Loading...
HomeMy WebLinkAbout07-620567- 00205 C Zvi J'ert Stephen E. Farina Prothonotary OFFICE OF ,?RpTHONOTApy Curtis R Long, Prothonotary Sept 26, 2007 Cumberland County Court House Hanover & High Streets Carlisle, Pa 17013 IN RE: Craig R. Wilson & Edward S Tamin Dauphin County Dkt No 2007 CV 656 CV Cumberland County Dkt No. 07-- 6,2 0-:? Cud -i. Dear Sir/ Madam: Front & Market Streets Harrisburg, PA 17101 (717) 780-6520 By Order of September 20, 2007 by Hon Lawrence F. Clark, Judge The above matter has been transferred to the Court of Common Pleas of Cumberland County. I am, accordingly, sending originals of all the papers herewith. I Will appreciate the return of the attached receipt address to the Attention: of Ms. Lisandra Garcia. Very truly yours, #eyt- W aWha Stephen E. Farina Prothonotary County of Dauphin Date: 9/26/2007 Time: 11:30 AM Page 1 of 2 Filed: 1/25/2007 Subtype: Civil Comment: Status History Pending Transferred Judge History Date Judge 1/25/2007 No Judge, Payments Christian Hugel Dauphin County Complete Case History Case: 2007-CV-00656-CV Craig R Wilson vs. Edward S Tamin, etal. Physical File: Y 1/25/2007 9/26/2007 Receipt Date Type 123686 1/25/2007 Civil Filing Plaintiff Name: Wilson, Craig R Address: Phone: Home: Employer: Litigant Type: Comment: Attorneys Hugel, Christian C Defendant Name: Tamin, Edward S Address: Phone: Home: Employer: Litigant Type: Comment: Attorneys Faller, George B Jr Defendant Name: Kenyon, Allen D Address: Phone: Home: Employer: Litigant Type: Comment: Work: (Primary attorney) Work: (Primary attorney) Work: Appealed: N Reason for Removal Current User: LGARCIA ?lG b ?- G -Z o Amount 117.00 Total 117.00 SSN: DOB: Sex: Send notices: Y Send Notices SSN: DOB: Sex: Send notices: Y Send Notices SSN: DOB: Sex: Send notices: Y ORIGINAL DISTRIBUTEp S 21 7 CRAIG R. WILSON, Plaintiff V. EDWARD S. TAMIN, Defendant IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA NO. 2007-CV-00656-CV CIVIL ACTION - LAW JURY TRIAL OF TWELVE DEMANDED ORDER AND NOW this6,Z- day of , 2007, it is hereby ordered that the Defendant's Preliminary Objections are sustained, and this case be transferred to the Cumberland County Court of Common Pleas upon Plaintiff's payment of the costs for transfer or removal pursuant to Pa.R.C.P. t046(e). cc: Christian Hugel, Esquire 502 Market Street Lemoyne, PA 17043 717-737-5255 - telephone 717-737-6171 - fax George B. Faller, Jr., Esquire MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 717-243-3341 - telephone 717-243-1807 - fax gfaller@Martsonlaw.com SEP 2 6 2-M-7 I hereby c, di ' that the foregoing is a true and correct GOPYol the original filed. ?.-. -f-?ahrrK.d? _ 9rothonotary F IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA CRAIG R. WILSON Apartment 7 . 2222 Walnut Street Harrisburg, PA 17103, Plaintiff versus No. Aco? CV QoL05b CV Civil Action - Law EDWARD S. TAMIN 1200 Bent Creek Blvd. Mechanicsburg, PA 17050, ?C\?) - and ALLEN D. KENYON ` r Apt. 2 _ x r 2459 River Road m? Middletown, PA 17057'r .?. Defendants PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue a Writ of Summons in the above captioned action. Writ of Summons shall be issued and forwarded to Sheriff for service. Christian C. Hugel, Esquire 502 Market Street Signature of Attorney Lemoyne, PA 17043 (717) 737-5255 Supreme Court ID No. 76062 Attorney for Plaintiff Date: January 25, 2007 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE HEREBY NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF COMMENCED AN ACTION AGAINST YOU. Date: JAN 2 5 2007 " e'. Deputy (§)jjire of f4e ?*hPriff Mary Jane Snyder / Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin Sheriff's Return No.0656-CV - - -2007 AND NOW:January 30, 2007 at 4:06PMserved the within WRIT OF SUMMONS KENYON ALLEN D M ca Ln cn upon by personally handing to DEFENDANT 1 true attested copy(ies) of the original WRIT OF SUMMONS and making known to him/her the contents thereof at 2459 RIVER RD, APT. 2 MIDDLETOWN, PA 17057-0000 So Answers, ? x e;7*1 Sheriff of Dauphin County, Pa. SCHAEFF Plaintiff: WILSON CRAIG R 1?(:) - &J Sheriff's Costs:$ 2D 01/29/2007 RCPT NO 226003 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy (pit-tre of 14le o??eriff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor f ,a.:.:.?;J s Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff e•s 0 Q Commonwealth of Pennsylvania r r i County of Dauphin - v, L ?..q=? i ' i 1 Sheriff's Return r- =?- C:)M ,.. -. No.0656-CV - - -2007 to CA AND NOW:February 1, 2007 at 3:07PMserved the within WRIT OF SUMMONS upon TAMIN EDWARD S by personally handing (CUMBERLAND CO) to DEFENDANT 1 true attested copy(ies) of the original WRIT OF SUMMONS and making known to him/her the contents thereof at 1200 BENT CREEK BLVD MECHANICSBURG, PA 17050-0000 So Answers, ? ) 7 e;5?- Sheriff of Dauphin County, Pa. Plaintiff: WILSON CRAIG R Sheriff's Costs: $80.00 PD 01/29/2007 RCPT NO 226003 F:\FILES\DATAFILE\Travelers3090\Curtent\86213090.862. pral /nlm Created 9/20/04 0:06PM Reviseii 4/"^5/07 2:21"? 3090.862 1 By George B. Faller, Jr., Esquire --:l MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER 7; MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 - ,' (717) 243-3341 Attorneys for Defendant C) Edward S. Tamin c n CRAIG R. WILSON, IN THE COURT OF COMMON PLEAS OF Plaintiff DAUPHIN COUNTY, PENNSYLVANIA V. NO. 2007-CV-00656-CV CIVIL ACTION - LAW EDWARD S. TAMIN and ALLEN D. KENYON, Defendants JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO THE PROTHONOTARY OF DAUPHIN COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Defendant Edward S. Tamin in the above matter and issue a rule upon the Plaintiff to file a Complaint within twenty (20) days from service thereof or suffer judgment of non pros. Defendant hereby demands a twelve juror jury trial in the above captioned action. MAR Dated: April 25, 2007 E D W OEFIGES GeorgYB. Faller, 7r., 'Fsquire I.D. No. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Edward S. Tamin RULE AND NOW, this / "day of , 2005, a Rule is issued upon the Plaintiff _lVa4?, to file a Complaint within twenty (20) days 40ra service hereof. Prot otary CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Christian C. Hugel, Esquire 502 Market Street Lemoyne, PA 17043 Mr. Allen D. Kenyon 2459 River Road Apt. 2 Middletown, PA 17057 MARTSO AW OFFICES By % 1 Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: April 25, 2007 ( i) 1MAGED IN THE COURT OF CObMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA CRAIG R. WILSON, ?lLl Plaintiff No. 2007-CV-656-CV, V. CIVIL ACTION - LAW rn EDWARD S. TANIN, • T-- Defendant` r NOTICE w YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or orretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary at the Dauphin County Courthouse, 213-A N. Front Street, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 V AVISO USTED HA SIDO DEMANDADOJA EN CORTE. Si usted desea defenderse de las demandas que se presentan mcis adelante en las siguientes paginas, debe tomar accion dentro de los prbximos veinte (20) dias despues de la notificacibn 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 accion 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 reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin m6s aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA CRAIG R. WILSON, Plaintiff No. 2007-CV-656-CV V. CIVIL ACTION - LAW EDWARD S. TAMIN, Defendant N C ;Wr cr% COMPLAINT AND NOW COMES, Plaintiff, Craig R. Wilson, by and through his attorney, Christian C. Hugel, Esquire, and respectfully files this Complaint and avers the following: 1. Plaintiff Craig R. Wilson is an adult individual, residing at 2222 Walnut Street, Apt. 7, Harrisburg, Dauphin County, Pennsylvania, 17103. 2. Defendant Edward S. Tamin, is an adult individual residing at 1200 Bent Creek Bloulevard, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. On January 26, 2005, at or about 12:30 p.m., DefendantEdward S. Tamin, was operating a motor vehicle traveling westbound on Carlisle Pike, at the intersection of Gateway Drive, in Hampden Township, Pennsylvania. 4. At said time and place, Plaintiff Craig R. Wilson was a passenger in a motor vehicle, traveling westbound on Carlisle Pike, in Hampden Township, Pennsylvania. 5. Defendant Edward S. Tamin was stopped at a red light behind the vehicle Defendant Craig R. Wilson was a passenger in, and another vehicle which was between Plaintiff's vehicle and Defendant's vehicle. 6. Suddenly and without warning, Defendant Edward S. Tamin accelerated his vehicle into the rear of the stopped vehicle in front of Defendant. That vehicle was struck with such force that it was pushed forward and struck the vehicle in front of it, which Plaintiff was a passenger in. 7. This accident resulted from the negligence and recklessness of Defendant Edward S. Tamin and was due in no manner whatsoever to any act or failure to act on the part of Plaintiff Craig R. Wilson. 8. The negligence and recklessness of Defendant Edward S. Tamin consisted of the following: a. Failure to properly operate and control his motor vehicle. b. Failure to obey traffic control devices. c. Operation of his motor vehicle without due regard for the rights, safety, and position of the Plaintiff at the point aforesaid. d. Operating his motor vehicle in violation of the statutes of the Commonwealth of Pennsylvania pertaining to the operation of vehicles on streets and highways. e. Failure to keep a reasonable and proper look out for other vehicles on the streets or highways. f. Failing to exercise a degree of care, caution, and skill reasonably required under the circumstances. g. Failing to notice Plaintiff's vehicle. h. Failing to have their vehicle under control so as to prevent their vehicle from striking Plaintiff's vehicle. 9. As a result of this accident, Plaintiff Craig R. Wilson, who was the restrained passenger the aforesaid vehicle, was injured, which injuries are or may be permanent, and which are serious, including injuries to his back, excruciating pain, depression, anxiety, inability to walk normally, inability to work, and sleeping disorders. 10. As a further result of this accident, Plaintiff Craig R. Wilson has been obliged to receive and undergo hospitalization, medical attention and care, and to incur various expenses associated with his treatment and convalescence. In addition, Plaintiff is totally unemployable, is disabled, and has lost wages. 11. As a further result of this accident, Plaintiff Craig R. Wilson has suffered severe physical and mental anguish, inconvenience, humiliation, loss of life's pleasures, and may continue to suffer the same permanently and/or for an indefinite time into the future. WHEREFORE, Plaintiff demands judgment against Defendant in an amount in excess of $50,000.00, plus interest and costs of suit., and in excess of any amount requiring compulsory arbitration. d, Respectfully submit;4? G 7/ ristian C. Hugel, Esquire Ch I.D. No. 76062 Law Offices of Christian C. Hugel 502 Market Street Lemoyne, PA 17043 (717) 737-5255 Attorney for Plaintiffs VERIFICATION I, Christian C. Hugel, Esquire, attorney for Plaintiff Craig R. Wilson in the within matter and authorized to make this Verification on his behalf, verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. The undersigned understands that false statements therein are subject to the penalties of 18 Pa. C.S. 14904, relating to unsworn falsification to authorities. Date: (a)-2 :2Dp' V'Z" C Christian C. Hugel, Esquire CERTIFICATE OF SERVICE If Christian C. Hugel, Esquire, hereby certify that the foregoing Amended Complaint was served this date by depositing a true and correct copy of same in first class U.S. Mail, postage prepaid, addressed as follows: George B. Faller, Jr., Esquire Martson Law Offices 10 East High Street Carlisle, PA 17013 IZ6?-Z60-7 6 A I , ?' G * ov, / Dated: Christian C. Hugel, squire George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant C3 4 -0 © rrn W a Zr. xmz x arn --< co M AGEr CRAIG R. WILSON, Plaintiff, V. EDWARD S. TAMIN, Defendant. IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA NO. 2007-CV-656-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED DEFENDANT'S PRELIMINARY OBJECTIONS TO IMPROPER VENUE OF PLAINTIFF'S COMPLAINT AND NOW comes, Defendant, Edward S. Tamin, by and through his counsel, MARTSON LAW OFFICES, and aver the following in support of their Preliminary Objections: 1. Plaintiff's Complaint alleges that the Defendant caused a motor vehicle accident as follows: "On January 26, 2005, at or about 12:30 p.m., Defendant Edward S. Tamin, was operating a motor vehicle traveling westbound on Carlisle Pike, at the intersection of Gateway Drive, in Hampden Township, Pennsylvania." (Plaintiff's Complaint at Paragraph 3.) 2. Plaintiff's Complaint alleges that: "Defendant Edward S. Tamin, is an adult individual residing at 1200 Bent Creek Boulevard, Mechanicsburg, Cumberland County, Pennsylvania 17050." 3. Plaintiff's Complaint does not establish a proper basis for venue in the Dauphin County Court of Common Pleas. 4. Plaintiff's Complaint establishes that the only county with proper venue would be Cumberland County. 5. Plaintiff's counsel has agreed and stipulated to these objections and transfer of the case to the Cumberland County Court of Common Pleas. WHEREFORE, Defendant requests that this Court sustain Defendant's Preliminary Objections as to improper venue and transfer the case to Cumberland County Court of Common Pleas upon Plaintiff's payment of the costs for transfer or removal pursuant to Pa. R.C.P. 1006(e). MARTSON LAW By Georg&S. Fall r, Jr., Esquire I.D. No. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Dated: July 11, 2007 Attorneys for Defendant Edward S. Tamin v CERTIFICATE OF SERVICE I, Melissa A. Scholly, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Defendant's Preliminary Objections of Improper Venue to Plaintiff's Complaint was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Christian C. Hugel, Esquire 502 Market Street Lemoyne, PA 17043 MARTSON LAW OFFICES By: *W?M6 , a Melissa A. Scholly Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: July 11, 2007 01 CRAIG R. WILSON, Plaintiff V. EDWARD S. TAMIN, Defendant AND NOW this day of Co Fory IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA NO. 2007-CV-00656-CV CIVIL ACTION - LAW JURY TRIAL OF TWELVE DEMANDED ORDER 2007, it is hereby ordered that the Defendant's Preliminary Objections are sustained, and this case be transferred to the Cumberland County Court of Common Pleas upon Plaintiff's payment of the costs for transfer or removal pursuant to Pa.R.C.P. 1006(e). BY THE COURT, J. J George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant CRAIG R. WILSON, V. C7 T> Z trJ - n°c IN THE COURT OF COMMON PLEAS OF Plaintiff, DAUPHIN COUNTY, PENNSYLVANIA EDWARD S. TAMIN, Defendant. NO. 2007-CV-656-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED DEFENDANT'S PRELIMINARY OBJECTIONS TO IMPROPER VENUE OF PLAINTIFF'S COMPLAINT AND NOW comes, Defendant, Edward S. Tamin, by and through his counsel, MARTSON LAW OFFICES, and aver the following in support of their Preliminary Objections: 1. Plaintiff's Complaint alleges that the Defendant caused a motor vehicle accident as follows: "On January 26, 2005, at or about 12:30 p.m., Defendant Edward S. Tamin, was operating a motor vehicle traveling westbound on Carlisle Pike, at the intersection of Gateway Drive, in Hampden Township, Pennsylvania." (Plaintiff's Complaint at Paragraph 3.) 2. Plaintiff's Complaint alleges that: "Defendant Edward S. Tamin, is an adult O d individual residing at 1200 Bent Creek Boulevard, Mechanicsburg, Cumberland County, Pennsylvania 17050." 3. Plaintiff's Complaint does not establish a proper basis for venue in the Dauphin County Court of Common Pleas. 4. Plaintiff's Complaint establishes that the only county with proper venue would be Cumberland County. 5. Plaintiff's counsel has agreed and stipulated to these objections and transfer of the case to the Cumberland County Court of Common Pleas. WHEREFORE, Defendant requests that this Court sustain Defendant's Preliminary Objections as to improper venue and transfer the case to Cumberland County Court of Common Pleas upon Plaintiffs payment of the costs for transfer or removal pursuant to Pa. R.C.P. 1006(e). MART$QN LAW OFFICES BY 1 1 /Y-k-13 George . Falls, Jr., Esquire I.D. No. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Dated: July 11, 2007 Attorneys for Defendant Edward S. Tamin F CERTIFICATE OF SERVICE I, Melissa A. Scholly, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Defendant's Preliminary Objections ofImproper Venue to Plaintiff's Complaint was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Christian C. Hugel, Esquire 502 Market Street Lemoyne, PA 17043 MARTSON LAW OFFICES By: Melissa A. Scholly Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: July 11, 2007 CRAIG R. WILSON, Plaintiff v. EDWARD S. TAMIN, Defendant AND NOW this day of IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA NO. 2007-CV-00656-CV CIVIL ACTION - LAW JURY TRIAL OF TWELVE DEMANDED ORDER 2007, it is hereby ordered that the Defendant's Preliminary Objections are sustained, and this case be transferred to the Cumberland County Court of Common Pleas upon Plaintiffs payment of the costs for transfer or removal pursuant to Pa.R.C.P. 1006(e). BY THE COURT, J. CRAIG R. WILSON, v. EDWARD S. TAMIN, Defendant NO. 2007-CV-00656-CV CIVIL ACTION - LAW JURY TRIAL OF TWELVE DEMANDED AND NOW this day of ORDER 2007, it is hereby ordered that the Defendant's Preliminary Objections are sustained, and this case be transferred to the Cumberland County Court of Common Pleas upon Plaintiff's payment of the costs for transfer or removal pursuant to Pa.R.C.P. 1006(e). BY THE COURT, IN THE COURT OF COMMON PLEAS OF Plaintiff DAUPHIN COUNTY, PENNSYLVANIA J. 0. I CRAIG R. WILSON, IN THE COURT OF COMMON PLEAS OF Plaintiff DAUPHIN COUNTY, PENNSYLVANIA V. NO. 2007-CV-00656-CV EDWARD S. TAMIN, CIVIL ACTION -LAW Defendant JURY TRIAL OF TWELVE DEMANDED ORDER AND NOW this day of , 2007, it is hereby ordered that the Defendant's Preliminary Objections are sustained, and this case be transferred to the Cumberland County Court of Common Pleas upon Plaintiff's payment of the costs for transfer or removal pursuant to Pa.R.C.P. 1006(e). BY THE COURT, J. f George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant CRAIG R. WILSON, V. C.) a w -a? Dc tv o^''< a°o --? ;:0 -< C -? P Plaintiff, IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA EDWARD S. TAMIN, Defendant. NO. 2007-CV-656-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED DEFENDANT'S PRELIMINARY OBJECTIONS TO IMPROPER VENUE OF PLAINTIFF'S COMPLAINT AND NOW comes, Defendant, Edward S. Tamin, by and through his counsel, MARTSON LAW OFFICES, and aver the following in support of their Preliminary Objections: 1. Plaintiff's Complaint alleges that the Defendant caused a motor vehicle accident as follows: "On January 26, 2005, at or about 12:30 p.m., Defendant Edward S. Tamin, was operating a motor vehicle traveling westbound on Carlisle Pike, at the intersection of Gateway Drive, in Hampden Township, Pennsylvania." (Plaintiff's Complaint at Paragraph 3.) 2. Plaintiff's Complaint alleges that: "Defendant Edward S. Tamin, is an adult individual residing at 1200 Bent Creek Boulevard, Mechanicsburg, Cumberland County, Pennsylvania 17050." 3. Plaintiff's Complaint does not establish a proper basis for venue in the Dauphin County Court of Common Pleas. 4. Plaintiff's Complaint establishes that the only county with proper venue would be Cumberland County. f 5. Plaintiff's counsel has agreed and stipulated to these objections and transfer of the case to the Cumberland County Court of Common Pleas. WHEREFORE, Defendant requests that this Court sustain Defendant's Preliminary Objections as to improper venue and transfer the case to Cumberland County Court of Common Pleas upon Plaintiff's payment of the costs for transfer or removal pursuant to Pa. R.C.P. 1006(e). MART,SQN LAW By George . Fall r, Jr., Esquire I.D. No. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Dated: July 11, 2007 Attorneys for Defendant Edward S. Tamin CERTIFICATE OF SERVICE I, Melissa A. Scholly, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Defendant's Preliminary Objections ofImproper Venue to Plaintiff's Complaint was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Christian C. Hugel, Esquire 502 Market Street Lemoyne, PA 17043 MARTSON LAW OFFICES By: Melissa A. Scholly Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: July 11, 2007 I CRAIG R. WILSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : DAUPHIN COUNTY, PENNSYLVANIA V. NO. 2007-CV-00656-CV CIVIL ACTION - LAW EDWARD S. TAMIN, Defendant JURY TRIAL OF TWELVE DEMANDED O_ AND NOW this day of , 2007, it is hereby ordered that the Defendant's Preliminary objections are sustained, and this case be transferred to the Cumberland County Court of Common Pleas upon Plaintiff's payment of the costs for transfer or removal pursuant to Pa.R.C.P. 1006(e). BY THE COURT, J. George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant O .? C Z i= ?. O c) o c fin z w y Qrn< c) ..corn -c o CRAIG R. WILSON, V. EDWARD S. TAMIN, Defendant. IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA Plaintiff, NO. 2007-CV-656-CV CIVIL ACTION - LAW JURY TRIAL DEMANDED DEFENDANT'S PRELIMINARY OBJECTIONS TO IMPROPER VENUE OF PLAINTIFF'S COMPLAINT AND NOW comes, Defendant, Edward S. Tamin, by and through his counsel, MARTSON LAW OFFICES, and aver the following in support of their Preliminary Objections: 1. Plaintiff's Complaint alleges that the Defendant caused a motor vehicle accident as follows: "On January 26, 2005, at or about 12:30 p.m., Defendant Edward S. Tamin, was operating a motor vehicle traveling westbound on Carlisle Pike, at the intersection of Gateway Drive, in Hampden Township, Pennsylvania." (Plaintiff s Complaint at Paragraph 3.) 2. Plaintiffs Complaint alleges that: "Defendant Edward S. Tamin, is an adult individual residing at 1200 Bent Creek Boulevard, Mechanicsburg, Cumberland County, Pennsylvania 17050." 3. Plaintiffs Complaint does not establish a proper basis for venue in the Dauphin County Court of Common Pleas. 4. Plaintiffs Complaint establishes that the only county with proper venue would be Co Cumberland County. Ct? w ?Py George B. Faller, Jr., Esquire LD. No. 49813 MARTSON DEARDORFF WILLjAMS OTTO G11 Y & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant CRAIG R 'WIISON, IN THE COURT OF COMMON Plaintiff, DAUPHIN COUNTY p PLEAS OF ENNSYLVANIA V. : N0.2007-CV-656-CV EDWARD S. TAMIlV, : C-WIL ACTION - LAW Defendant. : JURY TRIAL DEMANDED ..jR O--RQF AND NOW this - day of Defendant's pre2007, it is hereby ordered that the County Court Objections are sustained, and this case be transferred to the Cumberland of Common Pleas upon Plaintiffs payment of the costs Pursuant to Pa.R.C.P. 1006(e), for transfer or removal BY THE COURT, J. FARLFS%Cbmu%Travakts3omcwrtnt%62X3090.862stv2Mkn Created: 940104 0:%M Revised: 9/13/07 2:14PM 5 F 1 1AVED 0 F, George B. Faller, Jr., Esquire kq'l I.D. No. 49813 2001 SEP 17 PM 1: 59 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant CRAIG R. WILSON, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : DAUPHIN COUNTY, PENNSYLVANIA V. EDWARD S. TAMIN, Defendant. NO. 2007-CV-656-CV CIVIL ACTION - LAW : JURY TRIAL DEMANDED STIPULATION OF COUNSEL IT IS HEREBY STIPULATED AND AGREED by and between counsel for Defendant Edward S. Tamin and counsel for Plaintiff Craig R. Wilson that: 1. The Court sustain Defendant's Preliminary Objections as to improper venue and transfer the case to Cumberland County Court of Common Pleas upon Plaintiffs payment of the costs for transfer or removal pursuant to Pa. R.C.P. 1006(e). MARTSON LAW OFFICES By George B. F ., uire I.D. Number 813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant LAW OFFICES OF CHRISTIAN C. GEL By Christian C. Hugel, Esquire I.D. Number 76062 502 Market Street Lemoyne, PA 17043 (717) 737-5255 Attorneys for Plaintiff Date: CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Stipulation of Counsel was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Christian C. Hugel, Esquire LAW OFFICES OF CHRISTIAN C. HUGEL 502 Market Street Lemoyne, PA 17043 MARTSON LAW OFFICES sy 4) Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: 4 F: \RLES\Clients\Travelm3090\Cunent\862\3090.862.rnot. compel.wpd George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. No. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant CRAIG R. WILSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND QQCOUNTY, PENNSYLVANIA V. NO. 2007-CV-OW6&fiwCV CIVIL ACTION - LAW EDWARD S. TAMIN Defendant JURY TRIAL OF TWELVE DEMANDED DEFENDANT'S MOTION TO COMPEL DISCOVERY 1. This case arises out of an automobile accident that occurred on January 26, 2005. 2. Plaintiff has filed a claim alleging that he sustained personal injuries as a result of the accident. 3. On or about April 25, 2007, Defendant served Interrogatories on Plaintiff. A copy of Defendant's First Set of Interrogatories Directed to Plaintiff is attached hereto as Exhibit "A." 4. On or about April 25, 2007, Defendant served a Request for Production of Documents on Plaintiff. A copy of Defendant's Request for Production of Documents is attached hereto as Exhibit «B Despite repeated requests made by way of telephone calls and written correspondence, Defendant's discovery requests remain unanswered. Copies of written correspondence are attached hereto as Exhibit "C." 6. There has been no prior involvement by any Judge in this matter. WHEREFORE, Defendant requests that this Court issue an Order directing Plaintiff to answer the discovery within twenty days. Date: December l ? , 2007 MART AW OF CES BY George 1KT'aller,7r., Esq? I.D. Number 49813 U 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant -a RFCYCLFD PAPE0. RELY L-f F `FILES\DATAFILF\Trarelers3090,Current\S6'\3090.802 intl;nlm Crcated' 9,20,04 0.00M Revised 4,2507 ?. 1'P:M 1090 862 t George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Edward S. Tamin CRAIG R. WILSON, Plaintiff Q V. O EDWARD S. TAMIN ?J and ALLEN D. KENYON, Defendants IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA NO. 2007-CV-00656-CV CIVIL ACTION - LAW : JURY TRIAL OF TWELVE DEMANDED DEFENDANT EDWARD S. TAMIN'S FIRST SET OF INTERROGATORIES DIRECTED TO PLAINTIFF TO: CRAIG R. WILSON, Plaintiff, and his attorney, CHRISTIAN C. HUGEL, ESQUIRE Enclosed are Interrogatories propounded by Defendant to be answered under oath by the aforesaid Plaintiff pursuant to Pa. R.C.P. No. 4005, within thirty (30) days from the date of service hereof. A copy of said Answers shall be served upon counsel for Defendant at the address below. These Interrogatories shall be deemed to be-continuing Interrogatories and if, between the time of your Answers to said Interrogatories and the time of trial of this case, you or anyone acting in your behalf learn of any further information not contained in your said Answers, you shall promptly furnish said information to the undersigned by supplemental answers. As used herein, the words "accident" or "occurrence" refer to the event or events described in your Complaint and all related events and circumstances. The word "you" or "your includes your attorneys, representatives, insurers, and all others purporting to act on your behalf. Unless otherwise specified, response to the following Interrogatories shall give the requested information for the period from January 26, 2005, to the present (hereinafter sometimes referred to as the "time period"). Exhibit "A" x It is hereby certified that a true and correct copy of these Interrogatories was mailed to counsel for the Plaintiff on this date by the undersigned. MARTSON LAW OFFICES By L94C? 6 George B. Faller, Jr., Esquire V I.D. Number 49813 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Edward S. Tamin Date: April 25, 2007 x Interrogatory No. 1 For each health care practitioner Plaintiff has seen since the date of the accident (whether in connection with the injuries suffered in the accident or not), provide the identity of same, the purpose of seeing practitioner, the number and inclusive dates of each visit, a description of all medication recommended or prescribed, a description of any treatment received or recommended, a listing of any charges incurred and the identity of the person or entity paying same if not Plaintiffs. ANSWER: X Interrogatory No. 2 Identify any health care practitioner that you have seen for ten (10) years prior to the incident in question, including but not limited to, your family physician and give the name and address of each. ANSWER: Interrogatory No. 3 State whether, as a result of the said occurrence, you required any medical or vocational rehabilitation services; that is, services necessary to reduce disability and to restore the physical, psychological, social and vocational functions, including but not limited to: medical care, diagnostic and evaluation procedures, physical and occupational therapy, other necessary therapies, speech pathology and audiology, optometric services, nursing care under the supervision of a registered nurse, medical social services, vocational rehabilitation and training services, occupational licenses and tools, and transportation necessary to secure such services. If so, state fully: The names and addresses of all medical, rehabilitation facilities, hospitals and/or clinics at which you were examined or attended; the names and addresses of all individuals and physicians who attended or examined you; the date of each treatment; and a description of the treatment received. ANSWER: Interrogatory No. 4 State fully all the injuries you claim to have suffered in or as a result of the said occurrence. ANSWER: Interrogatory No. 5 As to the injuries claimed in Interrogatory No. 4, have you ever experienced or been treated for the same or similar condition? ANSWER: Interrogatory No. 6 State fully all elements of economic loss, and the dollar value thereof, that you claim to have suffered in or as a result of the said occurrence. As part of your answer, state specifically, any claims for loss of income, past, present and future, explain how that was computed, and provide the inclusive dates of all time lost from work, whether full time or part time. ANSWER: Interrogatory No. 7 If you still suffer pain from any of your injuries and conditions resulting from the incident, state specifically the frequency and nature of the pain and the injuries or conditions from which it emanates. ANSWER: Interrogatory No. S What future reasonable and necessary professional medical treatment and/or care do you claim you will require as a result of the said occurrence? ANSWER: Interrogatory No. 9 Was any investigation made of the accident or accident scene by you or by anyone acting on your behalf after the accident? If so, then for each such investigation, kindly state further: (a) The date and time it was made; (b) The name, address and employment of the person who made it; C The date and present custodian of any report concerning the inspection or investigation; (d) The identity of all persons interviewed as part of the inspection or investigation; and (e) A description of any exhibits, including, but not limited to, photographs or drawings prepared in connection with the investigation or inspection. ANSWER: Interrogatory No. 10 Please identify each of your employers, state the inclusive dates of employment and your gross and net earnings on a weekly or monthly basis for the period beginning five years before the accident to and including the present. With respect to each such employment, please describe your job duties and responsibilities. ANSWER: Interrogatory No. 11 If you have filed a Federal, State or Local Income Tax return for any of the five calendar years preceding the accident or any year since, please state whether copies were kept or subsequently obtained, and, if so, identify every person who has, or at any time had, a copy of same. Alternatively to an answer, you may attach complete copies of each return as filed, to include, without limitation, all schedules, W-2, 1099's and other attachments. ANSWER: Interrogatory No. 12 State whether you have been unable to perform satisfactorily all duties required of you in your employment and all activities of daily living since the date of the said occurrence, indicating with particularity those duties and activities you were unable to perform and the names and addresses of all persons having knowledge of such, including your supervisors, fellow employees, family, friends and the like. State further the identity of any physician who has advised you concerning the limitations or duration of any such disability. ANSWER: Interrogatory No. 13 Please state the name and address of any insurer, auto or otherwise, which you believe provides coverage, whether first party, third party, primary, secondary, contingent worker's compensation or other, for any injury or loss arising out of the said accident, and state further the owner of the policy, the type of policy, a description of any claim made, the nature of the coverage, the limits of each coverage applicable, the nature and amounts of any benefits paid by any such insurer and a description of any claim that was denied in whole or in part, as well as the name, address, policy number and claim number for any claim arising out of the events described in the policy number(s) and claim number(s) for any claim arising out of the events described in the complaint. ANSWER: Interrogatory No. 14 Identify any medical expenses which you have incurred which have not been covered by a collateral source (i.e. first party medical coverage, worker's compensation, Blue Cross/Blue Shield, etc.). ANSWER: Interrogatory No. 15 Please identify each person you expect to call as an expert witness at trial and state the subject matter on which each person is expected to testify. ANSWER: Interrogatory No. 16 As to each person identified in your answer to the preceding interrogatory, please state the substance of the facts and opinions to which he is expected to testify and the grounds for each opinion.* Signature of Expert *A report, personally signed by your expert, may be furnished in lieu of your answer to this interrogatory. If you elect to furnish reports in lieu of an answer, then please indicate in the space above the date of each such report and the persons by whom they were prepared. Interrogatory No. 17 Identify every person known to you who claims to have seen or heard any of the parties make any statement or statements pertaining to any of the events or happenings alleged in the pleadings. ANSWER: Interrogatory No. 18 Identify every person known to you, who you believe may have knowledge concerning: (a) The happening of the accident; (b) Any fact or circumstance pertaining to the accident; or 0 The conditions at the scene at, or immediately before or after, the time of the accident. ANSWER: Interrogatory No. 19 Have you, your attorney, or any representative of you or your company entered into or been a party to any releases, stipulations, understandings or agreements regarding your liability for the claims which have been made in this case? ANSWER: Interrogatory No. 20 Have you ever been an occupant of an automobile that was involved in a collision, other than the collision described in your Complaint? If so, please state: (a) the date and location of each collision; (b) the identity of all other occupants of all vehicles involved in the collision; 3 whether you were injured in the collision, and, if so, the nature and extent of your injuries; (d) whether a claim was made by you as a result of the collision, and, if so, the identity of the insurer and claims adjuster and location of the claims office of all insurers against whom any claim was made by you, whether as a first party or third party; (e) whether you were a party in any court action or arbitration arising out of the collision, and, if so, please state below the full caption, identity of all attorneys, and the present status of said court action or arbitration. ANSWER: , k Interrogatory No. 21 Have you ever been convicted or pled guilty to a crime? If so, list the court, the offense and the date of the conviction or guilty plea. ANSWER: l Interrogatory No. 22 Have you ever, either prior to or after the accident, made a claim for a personal injury or worker's compensation? If so, describe the circumstances surrounding the claim including the name of the party against whom the claim was made and their insurance company. ANSWER: Interrogatory No. 23 State your full name, any aliases, prior names, nicknames and your social security numbers and date of birth. ANSWER: ? 1 l COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF Craig R. Wilson, being duly sworn according to law, depose and say that the facts set forth in the foregoing Answers to Interrogatories are true and correct. Craig R. Wilson Sworn to and subscribed before me this day of , 2007 • 4 ¦ CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Interrogatories was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Christian C. Hugel, Esquire 502 Market Street Lemoyne, PA 17043 Mr. Allen D. Kenyon 2459 River Road Apt. 2 Middletown, PA 17057 MARTSON LAW OFFICES r By_ Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: April 25, 2007 Y • . . 4F% -VCLFVpAVIN IL 41 CF `,FILES\DATAFILE\Tracelers30,30\Cutrent\86?\3090.868.gpol/nlm Created. 9.]004 OQ OoPM Revised. 425.07 3 03PM t t• . 3690_So2 a 0 a? George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Edward S. Tamin CRAIG R. WILSON, V. IN THE COURT OF COMMON PLEAS OF Plaintiff DAUPHIN COUNTY, PENNSYLVANIA EDWARD S. TAMIN and ALLEN D. KENYON, Defendants NO. 2007-CV-00656-CV CIVIL ACTION - LAW : JURY TRIAL OF TWELVE DEMANDED DEFENDANT EDWARD S. TAMIN'S REQUEST FOR PRODUCTION OF DOCUMENTS DIRECTED TO PLAINTIFF TO: CRAIG R. WILSON, Plaintiff, and his attorney, CHRISTIAN C. HUGEL, ESQUIRE AND NOW, this 25th day of April, 2007, pursuant to Pa. R.C.P. 4009, as amended, comes Defendant Edward S. Tamin, by his Attorneys, MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, Ten East High Street, Carlisle, Pennsylvania, and requests Plaintiffto produce for inspection, examination and copying, at the above office, not later than thirty (30) days after service of this Request the following documents: 1. All photographs in the possession, custody or control of Plaintiffs, counsel for Plaintiffs, or any other person or entity acting on behalf of Plaintiffs, including any insurers for Plaintiffs, showing, representing or purporting to show any vehicles, locales, instrumentalities, persons, property, and any and all other matters related to the subject matters of this litigation. 2. All diagrams, sketches, drawings, plans, measurements or blueprints in the possession, custody or control of Plaintiffs, counsel for Plaintiffs, or any other person or entity acting on behalf of Plaintiffs, including any insurer of Plaintiffs, showing representing or purporting to show any of the instrumentalities, locales, persons or other matters involved in the incident which forms the basis of Plaintiffs' Complaint. 3. All statements, signed statements, transcripts of recorded statements or interviews, recorded statements if not transcribed or any statement or recorded statements if not transcribed verbatim taken of any parties, persons or witnesses as part of an investigation of the happening or cause of the incident in question, conducted by, or in the possession of, Plaintiffs, Plaintiffs' attorney, insurers or anyone else action on behalf of Plaintiffs. Exhibit "B" r r + 4. All expert opinions, expert reports, expert summaries or other writings of experts in possession, custody or control of Plaintiffs, Plaintiffs' attorneys or insurers, which relate to the subject matter of this litigation and the incident in question. 5. All documents prepared by Plaintiffs, or by any insurers, representatives, agents or anyone acting on behalf of Plaintiffs, except Plaintiffs' attorneys, during an investigation of any aspect of the incident in question. Such documents shall include any documents made or prepared up through the present time, with the exclusion of the mental impressions, conclusions or opinions respecting the value or merit of a claim or defense, or respecting strategy or tactics. (NOTE: As referred to herein, "documents" includes written, printed, typed, recorded or graphic matter, however produced or reproduced, including correspondence, telegrams, other written communications, data processing storage units, tapes, contracts, agreements, notes, memoranda, analyses, projections, indices, work papers, studies, reports, surveys, diaries, calendars, films, photographs, diagrams, drawings, minutes of meetings or any other writing (including copies of the foregoing, regardless of whether the parties to whom this request is addressed are now in the possession, custody or control of the original) now in the possession, custody or control of Plaintiffs, Plaintiffs' former or present counsel, agents, employees, officers, insurers or any other person action on Plaintiffs' behalf.) 6. If not otherwise covered by the above Requests, the complete claims/investigation/subrogation/no-fault file(s) of Plaintiffs or any insurers thereof, dealing with the incident in question, with the exclusion of the mental impressions, conclusions or opinions respecting the value or merit of a claim or defense, or respecting strategy or tactics. 7. All documents in the possession, custody or control of Plaintiffs, Plaintiffs' counsel, insurers, physicians, or anyone else acting on Plaintiffs' behalf, dealing in any way with all injuries, damages and losses sustained by Plaintiffs. This should include, but not be limited to, invoices, estimates, appraisals, inventories, medical bills, medical records, reports, x-rays, intake notes, correspondence, and charts concerning any injuries and damages alleged in Plaintiffs' Complaint. 8. A copy of the declarations page of any insurance policy where you would be an insured party or other document indicating the tort option (full or limited) which would be applicable. 9. If any document or class of documents is being withheld on the basis of any privilege, identify the document or class of documents, the date or dates of the documents, its author or originator, as well as the privilege which is being asserted. MARTSON LAW OFFICES By 4 ? ? <:Gt , George B. Faller, Jr., Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: April 25, 2007 Attorneys for Defendant Edward S. Tamin w k r f CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Defendant Edward S. Tamin's Request for Production of Documents Directed to Plaintiff was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Christian C. Hugel, Esquire 502 Market Street Lemoyne, PA 17043 Mr. Allen D. Kenyon 2459 River Road Apt. 2 Middletown, PA 17057 MARTSON LAW OFFICES By,-/' I!r'2? Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: April 25, 2007 M l F? 4 ? u?cvneo rnvFx ca RF , ,ne E : ?I • 0 N ,.' !: T' l..,, ..t October 25, 2007 Christian C. Hugel, Esquire 502 Market Street Lemoyne, PA 17043 RE: Craig R. Wilson v. Edward S. Tamin and Allen D. Kenyon No, 2007-CV-00656-CV - Dauphin County C.C.P. Our File No. 3090.862 Dear Mr. Hugel: ?? In an effort to move this case forward in Cumberland County, I remind you that your client's Answers to Interrogatories and Response to Request for Production of Documents are several months past due. Please advise as to when we can expect your client's discovery responses, and please confirm that the costs to transfer this action from Dauphin to Cumberland County have been paid. Should you have any questions, feel free to contact our office. Very truly yours, TEF mas MARTSON LAW OFFICES Trudy E. Fehlinger cc: Ms. Carol Alberto (L2ti2215) (%"a e-mail) . IhLCt- C , .C" _ N;, ,:., Exhibit "C" ON December 3, 2007 Christian C. Hugel, Esquire 502 Market Street Lemoyne, PA 17043 RE: Craig R. Wilson v. Edward S. Tamin No. 2007-6205 - Cumberland County C.C.P. Our File No. 3090.862 Dear Mr. Hugel: This letter is in follow-up to your telephone conversation with my assistant, Melissa, on Thursday, November 29, 2007. It is our understanding that you are having difficulty finalizing the responses to our written discovery which were served on you on April 25, 2'007. Please forward-to us what you have completed so far within ten (10) days from the date of this letter so that we c in move forward with this case. Should you have any questions, feel free to contact our office. Very truly yours, MARTSON LAW OFFICES George B. Faller, Jr. GBF.- mas cc: %Is. Carol Alberto (1-21N22 15) (via e-mail) CERTIFICATE OF SERVICE I, Nichole L. Myers, an authorized agent of Manson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Defendant's Motion to Compel Discovery was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Christian C. Hugel, Esquire 502 Market Street Lemoyne, PA 17043 MARTSON LAW OFFICES By L(X Nichole L. Myers Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: December ? O , 2007 t CRAIG R. WILSON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 07-6205 CIVIL . CIVIL ACTION - LAW EDWARD S. TAMIN, Defendant JURY TRIAL DEMANDED IN RE: DEFENDANT'S MOTION TO COMPEL ORDER AND NOW, this 3lday of December, 2007, a rule is issued on the plaintiff to show cause why the relief requested in the within motion ought not to be granted. This rule returnable twenty (20) days after service. BY THE COURT, ug ; 4 I?j iiNaA } N S I •Z Ind I E 330 LOOZ 1ibV'.I.()h CIA I"d aHI JO George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant CRAIG R. WILSON, V. Plaintiff, EDWARD S. TAMIN, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-6205 CIVIL ACTION - LAW : JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that: (1) a notice of intent to serve 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: January 3, 2008 By I.D. No. 49813 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Defendant F.\FILES\Clients\Travelers3090\Current\867L090.86'_.not I Created. 11'2,97 10 14 24 AM Revised. 12 05107 11 31.35 AM George B. Faller, Jr., Esquire I.D. No. 49813 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant CRAIG R. WILSON, V. IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-6205 CIVIL ACTION - LAW EDWARD S. TAMIN, Defendant. : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. Date: December 5, 2007 n `J MARTSON LAW OFFICES r-? f? (A By ""`?. George B. Faller, Jr., Esquire I.D. No. 49813 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Defendant COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Craig R. Wilson, Plaintiff, File No. 2007-6205 V. Edward S. Tamin, Defendant. ' SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Ms. Kimberly King, GEICO Casualty Company TO: One Geico Blvd., Fredericksburg, VA 22412 (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: The entire first party benefits file for a claim by Craig R. Wilson. The claim was made by Mr. Wilson, as a passenger of your insured, Marguerite J. Neal, date of accident January 26, 2005, claim number 0175593520101018 and policy number 1748281902. at Martson Law Offices, 10 East High Street, Carlisle, PA 17013 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: George B. Faller, Jr., Esquire ADDRESS: Marston Law Offices 10 East Hieh Street Carlisle. PA 17013 TELEPHONE: 717-243-3341 SUPREME COURT ID # 49813 ATTORNEY FOR: D e f e n rt an t Date: December 3, 2007 BY THE T: notary, tiVff Iii ' ion 'Seal of the Court Deputy CERTIFICATE OF SERVICE I, Melissa A. Scholly, an authorized agent for Martson Law Offices, hereby certify that a copy of the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Christian C. Hugel, Esquire 502 Market Street Lemoyne, PA 17043 MARTSON LAW OFFICES By: Melissa A. Scholly Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: January 3, 2008 C'? rIZO C7 t'l v: J i X8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILSON Vs., NO. 076205 TAMIN , CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 GEORGE B FALLER JR, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 05/07/08 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3336 File #: M351409 By: Christine Moisy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILSON Vs. TAMIN TO: CHRISTIAN HUGEL, ESQ (PLAINTIFF) No. 076205 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 04/16/08 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE; PA 17013 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 By: Christine Moisy Enc (s) : Copy of subpoena(s) Counsel return card File #: M351409 apwxVaMALTH OF PENNMVANIA Caney OF -CLIGOMM WILSON Vs. TAMIN Fi la No. 0'71;2ns SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: REHAB MED ASSOCS, 5124 E TRINDLE RD, MECHANICSBURG PA 17055 (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 ADDENDUM at MEDICAL LEGAL RBPRODUCTIONS,(AVigess4940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of carpliance, to the party making thin 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 thin subpoena may seek a court orde:- carpe 11 ing you to camp ly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: GEORGE 34 FALL R JR, ESQ ADDRESS: - 113 S h! GH-ST- TELEPHONE: CARLISLE, PA 17 013 SUPREME COURT ID #215 - 3 3 5- 3 212 ATTORNEY FOR: 49233-- DEFENDANT BY THE OOURT: M351409-01 DATE : a" 1 Se 1 of the Oourt S - Prothonotary/C1 k, Civil Divisionp.' .. u Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA WILSON Vs. No. 076205 TAMIN CUSTODIAN OF RECORDS FOR : REHAB MED ASSOCS ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: CRAIG R WILSON ADDRESS: 919 GIBSON BLVD STEELTON PA DATE OF BIRTH: 02/20/59 SSAN: XXXXX7656 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or REHAB MED ASSOCS CUMBERLAND M351409-01 * * * SIGN AND RETURN THIS PAGE * * * OF PENNMVANIA ax wry qF-avemEmm WILSON ' Vs. File No. 07r. 9nc; TAMIN SUBPOENA TO PRODUCE DOCLMNTSJW*ft S8ILLING REQUESTED FOR DISCOVERY PURSUANT TO RULE 4009.22 HEALTHSOUTH REHAB HOSP, 175 LANCASTER BLVD, MECHANICSBURG PA 17055 TO: NTN _ ffET1T.GAL RZGQRDS DR-312T (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 ADDENDUM at MEDICAL LEGAL REPRODUCTIONS,(AVAe]aso940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of WrP1ianCe, to the party making thi request at the address listed above. You have the right to seek in advance the rea,onable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving thi, subpoena may seek a court ordei- om pe l l i ng you to coup l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: GEORGE-- RALLER JR, ESQ ADDRESS: TELEPHONE: CARLISLE, PA 17 013 SUPREME COURT ID # 215 - 33 5- 3 212 ATTORNEY FOR: 4 0813 DEFENDANT BY THE COURT. M351409-02 DATE : I a -w Q Sell of the Court Prothonotary/Ci , Civil Division/,,-' Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA WILSON Vs. TAMIN No. 076205 CUSTODIAN OF RECORDS FOR : HEALTHSOUTH REHAB HOSP Any and all hospital records, including microfilm, microfiche emergency room reports, x-ray reports, out-patient records physical therapy records, and any other information pertaining to: NAME: CRAIG R WILSON ADDRESS: 919 GIBSON BLVD STEELTON PA DATE OF BIRTH: 02/20/59 SSAN: XXXXX7656 MEDICAL BILLING REQUESTED ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or HEALTHSOUTH REHAB HOSP CUMBERLAND M351409-02 * * * SIGN AND RETURN THIS PAGE apy9&vMV,AUTH OF PF3NUMVANIA a xwry of a m WILSON Vs. TAMIN File No. 0762nc; SUBPOENA TO PRODUCE DOCUMENTS BILLING REQUESTED FOR DISOOVERY PURSUANT TO RUB 4009.22 TO: DR ABDULAI BUKARI, 43 KLINE PLZ, HARRISBURG PA 17104 (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 ADDENDUM at MEDICAL LEGAL REPRODUCTIONS,(AVA%ssj940 DISSTON ST., PHILA., PA 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 thi; request at the address listed above. You have the right to seek in advance the reasonabl,- 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 thi, subpoena may seek a court ordei- oampelling you to ca, ly with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: GEORGE -la FALLER JR, ESQ ADDRESS: 1U B k1lUki b7 TELEPHONE : CARLISLE, PA 17 013 SUPREME ODURT ID #215 - 3 3 5- 3 212 ATTORNEY FOR: --92- DEFENDANT M351409-03 DATE : ot'A'j a U1) S dal of the Court BY THE COURT: Prothonotary/01", Civil Division Deputy (Ef f . 7/9T ) ADDENDUM TO SUBPOENA WILSON Vs. No. 076205 TAMIN CUSTODIAN OF RECORDS FOR : DR ABDULAI BUKARI ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: CRAIG R WILSON ADDRESS: 919 GIBSON BLVD STEELTON PA DATE OF BIRTH: 02/20/59 SSAN: XXXXX7656 MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ l RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ( ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or DR ABDULAI BUKARI CUMBERLAND M351409-03 * * * SIGN AND RETURN THIS PAGE CpM AL.TH OF pFiaSYLVANIA 0001 Ty OF Q 'ID WILSON , Vs. File No. 0762f1? _ TAMIN SUBPOENA TO PRODUCE DO0j ENTS W~ILLINQ REQUESTED FOR DISOOVERY PURSUANT TO RULE 4009.22 TO: HARRISBURG INTERV PAIN, 825 SIR THOMAS CT, HARRISBURG PA 17109 (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 ADDENDUM at MEDICAL LEGAL REPRODUCTIONS,(AVAE$ss$940 DISSTON ST., PHILA., PA 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 thi; request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving thin subpoena may seek a court orde:- c=pe l l i ng you to oa, l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: GEORG?2 FALLER JR, ESQ ADDRESS: TELEPHONE : CARLISLE, PA 17 013 SUPREME COURT ID #215 - 3 3 5- 3 212 ATTORNEY FOR: 49813 DEFENDANT BY THE OOURT: M351409-04 DATE : 0,0,?P Jr. a uv g, 1 of the Court 11311 e4lizzl- P geMl - Prothonotary/C1 , Civil Division jam=' 1 qty (Eff. 7/9T) ADDENDUM TO SUBPOENA WILSON Vs. TAMIN CUSTODIAN OF RECORDS FOR: HARRISBURG INTERV PAIN No. 076205 ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ADDRESS: DATE OF BIRTH: SSAN: CRAIG R WILSON 919 GIBSON BLVD 02/20/59 XXXXX7656 STEE LTON PA MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or HARRISBURG INTERV PAIN CUMBERLAND M351409-04 * * * SIGN AND RETURN THIS PAGE * * * ?7r 31 "^C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILSON Vs. NO. 076205 TAMIN CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 GEORGE B FALLER JR, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 06/05/08 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3336 File #: M352344 By: Christine Moisy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILSON Vs. TAMIN No. 076205 TO: CHRISTIAN HUGEL, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'T'S AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 05/14/08 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 By: Christine Moisy Enc(s): Copy of subpoena(s) Counsel return card File #: M352344 rn OF PENN YLVANIA COUNry OF CEAI'ID r WILSON , Vs. Fi le No. A76205 TAMIN ' SUBPOENA TO PRODXE DOCUMENTS- OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HARRISBURG HOSP, 111 S FRONT ST, HARRISBURG PA 17101 ( 4ii of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunents or things: _ SEE ATTACB ED ADDENDUM at MEDICAL LEGAL REPRODUCTIONSXAiltllE sg$940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of campliance, to the party making thi request at the address listed above. You have the right to seek in advance she 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 (120) days after its service, the party serving thin subpoena may seek a court order oompelling you to cart ply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWIN13 PERSON: NAME: `GORGE D RAILER JR, ESQ ADDRESS: 10 E HIGH ST TELEPHONE : CARLISLE, PA 17 013 SUPRID E COURT ID #215 - 3 3 5- 3 212 ATTORNEY FOR: 4-9233- DEFENDANT BY THE COURT: M352344-01 DATE : / ?(? 4' Sea of the court ze -P-0?4 Prothonotary/C1 , Civil Division / - CLA, Deputy (Eff. 7/97) . w WILSON Vs. TAMIN ADDENDUM TO SUBPOENA No. 076205 CUSTODIAN OF RECORDS FOR: HARRISBURG HOSP Any and all hospital records, including microfilm, microfiche emergency room reports, x-ray reports, out-patient records physical therapy records, and any other information pertaining to: NAME: CRAIG R WILSON ADDRESS: 919 GIBSON BLVD STEELTON PA DATE OF BIRTH: 02/20/59 SSAN: XXXXX7656 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or HARRISBURG HOSP CUMBERLAND M352344-01 * * * SIGN AND RETURN THIS PAGE * * * rl?p P A rv ??r'; rn -0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILSON Vs. NO. 076205 TAMIN CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 GEORGE B FALLER JR, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2% A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 10%03/08 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST qw? File #: M156312 CARLISLE, PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940. DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3336 By: Linda Morson IN TIC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILSON' Vs. TAMIN No. 076205 TO: CHRISTIAN HUGEL, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 09/12/08 Enc,(s) : Copy of subpoena(s) " Counsel return card File #: M356312 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 By: Linda Morson t Cow"MmITH OF PFIwa tLV ?IA couNn op a mmAw ,,,..-._...... WILSON Vs. TAMIN File No. 0762nS SUBPOENA TO PRODUCE DOCtENTSWV~11LLIN11 REQUESTED FOR DISOOVERY PURSUANT TO RULE 4009.22 DR BRUCE GOODMAN, 4800 LINGLESTOWN RD #102, HARRISBURG PA 17112 TO: (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 ADDENDUM at MEDICAL LEGAL REPR0DUCTI0NS,(ATjW*sW40 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of catpliance, to the party making thi! request at the address listed above. You have the right to seek in advance she 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 thin subpoena may seek a court orde- c:ampe l l i ng you to catp l y with it. THIS SUBPOENA WAS ISSUED AT THE REMEST OF THE FOLLOWING PERSON: NAME: r-RORnE-R IFAT.T, .R JR, ESQ ADDRESS: 10 E R-LGH ST TELEPHONE : CARLISLE, PA 17 013 SUPREW OOURT ID #____215-335-3212 ATTORNEY FOR : 49813 DEFENDANT M356312-01 DATE : a vo S' 1 of the 06urt BY THE COURT: P othonotary/ Jerk, Civil Division Deputy (Eff . -1/97) ADDENDUM TO SUBPOENA WILSON Vs. I No. 076205 TAMIN CUSTODIAN OF RECORDS FOR : DR BRUCE GOODMAN ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: CRAIG R WILSON ADDRESS: 919 GIBSON BLVD STEELTON PA DATE OF BIRTH: 02/20/59 SSAN: XXXXX7656 MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ l RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or u DR BRUCE GOODMAN CUMBERLAND M356312-01 * * * SIGN AND RETURN THIS PAGE 1 ?? _ ? -.?- w-W; ?. ; t ;? -?'i: c :_ : - ' t:° rrl . .. ? ,. IN. THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CRAIG R WILSON Vs. NO. 20076205 EDWARD S TAMIN , CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 GEORGE B FALLER JR, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 12. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 10/08/08 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE; PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3590 File #: M356504 By: Theresa Deni IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CRAIG R WILSON Vs. EDWARD S TAMIN No. 20076205 TO: CHRISTIAN HUGEL, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE 'DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 09/17/08 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3590 By: Theresa Deni Enc(s): Copy of subpoena(s) Counsel return card File #: M356504 CCM ALTH OF PENNSYLVANIA couNPY OF alfflE SMAND CRAIG R WILSON Vs. Fi Is No. 20076205 EDWARD S TAMIN SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 PEERLESS INSURANCE, 275 GRAND VIEW AVE STE 300, CAMP HILL PA 17011 TO: AT'T7 4 QT A 1MQ nEE.T (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 ADDENDUM at MEDICAL LEGAL REPRODUCTIONS,(AVjrasssV 40 DISSTON ST., PHILA., PA You may -deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of compliance, to the party making thin request at the address listed above. You have the right to seek in advance the rea.onabl,- cost of preparing the copies or producing the things sought. If you fail to produce the documents or (20) days after its service, the party carpe l l i ng you to camp l y with it. things required by this subpoena within twenty serving thin subpoena may seek a court ordei- THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: GEORGE B FALLER JR, ESQ ADDRESS: TELEPHONE : CARLISLE, -PA--17013 SUPREME OOURT ID "# 215 - 3 3 5- 3 212 ATTORNEY FOR : 4 9 813 DEFENDANT M356504-01 DATE: eal of the Court BY THE COURT: Prot tary/C1 Ci i1 Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA CRAIG R WILSON Vs. No. 20076205 EDWARD S TAMIN CUSTODIAN OF RECORDS FOR: PEERLESS INSURANCE ANY AND ALL INSURANCE RECORDS AND INFORMATION PERTAINING TO THE INSURED, ALLEN KENYON, CLAIM NUMBER, 902518980. PERTAINING TO: NAME: ALLEN KENYON ADDRESS: 2459 RIVER RD APT 2 MIDDLETOWN PA DATE OF BIRTH: 12/01/57 SSAN: XXXXX CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ J RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ J NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or PEERLESS INSURANCE CUMBERLAND M356504-01 * * * SIGN AND RETURN THIS PAGE * * * p y> t? IVA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILSON Vs. NO. 076205 TAMIN CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 GEORGE B FALLER JR, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 10/14/08 File #: M356727 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3336 By: Linda Morson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY WILSON Vs. TAMIN No. 076205 TO: CHRISTIAN HUGEL, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 09/23/08 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 By: Linda Morson Enc (s) : Copy of subpoena(s) Counsel return card File #: M356727 4 ap A= OF pFIdVSYLVANIA OOUNry OF m WILSON Vs. TAMIN File No. 07620s JNTS OR THINGS SUBPOENA TO PRODUCE O=11 FOR D190d1/ERY PURSUANT TO RULE 4009.22 EDGEWATER PSYCHIATRIC CTR, 2421 N FRONT ST, HARRISBURG PA 17110 ?? ATTNi MR-P-1C-A-1-R-ECOR-nS L1EPT (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 ADDENDUM at MEDICAL LEGAL REPRODUCTIONS,(AVJFssS*940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of cap1iance, to the party making thi request at the address listed above. You have the right to seek in advance the reasonablc- 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 thin subpoena may seek a court order oampe l l i ng you to comp 1 y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: GEORGE 8 FATTER JR, ESQ ADDRESS: TELEPHONE : CARLISLE, PA 17 013 SUPREME COURT ID #215 - 3 3 5- 3 212 ATTORNEY FOR : 4$813 DEFENDANT BY THE COURT: M356727-01 DATE : '" Z- -, -a Z. ;?or eal of the Court Prothonotary/Clerk, Civil Division/-- (14 &4dj= 61, 2a,:?A All "-/" Deputy (Eff. 7/9T) 4 ADDENDUM TO SUBPOENA WILSON Vs. No. 076205 TAMIN CUSTODIAN OF RECORDS FOR: EDGEWATER PSYCHIATRIC CTR ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: CRAIG R WILSON ADDRESS: 919 GIBSON BLVD STEELTON PA DATE OF BIRTH: 02/20/59 SSAN: XXXXX7656 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as 'custodian of records that, to the best of my knowledge; information and belief all documents or things above mentioned have beer, produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or EDGEWATER PSYCHIATRIC CTR CUMBERLAND M356727-01 * * * SIGN AND RETURN THIS PAGE * * * . . .. CONMJN?H OF PENHdMVANIA COON TY OF CL1 WILSON ' Vs. File No. n71;2n-C; TAMIN SUBPOENA TO PRODUCE DOCUMENT'S OR THINGS FOR DISCOVERY PURSUANT TO R LE 4009.22 TO: CASE MANAGEMENT UNIT, 1100 S CAMERON ST, HARRISBURG PA 17104 (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 ADDENDUM at MEDICAL LEGAL REPRODUCTIONS,( sy4940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of ca, liance, to the party making thi: request at the address listed above. You have the right to seek in advance the reaeonablc- 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 thin subpoena may seek a court order campe l l ing you to omp 1 y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: GEORGE A FAT T FR JR, ESQ ADDRESS: TEELEPHONE : CARLISLE, PA 17 013 SUPREME COURT ID # 215-335-3212 ATTORNEY FOR: 49Ri3 DEFENDANT BY THE COURT: M356727-02 DATE : 4a"4, At, 2 eyy goal of the court T-Prothonotary/ lark, Civil Division/' Deputy (Eff. 7/9T) 1 • J M. ADDENDUM TO SUBPOENA WILSON Vs. No. 076205 TAMIN CUSTODIAN OF RECORDS FOR: CASE MANAGEMENT UNIT ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: CRAIG R WILSON ADDRESS: 919 GIBSON BLVD STEELTON PA DATE OF BIRTH: 02/20/59 SSAN: XXXXX7656 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or CASE MANAGEMENT UNIT CUMBERLAND M356727-02 * * * SIGN AND RETURN THIS PAGE * * * 1.;., :.?: ; r.. ., . ? ?% _ ,? v -?,-r; ,?,_? • n ..g, W ? ? -e?y .A? pp ?? Y? y F:\F1LES\CUeatA3090 Travelers)Curtnar1862\3090.862.Pra.Settle.wpd Created: 03/07/00 09:48:31 AM Revised: 06/09/09 02:08:39 PM Christian C. Hugel, Esquire I.D. No. 76062 Law Offices of Christian C. Hugel 502 Market Street Lemoyne, PA 17043 (717) 737-5255 Attorney for Plaintiff CRAIG R. WILSON, Plaintiff V. EDWARD S. TAMIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-6205 CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly mark the above-referenced matter as settled, discontinued and ended with prejudice. Dated: June J 0 , 2009 LAW OFFICES OF CHRISTIAN C. HUGEL By Christian C. Hugel, Esquire I.D. No. 76062 502 Market Street Lemoyne, PA 17043 (717) 737-5255 Attorney for Plaintiff Craig R. Wilson a' . . CERTIFICATE OF SERVICE I, Melissa A. Scholly, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Praecipe to Settle, Discontinue and End was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Christian C. Hugel, Esquire 502 Market Street Lemoyne, PA 17043 MARTSON LAW OFFICES By: Melissa A. Scholly Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: June 12, 2009 I ,1 Fl1?i}-Cr?? E OF THE PROTHONOTARY 2004 JUN 12 Dili 11: 5 9