARRISBURG, PA 17110 THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.71S 144-H DE02-0413148 14524-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MASONIC OD NURSING HOME (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things:_ **** SEE ATTACHE MER **** at The MCS Gr im Inc.. 1,601 Market Street Suite 8002hilad phia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB ESO ADDRESS: 110 S. NORTHERN-WAY FORK. PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: _ Defendant OCt 92 20 Date: Seal of the Court B THE rothono , ivil Division Deputy 14524-22 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MASONIC LODGE NURSING HOME ONE MASONIC DRIVE ELIZABETHTOWNE, PA 17022 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 01-01-1990 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.71S 144-H SU10-0753852 14524-L22 T,. 1 ? } r°;? y ..+^.$ ? ?` ? ?? 4 j .S?? y ? i ??} ?? ??; ?? ??s v WM? - ~?? CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/05/2009 MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R2.07 133-H DE11-0860549 14524-L23 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, -VS- CASE NO: 07-3609 VALERIE LAIR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL SCHEIB, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/11/2009 MCS on behalf of MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT CC: MICHAEL SCHEIB, ESQ. - RICHARD A. SADLOCK, ESQ. ANGINO & ROVNER 4503 NORTH FRONT STREET HARRISBURG, PA 17110 THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R2.07 120-H DE02-0471632 14524-CO1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HARRISBURG HOSPITAL HARRISBURG HOSPITAL HARRISBURG HOSPITAL MEDICAL HOSPITAL BILLING RADIOLOGY R2.07 120-H D802-0471631 14524-C00 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 VS. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBt?G JJOySpTTAL. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER**** at The MCC Q Inc- , 1601 Market Street, Suite 800, Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB, ESQ. ADDRESS: 110 S. NORTHERN WAY YORK PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Divisk /MR05M ? ?f 0 k I D puty Date: Seal of the Court 14524-23 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL MEDICAL RECORDS 111 S. FRONT STREET HARRISBURG, PA 17101 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. ALL MEDICAL RECORDS FROM 9/1/07 TO PRESENT Dates Requested: from: 09-01-2007 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 209-62-0329 Date of Birth: 06-23-1964 R1.81S 133-H SU10-0772192 14524-L23 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- VALERIE LAIR COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 07-3609 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/05/2009 MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT R2.07 133-H DE11-0860552 14524-L24 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Group ,-1601 Market Street-, Suite 800 Pbiladdphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB ESQ ADDRESS: 110 c NORTHERN WAY YORK PA 17402 TELEPHONE: (215).746-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 0 552009 Date: &4161 Se al of the Court BY THE COURT: gI &1141? P, Prothonotary/Clerk, Civil Divisi I IA-VF Dep ty 14524-24 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL BILLING RECORDS P. 0. BOX 2353 HARRISBURG, PA 17105 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. ALL BILLING RECORDS FROM 911107 TO PRESENT Dates Requested: from: 09-01-2007 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 209-62-0329 Date of Birth: 06-23-1964 R1.81S 133-H SU10-0772194 14524-L24 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/05/2009 MICHAEL SCHEIB, ESQ. Attorney for DEFENDANT 82.07 133-H DEll-0860555 14S24-L25 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 VS. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED MER **** at _ The MCS Gr=, Inc., 1601 Market Stree , Suite 800, P it rl lhi , PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL SCHEIB. ESQ. ADDRESS: 110 S. NORTHERN WAY YORK. PA 17402 TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Q5r0 Date: ? I Lo /a ?' Seal of the Court BY THE COURT: IJ C? yip C, lei Prothonotary/Clerk, Civil Divi 4 o ,11 D uty 14524-25 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL RADIOLOGY DEPT. 111 S. FRONT STREET HARRISBURG, PA 17101 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. ALL X-RAYS FROM 9/1/07 TO PRESENT Dates Requested: from: 09-01-2007 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: XXX-XX-0329 Date of Birth: 06-23-1964 R1.81S 133-H SU10-0772196 14524-L25 C'? g ?iti ? a „ , f , i ? ? ? '? J :`? ;'7'?r ? ? ? r • PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) (X) for JURY trial at the next term of civil court () for trial without a jury CAPTION OF CASE (entire caption must be stated in full) RHONDA L. REINFORD and R. TIMOTHY REINFORD, her husband Plaintiffs V. VALERIE LAIR, Defendant (check one) () Assumpsit () Trespass () Trespass (Motor Vehicle) (X) Other - Law The trial list will be called on June 2, 2009. Trials commence on June 29, 2009. Pre-trials will beheld on June 10, 2009 (Briefs are due 5 days before pre-trials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 314-1.) No. 07-3609 Civil Term Indicate the attorney who will try case for the party who files this praecipe: Richard A. Sadlock, Esquire Indicate trial counsel for other parties if known: David E. Cook, Esquire This case is ready for trial. I-JU Date: April 2009 Signed: Print Name: RICHARD A. SADLOCK Attorney for Plaintiffs 409683 CERTIFICATE OF SERVICE I, Kathy A. Toney, an employee of the law firm. of Angino & Rovner, P.C., do hereby certify that I am this day serving a true and correct copy of PLAINTIFFS' PRAECIPE LISTING CASE FOR TRIAL on the following via postage prepaid, first class United States mail, addressed as follows: David E. Cook, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402-3737 Kathy A. oney Date: April j 2009 353005 CA j,-il ITAOY 2 O9 M 'Vii is s GL ck:4, ._ .. 6`s co 1?a el* jo SDI CERTIFICATE ' PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DAVID COOK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/02/2009 MCS on behalf of /S/ 2avid l,ooh, elq. DAVID COOK, ESQ. Attorney for DEFENDANT R2.18 120-H DE11-0921859 14524-L26 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: RHONDA REINFORD AND R. TIMOTHY REINFORD -VS- COURT OF COMMON PLEAS TERM, CASE NO: 07-3609 VALERIE LAIR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL MEDICAL RECORDS HOLY SPIRIT HOSPITAL BILLING ONLY HOLY SPIRIT HOSPITAL X-RAY ONLY TO: RICHARD A. SADLOCK, ESQ., PLAINTIFF COUNSEL MCS on behalf of DAVID COOK, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 05/13/2009 MCS on behalf of DAVID COOK, ESQ. Attorney for DEFENDANT CC: DAVID COOK, ESQ. RICHARD A. SADLOCK, ESQ. ANGINO & ROWER 4503 NORTH FRONT STREET HARRISBURG, PA 17110 THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R2.18 116-H D802-0512922 14524-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MC4 Groin, Inc-, 1601 Market Street, Suite 800, PHadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DAVID COOK. ESQ. ADDRESS: 110 S. NORTHERN WAY YORK, PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUN 02 W Date:_ - ( 1!2 a !F r Seal of the Court ;BY THE COURT: thonotary/Clerk, Civil i n Deputy 14524-26 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL MEDICAL RECORDS 503 N. 21ST STREET CAMP HILL. PA 17011 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription; records, nurses notes, doctors comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: from: 09-01-2007 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 209-62-0329 Date of Birth: 06-23-1964 R2.18 116-H SU10-0785994 14524-L26 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DAVID COOK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/02/2009 MCS on behalf of /S/ 2avid C,oo42 ell. DAVID COOK, ESQ. Attorney for DEFENDANT R2.18 120-H DE11-0921861 14524-L27 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 VS. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group, Inc., 1601 Market Street, Suite 800, Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DAVID COOK. ESQ. ADDRESS: _ 110 S. NORTHERN WAY YYO L PA 17402 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: JUN 02 20 - Date: N-!*,, Seal of the Court a-) Di .4A_`7t?`J Civil Divisio 14524-27 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL BILLING DEPT. 503 N. 21ST STREET CAMPHILL. PA 17011 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all billing, insurance claims, payments, outstanding and/or delinquent invoices, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: from: 09-01-2007 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 209-62-0329 Date of Birth: 06-23-1964 82.18 116-H SU10-0785996 14524-L27 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS RHONDA REINFORD AND R. TIMOTHY REINFORD TERM, CUMBERLAND -VS- CASE NO: 07-3609 VALERIE LAIR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DAVID COOK, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 06/02/2009 MCS on behalf of /S/ 2avid (fooh, el DAVID COOK, ESQ. Attorney for DEFENDANT R2.18 120-H DE11-0921865 14524-L28 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RHONDA REINFORD AND R. TIMOTHY REINFORD File No. 07-3609 vs. VALERIE LAIR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HOLY SPIRIT HOSPITAL. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDFR **** at The MCS Gr=- Inc- 1601 Market Street, Suite 800, Philadelphia , PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: DAVID COOK. ESQ. ADDRESS: 110 S. NORTHERN WAY YORK PA 17402 TELEPHONE: (21_5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUN 0 2 2009 Date: 9!21 ( 15 24=4 Seal of the Court BY THE OURT: rothonotary/Clerk, Civil i Deputy 14524-28 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL RADIOLOGY DEPT. 503 N. 21ST STREET CAMP HILL. PA 17011 RE: 14524 RONNIE REINFORD Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 09-01-2007 to the present. Subject : RONNIE REINFORD 227 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 209-62-0329 Date of Birth: 06-23-1964 R2.18 116-H SU10-0785998 14524-L28 FtL -OFFICE OF THE MT! . 'Y 1oog JUN -8 PM T ! 9 #14 RHONDA L. REINFORD, and IN THE COURT OF COMMON PLEAS OF R. TIMOTHY REINFORD, CUMBERLAND COUNTY, PENNSYLVANIA her husband, Plaintiffs V. CIVIL ACTION - LAW VALERIE LAIR, Defendant NO. 07-3609 CIVIL TERM PRETRIAL CONFERENCE AND NOW, this 10th day of June, 2009, before Edgar B. Bayley, Judge, present for the plaintiffs was Michael E. Kosik, Esquire. Trial counsel for plaintiffs will be Richard A. Sadlock, Esquire. Appearing for defendant was David E. Cook, Esquire. Plaintiff, Rhonda L. Reinford, was injured when her vehicle was struck in the rear by a vehicle operated by defendant, Valerie Lair. Plaintiff claims that Lair was driving while under the influence of alcohol (.222). Plaintiff seeks general damages plus punitive damages. At this point liability is contested. Plaintiff maintains she suffered mostly back injuries which have been a cause of chronic pain to her. Plaintiff's husband, R. Timothy Reinford, seeks damages for loss of consortium. Each side shall have four peremptory challenges. Anticipated time of trial is two days. 0 o By the-- ?}x , o of=-Bayley, J. Richard A. Sadlock, Esquire For Plaintiffs David E. Cook, Esquire For Defendant r- c rn- -70- -i c a 5M ; cn c -n -c prs RHONDA L. REINFORD IN THE COURT OF COMMON PLEAS OF And CUMBERLAND COUNTY, PENNSYLVANIA R. TIMOTHY REINFORD, her husband, Plaintiffs CIVIL ACTION -LAW V. VALERIE LAIR, : NO. 2007 - 3609 CIVIL TERM Defendant : CIVIL JURY TRIAL VERDICT SLIP State the total amount of damages Plaintiff Rhonda L. Reinford sustained as a result of the negligence of the Defendant. $ :5?'j 91 3? DATE: JUNE , 2009 7,,RE-ERSON RHONDA L. REINFORD AND R. TIM071Y q e"-ra'?{ -- V S ---- VALERIE LAIR UR In the Court of Commons Pleas of Cumberland County, PA., Docket No. 2007-3609 Judge: GUIDO Attorney: Attorney: Date: ORS No. Juror # NAMES OF JURORS CALLED CAUSE P LDD - MERLE, TERRY M (? 2 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII JUN29-299 MCNEW, KEVIN B 3 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII JUN29-296 SMOTHERMAN, DORIS 4 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII JUN29-132 BIGLER, MARIAN A 5--4mm11111Ami N29--2259- PRIRR X4 -- -0111111111111111111111111 IN IIII 0 mul ? 9 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIillllllll JUN29-38 MARKEL, PATRICIA A 10 IIIIIIIillllllllllllllllllllllllllllilll JUN29-177 JULIANA, PATRICIA A 11 IIIlilllllllllllllllllllllllllllllllllll JUN29-49 RONAN, KENNETH A D? 13 "M 11-11 111111111141i0iftff- hTER,1DWIGHT D -------- 14 III1111111111111111111111111111111111111 JUN29-218 MORDA, JOSEPH S 15 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII JUN29-311 PARENT, SCOTT K 16 IIIIIIIIIIillllllllllllllllllllllllllill JUN29-54 RAMSEY, RANDOLPH L 17 Illillllllllllillllllllllllillllllllllll JUN29-212 SPROUT, CHERYL A 18 19 II11111111111111111111111111111111111111 JUN29-225 HARPER„ JR DONALD K 20 IIIIIIIIIIIIIIIIIIIIIIIIQIIIIIillllllll JUN29-275 DERMOTT, CASSIDY M J 22 IIIIIIIIIIIIIIIIIIIillllllllllllilllllll JUN29-115 ALLEMAN, BARBARA A RHONDA L. REINFORD AND R. TIMO In the Court of Commons Pleas of Cumberland County, PA., Docket No. 2007-3609 Judge: GUIDO VALERIE LAIR Attorney: Attorney: Date: JURORS No. --- V S ---- Juror # I NAMES OF JURORS CALLED I CAUSE I P I D S- 24 Illllllllglllllllllllllllllllilllllllll JUN29-263 5 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII JUN29-294 26 IIIIIIIIIIIIIINIIIIIIIIIIIIIIIIIIllllll JUN29-240 27 Ililllllllllilllllllllllillllllllllillll JUN29-167 28 1IIIIIIIIIIIIIIIIIIIIIIIIIIIINIIIIIIIII JUN29-298 29 1IIIIIIIIIIIIIIII111111111111?111111111 JUN29-51 3 1111111 IIIII IIIII111111111111111111IIII JUN29-153 31 IIIIIIIIIIIIIIIIIIIIIIIIIIIII?Iilllllll JUN29-269 32 IIIIIIIIIIIIIIIIIIIIIIIIIII1111111111111 JUN29-144 33 Illlllllllllllillllgllllllll?llllllill JUN29-194 34 1IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII JUN29-346 35 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII JUN29-61 36 1IIIIIIIIIIIilllllllllllllllllllllllllll JUN29-149 37 IIIIIIIIIIIIIIIIIIIIIIIIIIIillllllllllll JUN29-304 38 1IIillllllllllllllllllllllllllllllllllll JUN29-182 39 Illillllllllllllllllllllllllllllllllllll JUN29-200 40 IIIllulllllllllllllllllllllllllllllllll JUN29-318 41 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII JUN29-277 42 IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIiI JUN29-130 43 IIIIIIIIIIIIIIIillllllilllllllllllllllll JUN29-295 MOUNTZ„ JR WAYNE S DANIELSON, KATHLEEN L BOGACZYK (POLINKA), AMBER N SIMPSON, HEATHER A SPITZ, ROGER C SLUSSER, ROBERT L ANDERSON, SHAWN M LEHR, DEBORAH J BITTINGER, SAMUEL R STAHL, DONALD E BRETZ, DEBRA K HEPNER, JONATHAN R GIRARDI, PATRICK M MILLER„ JR CHARLES L SEMKIW-FUNK, DONNA M BLEYER,NANCY L ROTH, ANDREW J REITZEL, DEBORAH H HAUGH, JACALYN A FRANKLIN, KRISTA A 44 IIIIIIIIIIIIIIIIIII?IIIIIIIIIIIII?IIII 1 JUN29-84 I NEGLEY„ JR RONALD P RHONDA L. REINFORD AND R. TIMO ---- V S --- VALERIE LAIR In the Court of Commons Pleas of Cumberland County, PA., Docket No. 2007-3609 Judge: GUIDO Attorney: Attorney: Date: JUR ORS No. Juror # NAMES OF JURORS CALLED CAUSE P D 45 IIIIIIIIIIIIIIIIIIIIIIIIQIIIIIIIIIIIIII JUN29-109 STRAWN, VICTORIA L 46 IIIIIIIIIIIIIIIIIIIIIIII?IIIIIIIIIIIII JUN29-41 CSORDOS, JANEEN T 47 IIIIIIIIIIIIIIIIIIIIilllllllllllllllllll JUN29-57 PANNEBAKER, MELINDA 48 IIIIIIIII?IIIIIIIIIIIIIIIIIIIIIIIQIIII JUN29-92 LUNDQUIST, MALENE M 49 illllllliglllllllllllllllllllllllllllll JUN29-135 WILES, JOANNE W 50 Illllllllulllllllllllllllllllllllllllll JUN29-152 BROOKENS, STEVEN N 51 IIIIIIIIIIIIIIIIIIIIII111111111111111111 JUN29-19 LEVENSON, ROBERT 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHONDA L. REINFORD and R. TIMOTHY REINFORD, Plaintiffs V. NO. 07-3609 CIVIL TERM CIVIL ACTION LAW VALERIE LAIR, Defendant JURY TRIAL DEMANDED PRAECIPE TO SETTLE AND SATISFY TO: PROTHONOTARY Please mark the judgment in the above-captioned matter as settled and satisfied. Date: , 2009 `071? ve f op Supreme Court I.D. No. 47281 4503 North Front Street Harrisburg, PA 17110 (717) 238-6791 Attorneys for Plaintiffs rr _ (ft {. 'AQv jj 41: .s? 4, .