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HomeMy WebLinkAbout01-6255 DORA L. MOORE and ALPHONSO MOORE, SR., Wife and Husband Plaintiffs V, JOSEPH M. UHRINEK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LOCAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 {717) 249-3166 DORA L. MOORE and : ALPHONSO MOORE, SR., : Wife and Husband : : Plaintiffs : _. JOSEPH M. UHRINEK : : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe romar accion dentro de los proximos veinte (20) dias despues de la notificacion 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 mas 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 O NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 DORA L. MOOR]~ and : ALPHONSO MOOR~, SR., : Wife and Husband : : Plaintiffs : V, ., : JOSEPH M. UHRINEK : : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COMPLAINT AND NOW, comes the Plaintiffs, DORA L. MOORE and ALPHONSO MOORE, SR., by and through their attorneys, SCHMIDT, RONCA & KRAMER, P.C., and respectfully set forth as follows: 1. Plaintiffs are adult individuals currently residing at 4462 Adsall Drive, Woodbridge, Virginia 22193. 2. Defendant Joseph M. Uhrinek is an adult individual currently residing at 50 Pine Ridge Circle, Enola, Cumberland County, Pennsylvania, 17025. 3. The facts and occurrences hereinafter stated took place on or about May 26, 2000 at approximately 8:50 a.m., at the intersection of Routes 11 & 15 and Valley Road in East Pennsboro Township, Cumberland County, Pennsylvania. 4. At the aforementioned time and place, it was daylight, the road surface was dry, and there were no adverse weather conditions. 5. At the aforementioned time and place, Plaintiff Dora Moore was a passenger in a 1994 Chevrolet Blazer being operated by Joseph Ragland, and was stopped at a red traffic signal on Routes 11 & 15 at the intersection with Valley Road. 6. At the aforementioned time and place, Defendant Joseph Uhrinek was the owner and operator of a 1992 Toyota and was traveling directly behind the Ragland vehicle. 7. At the aforementioned time and place, Defendant Uhrinek failed to notice the stopped Ragland vehicle, and collided with the rear of the Ragland vehicle in which Plaintiff Dora Moore was a passenger. 8. The collision between the two vehicles caused the injuries to Plaintiff Dora Moore set forth below. COUNT I DORA L. MOORE v. JOSEPH M. UHRINEN NEGLIGENCE 9. Paragraphs 1 through 8 of the Plaintiffs' Complaint are incorporated herein by reference and made a part thereof as if set forth in full. 10. The accident was caused solely by the negligence and carelessness of Defendant Uhrinek, and was in no way caused or contributed to by Plaintiff Dora Moore. 11. The negligence and carelessness of Defendant Joseph Uhrinek consisted of the following: inattentiveness; driving too fast for conditions; operating his vehicle at an excessive rate of speed under the circumstances; failing to have his vehicle under proper and adequate control; failing to apply his brakes in time to avoid the collision with the Ragland vehicle; negligently applying the brakes; failing to observe the Ragland vehicle lawfully on the highway; failing to operate his vehicle in accordance with existing traffic conditions and traffic controls; 2 failing to keep a reasonable lookout for other vehicles lawfully on the roadway; and operating his vehicle so as to create a dangerous situation for other vehicles on the roadway. 12. As a direct and proximate result of the accident, Plaintiff Dora Moore suffered severe and what are believed to be permanent injury, which include the following: a. Lumbar strain; b. Trapezius strain; c. Low back pain; and d. Numbness in hands. 13. As a direct and proximate result of the accident, Plaintiff Dora Moore has incurred medical expenses to date and may continue to incur medical expenses into the future, and thus, a claim for these expenses is made. 14. As a direct and proximate result of the injuries sustained in the motor vehicle accident, Plaintiff Dora Moore has been advised and, therefore avers, that the aforementioned injuries may be permanent in nature and effect and, thus, a claim for these injuries is made. 15. As a direct and proximate result of the injuries sustained in the motor vehicle accident, Plaintiff Dora Moore has undergone in the past, and will continue to undergo in the future, great pain and suffering, and thus, a claim for these losses is made. 16. As a direct and proximate result of the injuries sustained in the motor vehicle accident, Plaintiff Dora Moore has been obliged to spend various sums of money and to incur various expenses for the injuries that he has suffered, and may continue to incur the same in the future, and thus, a claim for these losses is made. 3 17. As a direct and proximate result of the injuries sustained in the motor vehicle accident, Plaintiff Dora Moore suffered a permanent diminution of her ability to enjoy life and life's pleasures, and thus, a claim for these losses is made. 18. As a direct and proximate result of the injuries sustained in the motor vehicle accident, Plaintiff Dora Moore suffered a loss of earnings and an impairment of her earning power and capacity, and thus, a claim for these losses is made. WHEREFORE, Plaintiff Dora Moore demands judgment on the Defendant, Joseph Uhrinek, in an amount in excess of Thirty-Five Thousand ($35,000.00) Dollars and in excess of an amount requiring compulsory arbitration. COUNT II DORA L. MOORE v. JOSEPH M. UI-I~_~N~' PUNITIVE DAMAGR~ 19. Paragraphs 1 through 18 of the Plaintiffs' Complaint are incorporated herein by reference and made a part hereof as if set forth in full. 20. It is believed and therefore averred that Defendant Joseph M. Uhrinek was operating his vehicle under the influence of alcohol or drugs. 21. Defendant Joseph M. Uhrinek's actions, conduct, and negligence set forth above display a wanton and reckless indifference to the health, safety, rights, and interests of others. 22. Defendant Joseph M. Uhrinek's egregious behavior and outrageous conduct was a direct and proximate cause of the aforementioned accident and injuries to the Plaintiff. 4 WHEREFORE, Plaintiff Dora Moore demands punitive damages against Defendant Joseph Uhrinek in an amount in excess of Thirty-Five Thousand ($35,000.00) Dollars and in excess of an amount requiring compulsory arbitration. COUNT III ALPHONSO MOORE~ SR. v. JOSEPH M. U'HRINEK LOSS OF CONSORTIUM 23. Paragraphs 1 through 22 are incorporated herein by reference as though set forth in full. 24. As a direct and proximate result of Defendant Uhrinek's negligence, the Plaintiff, Alphonso Moore, Sr., has been forced to incur the loss of society, companionship and services of his wife, Plaintiff Dora Moore. 25. The Plaintiff, Alphonso Moore, Sr., will continue to incur the same losses in the future, and thus, a claim for these past and future losses is made. WHEREFORE, the Plaintiff, Alphonso Moore, demands judgment on the Defendant, Joseph Uhrinek, in an amount in excess of Thirty-Five Thousand ($35,000.00) Dollars and in excess of an amount requiring compulsory arbitration. Respectfully submitted, SCHMIDT, RONCA 8s KRAMER, P.C. Scott B. Cooper, Esquire I.D. No. 70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff VERIFICATION BASED UPON PERSONAL KNOWLEDGE AND INFORMATION OBTAINED THROUGH COUNSEL We, DORA L. MOORE AND ALPHONSO MOORE, SR., verify that we are the Plaintiffs in the foregoin§ action and that the attached Complaint is based upon information which has been gathered by our counsel in the preparation of this lawsuit. The language of the Complaint, to the extent that it is based upon information which we have given to our counsel, is true and correct to the best of our knowledge, information and belief. To the extent that the contents of the Complaint is that of counsel, we relied upon counsel making this Verification. V~e understand that intentionai false statements herein are subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsifications to authorities. Date: /~--~' O ]' ~ ~, . bORA L. MOOl~ MOOm ', , ' JOSEPH B. RAGLAND : and SHARON A. RAGLAND, : Husband and Wife, : Plaintiffs : JOSEPH M. UHRINEK, : : Defendant : : DORA MOORE and : ALPHONSO MOORE, SR. : Wife and Husband, : Plaintiffs : JOSEPH M. UHRINEK, : : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2308 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6255 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED PLAINTIFFS~ RESPONSE TO PETITION OF DEFENDANT TO CONSOLIDATE CASES FOR THE PUl/POSER OF DISCOVERY AND TRIAL 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted 6. Admitted. 7. Admitted. 8. Denied as stated. The Defendant's characterization that there was minimal, if any, damage to either vehicle is specifically denied. By way of further answer, Plaintiffs' demand strict proof thereof of the Defendant to this allegation. 9. Admitted in part denied in part. It is admitted that both Plaintiffs contend they sustained various injuries as a result of the accident and their Complaints are incorporated herein by reference. By way of further answer, it is specifically denied that the aforesaid accident was a "minor accident" and strict proof is demanded from the Defendant. Plaintiffs also incorporate their response to Paragraph 8 of this Petition. Paragraph 10 is a conclusion of law to which no response is 10. required. 11. Paragraph 11 is a conclusion of law to which no responsive pleading is required. 12. Paragraph 12 is a conclusion of law to which no responsive pleading is required. By way of further answer, the Plaintiffs specifically deny that this is a ~minor accident" and demand strict proof thereof from the Defendant. 13. Paragraph 13 is a conclusion of law to which no responsive pleading is required. By way of further answer, to the extent a responsive pleading is deemed required, the Plaintiff specifically denied that consolidating both matters for trial is necessary. The Plaintiffs do not object to the cases being consolidated for the purposes of discovery, however, each Plaintiff has his or her own separate injuries. In addition, liability has not been admitted and one of the Plaintiffs was a passenger and, therefore, each Plaintiff should be entitled to have separate juries and separate proceedings determined liability and damages. The use of the same jury to hear both cases which have different injuries and damages would be prejudicial and unfair to the Plaintiffs. WHEREFORE, the Plaintiffs respectfully request this Honorable Court grant the Defendant's Petition to the extent it consolidates the proceedings for discovery, however, deny the motion to the extent it consolidates the proceedings for trial. DATE: ~/~"~ "~ By: Respectfully submitted, SCHMIDT, RONCA ~ KRAMER, P.C. Scott B. Cooper, Esquire I.D. No. 70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs CERTIFICATE OF SERVICE AND NOW, I, Tammie Lilley, hereby certify that I have this day served the foregoing Document by sending a copy of the same United States Mail, regular mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Brian N. Zulli, Esquire Nealon & Gover 2411 North Front Street Harrisburg, PA 17111 DATE: SCHMIDT, RONCA ~ KRAMER, P.C. Tammie Lill~_//'' ~ Secretary to Scott B~. Cooper, Esquire 209 State Street Harrisburg, PA 17101 (717) 232-6300 DORA L. MOORE and ALPHONSO MOORE, SR., Wife and Husband Plaintiffs V. JOSEPH M. UHRINEK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6255 Civil Term CML ACTION - LAW CERTIFICATE OF SERVICE AND NOW, this 7th day of January, 2002, I, Shawn T. Peterson, hereby certify that I have served a true and correct copy of the foregoing Plaintiffs' Interrogatories Addressed to Defendant - Set I by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Brian N. Zulli, Esquire Nealon & Gover 2411 North Front Street Harrisburg, PA 17111 SCHMIDT, RONCA & KRAMER, P.C. Shawn T. Peterson, Paralegal 209 State Street Harrisburg, PA 17101 (717) 232-6300 DORA L. MOORE and ALPHONSO MOORE, SR., Wife and Husband Plaintiffs V. JOSEPH M. UHRINEK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6255 Civil Term CIVIL ACTION - LAW CERTIFICATE OF SERVICE AND NOW, this 7th day of January, 2002, I, Shawn T. Peterson, hereby certify that I have served a true and correct copy of the foregoing Plaintiffs' First Set of Requests for Production of Documents Addressed to Defendant by depositin§ a copy of the same in the United States Mail, posta§e prepaid, at Harrisburg, Pennsylvania, addressed to: Brian N. Zulli, Esquire Nealon & Gover 2411 North Front Street Harrisburg, PA 17111 SCHMIDT, RONCA ~ KRAMER, P.C. Shawn T Peterson, Paralegai 209 State Street Harrisburg, PA 17101 (717) 232-6300 DORA L. MOORE and : ALPHONOSO MOORE, SR., : Wife and Husband, Plaintiffs Ve JOSEPH M. UHRINEK, Defendant IN TH COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6255 CIVIL TERM CIVIL ACTION-LAW ANSWER AND NOW, comes the Defendant, Joseph M. Uhrinek, by and through his attorneys, Nealon & Gover, P.C., and respectfully avers the following: 1. Admitted upon information and belief. 2-4. Admitted. 5. Admitted upon information and belief. 6. Admitted. 7.-8. Denied pursuantto 1029(e). COUNT I DORA L. MOORE v. JOSEPH M. UHRINEK NEGLIGENCE 9. Paragraphs 1-8 of Defendant's Answer are incorporated herein by reference and made part hereof as if fully set forth. 10.-11. These paragraphs state a conclusion of law to which no responsive pleading is required. However, if any of these paragraphs are deemed factual, it is hereby denied pursuant to 1029(e) and specific proof is demanded at trial. 12.-18. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of these averments and specific proof is demanded at trial. COUNT II DORA L. MOORE v. JOSEPH M. UHRINEK PUNITIVE DAMAGES 19. Paragraphs 1-18 of Defendant's Answer ara incorporated herein by reference and made part hereof as if fully set forth. 20. Denied. Defendant Joseph M. Uhrinek was not operating his vehicle under the influence of alcohol or drugs. 21-22. These paragraphs are a conclusion of law to which no responsive pleading is required. However, if any averments within these paragraph is deemed factual, it is denied pursuant to 1029(e). WHEREFORE, Defendant, Joseph M. Uhrinek demands this count be dismissed. COUNT III ALPHONSO MOORE, SR. v. JOSEPH M. UHRINEK LOSS OF CONSORTIUM 23. Paragraphs 1-22 of Defendant's Answer are incorporated herein by referenced and made part hereof as if fully set forth. 24.-25. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of this averment and specific proof is demanded at trial. WHEREFORE, Defendant Joseph M. Uhrinek, demands this Complaint be dismissed. Date: By: Respectfully submitted, NEALON & GOVER, P.C. Attorney I.D No. 85948 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 VERIFICATION I, JOSEPH M. UHRINEK, verify that the statements made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: CERTIFICATE OF SERVICE AND NOW, this 8th day of January, 2002 I hereby certify that I have served the foregoing Answer on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Scott B. Cooper, Esquire SCHMIDT, RONCA & KRAMER, P.C. 209 State Street Harrisburg, PA 17101 Brian N. Zulii, Es~ re~ JOSEPH B. RAGLAND, and SHARON A. RAGLAND, Husband and wife, Plaintiffs JOSEPH M. UHRINEK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2308 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED DORA L. MOORE and ALPHONSO MOORE, SR., Wife and Husband, Plaintiffs JOSEPH M. UHRINEK, Defendant IN TH COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6255 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED PETITION OF DEFENDANT, JOSEPH M. UHRINEK, TO CONSOLIDATE CASES FOR THE PURPOSES or DISCOVERY AND TRIAl 1. On May 17, 2001, Plaintiff, Joseph B. Ragland and Sharon A. Ragland commenced a civil action against Joseph M. Uhrinek, Docket No. 01-2308, in the Court of Common Pleas of Cumberland County, Pennsylvania. 2. On November 1, 2001, Dora L. Moore and Alphonso Moore, Sr., commenced a civil action against Joseph M. Uhrlnek, Docket No. 01-6255, in the Court of Common Pleas of Cumberland County, Pennsylvania. 3. Both actions arise out of a motor vehicle accident that occurred on or about May 26, 2000, at approximately 8:50 a.m. at the intersection of Routes 11 and 15 and Valley Road in East Pennsboro Township, Cumberland County, Pennsylvania. 4. At the aforesaid time and place, Plaintiff, Joseph Ragland, was operating a 1994 Chevrolet Blazer and was stopped at a red traffic signal on Routes 11 and 15 at the intersection with Valley Road. 5. At the same time and place, the Plaintiff, Dore L. Moore, was a passenger in the vehicle being driven by Joseph Ragland. 6. At the same time and place, Defendant, Joseph Uhrinek, was the owner and operator of a 1992 Toyota which was traveling directly behind the Ragland vehicle. 7. The front of the Uhrinek vehicle came in contact with the rear of the Ragland vehicle. 8. There was very minimal, if any, damage to either vehicle. 9. Both Plaintiffs, Dora Moore and Joseph Ragland, contend they sustained various personal injuries as a result of the aforesaid minor accident. 10. Pa.R.C.P. 213(a) provides in pertinent part: "In actions pending in a county in which involve a common question of law or fact or which arise from the transaction or occurrence, record on its own motion or the motion of any party may order a joint hearing or trial of any matter an issue in the actions, may order the actions consolidated, and may make orders that avoid unnecessary delay or costs." 11. Both actions arise out of the same "occurrence" as they both arise out of the aforesaid motor vehicle accident. 12. Both actions involve question of fact, namely whether the minor accident caused sufficient forces to injure either of the Plaintiffs. 13. Consolidation of the matters for tria! would conserve judicial resources as only one trial would be necessary. WHEREFORE, Defendant, Joseph Uhrinek, urges this Honorable Court to consolidate the above-captioned actions for the purposes of discovery and trial. Respectfully submitted, Date: I NEALON & GOVER, P.C. Brian N Zulli, Esq~re Attomey I.D. No. 85948 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 CERTIFICATE OF SERVICF AND NOW, this 21st day of December, 2001, I hereby certify that I have served the foregoing Petition of Defendant to Consolidate Cases on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Scott B. Cooper, Esquire SCHMIDT, RONCA & KRAMER, P.C. 209 State Street Harrisburg, PA 17101 Brian N. Zulli, Esqulre JOSEPH B. RAGLAND and SHARON A. RAGLAND, Husband and wife, Plaintiffs JOSEPH M. UHRINEK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2308 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED DORA L. MOORE and ALPHONSO MOORE, SR. Wife and Husband, Plaintiffs JOSEPH M. UHRINEK, Defendant IN TH COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6255 CIVIL TERM J J// CIVIL ACTION - LAW JURY TRIAL DEMANDED RULE TO SHOW CAUSE AND NOW, this /.~'~' day of ~ .... -/- ,200 ~, upon consideration of the Petition of Defendant to consolidate the above-captioned actions, it is hereby ordered and decreed that Rule is issued upon both Plaintiffs to show cause, if any, that they may have as to why the requested relief should not be granted. Rule returnable ~C~ days after service. By the Court: DORA L. MOORE and ALPHONSO MOORE, SR., Wife and Husband Plaintiffs JOSEPH M. UHRINEK Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6255 Civil Term CML ACTION - LAW CERTIFICATE OF SERVICE AND NOW, this 24th day of April, 2002, I, Shawn T. Peterson, hereby certify that I have served a true and correct copy of the foregoing Plaintiffs' Responses to Defendant's Request for Production of Documents - First Request by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Brian N. Zulli, Esquire Nealon & Gover 2411 North Front Street Harrisburg, PA 17111 SCHMIDT, RONCA/k KRAMER, P.C. Shawn T. Peterson, Paralegal 209 State Street Harrisburg, PA 17101 (717) 232-6300 JOSEPH B. RAGLAND and SHARON A. RAGLAN'D, Husband and Wife, Plaintiffs JOSEPH M. UHRINEK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2308 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED DORA MOORE and ALPHONSO MOORE, SR. Wife and Husband, Plaintiffs JOSEPH M. UHRINEK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6255 CIVILTERM / CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE OF Plaintiffs, intend 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. Respectfully submitted, 8CllMIDT, ItOI~CA es R:RA,MER P.C. Scott B. Cooper, Esquire I.D. # 70242 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs JOSEPH B. RAGLAND and SHARON A. RAGLAND, Husband and Wife, Plaintiffs JOSEPH M. UHRINEK, Defendant DORA MooRE and ALPHONSO MOORE, SR. Wife and Husband, Plaintiffs JOSEPH M. UHRINEK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2308 CML TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6255 CML TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUM~BrT8 OR TLFrBrc_"_ FOR DISCOVeRy IPO~__SUANT TO RULE Silvia Didia, M.D. 2645 North Third Street Harrisburg, PA 17110 Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things at the law offices of SCHMIDT, RONCA & KRAMER, P.C., 209 State Street, HarriSburg, PA 17101: Any and all prescriptions or records which would indicate medications prescribed to Joseph M. Uhrinek within one (1) year prior to the accident on May 26, 2000. 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: Scott B. Cooper, Esquire SCHMIDT, RONCA & KRAMER, P.C. 209 State Street, Harrisburg, PA 17101 (717) 232-6300 Supreme Court I.D. #: 70242 Attorney for Plaintiffs DATE: Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Division Deputy JOSEPH B. RAGLAND and SHARON A. RAGLAND, Husband and Wife, Plaintiffs V. JOSEPH M. UHRINEK, Defenrl~nt DORA MOORE and ALPHONSO MOORE, SR. Wife and Husband, Plaintiffs V. JOSEPH M. UHRINEK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2308 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DI~IM&NDED IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6255 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF A~ _=!W~.~. AND NOW, this 24th day of April, 2002, I, Shawn T. Peterson, hereby certify -that I have served a true and correct copy of the foregoing Notice of Intent to Serve Supoena by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Brian N. Z~lll, Esquire Nealon & C-over 2411 North Front Street HarrisburE, PA 17111 ~cmtm~, RONCA as ~ P.C. Shawn T. Peterson, Parale~a/ 209 State Street Harr/sburg, PA 17101 (717) 232-5300 DORA L. MOORE and ALPHONSO MOORE, SR., Wife and Husband Plaintiffs V. JOSEPH M. UHRINEK Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-6255 Civil Term CML ACTION - LAW _CERTIFICATE OF SERVICi~. AND NOW, this 14th day of May, 2002, I, Shawn T. Peterson, hereby certify that I have served a true and correct copy of the foregoing Plaintiffs' Answers to Interrogatories Propounded by Defendant - First Set by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Brian N. Zulli, Esquire Nealon & Gover 2411 North Front Street Harrisburg, PA 17111 SCHMIDT, RONCA/h KRAMER, P.C. Shawn T Pet'~rson, Paralegal 209 State Street Harrisburg, PA 17101 (717) 232-6300 JOSEPH B. RAGLAND and SHARON A. RAGLAND, Husband and Wife, Plaintiffs V. JOSEPH M. UHRINEK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2308 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED DORA MOORE and ALPHONSO MOORE, SR. Wife and Husband, Plaintiffs V. JOSEPH M. UHRINEK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6255 CIVIL TERM ~ CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 20th day of May, 2002, I, Shawn T. Peterson, hereby certify that I have served a t_rue and correct copy of the foregoing Plaintiffs' First Supplemental Response to Defendant's Requests For Production Of Documents And Answers To Interrogatories by depositing a copy of the same in the United States Mail, postage prepaid, at Ha~lisburg, Pennsylvania, addressed to: Brian N. Zulli, Esquire Nealon & Gover 2411 North Front Street Harrisburg, PA 17111 SCHMIDT, RONCA 8s KRAMER, P.C. By Shawn T. Peterson, Para.legal 209 State Street Hat'risburg, PA 17' 101 (717) 232-6300 JOSEPH B. RAGLAND and SHARON A. RAGLAND, Husband and Wife, Plaintiffs V. JOSEPH M. UHRINEK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2308 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED DORA MOORE and ALPHONSO MOORE, SR. Wife and Husband, Plaintiffs V. JOSEPH M. UHRINEK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6255 CML TERM / CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 20th day of May, 2002, I, Shawn T. Peterson, hereby certify that I have served a true and correct copy of the foregoing Plaintiffs' Second Supplemental Response to Defendant's Requests For Production Of Documents And Answers To Interrogatories by depositing a copy of the same in the United States Mail, postage prepaid, at Hm~ isburg, Pennsylvania, addressed to: Brian N. Zulli, Esquire Nealon & Gover 2411 North Front Street Ha~Tisburg, PA 17111 Shawn T. Peterson, Paralegal 209 State Street Hm'~'isburg, PA 17101 (717) 232-6300 JOSEPH B. RAGLAND and SHARON A. RAGLAND, Husband and Wife, Plaintiffs V. JOSEPH M. UHRINEK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-2308 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED DORA MOORE and ALPHONSO MOORE, SR. Wife and Husband, Plaintiffs V. JOSEPH M. UHRINEK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6255 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF AND NOW, this 23rd day of May, 2002, I, Shawn T. Peterson, hereby certify that I have served a true and correct copy of the foregoing Plaintiffs' Request For Admissions And Accompanying Interrogatories (Set I) by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Brian N. Zulli, Esquire Nealon & Gover 2411 North Front Street Harrisburg, PA 17111 ~CHMIDT, RONCA & KRAMER, P.C. Shawn T. Peterson, Paralegal 209 State Street Harrisburg, PA 17101 {717) 232-6300 CERTIFICATE PREP. EQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DORA MOORE COURT OF COMMON PLEAS TERM, UHRINEK -VS- CASE NO: 01-6255 As a prerequisite to service of a subpoena for documents and thinEs pursuant to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI, 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: 07/01/2002  BR~NS on ~half-~qf // Attorney for DEFENDANT DEll-342551 9 6 489 --LO1 COIv~v~OSVw~ALTH OF PENNS~fI~VANIA COUNTY OF CUlvlBERLAND IN THE MATTER 0F: DORA MOORE UHRINEK -VS- COURT OF C0~0N PLEAS TERM, CASE NO: 01-6255 NO~ICE OF INT~N~ TO SERVE A SUBPOENA TO PRODUCE DOC~S AN~ · HINGS FOR DISCovsRY PORSUAN~ TO k,~.~ 4009.21 US OFFICE OF PERSONNEL ~. USAA CASUALTY INSURANCE CO. U.S. D~P?. OF AGRIouL~ ~B~T X. ~Z~, ~. ~. B~VOIR ~c~. C~ ~OVA ~ CRA~T.~S ~, ~. EHPLOYHENX INSURANCE ~PLOYMENT HEDICAL ~ECORDS ~4~ICAL ~ECORDS ~nICAL RECORDS M~nICAL RECORDS · O= SC01~ D. COOPER, ESQUIRE HCS on behalf of BRIAN N. ZULLI, ESq. intends to serve a subpoena identical to the one that is attached to this notice. You have t~nty (20) days fr~m the date listed belo~ in ~hich to file of record and serve upon the undersigned an objection to the subpoena. If the t-~enty day notice period is ~aived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records -~y be ordered at your expense by cwletinS the attached counsel card and returning same to HCS or by contacting our local MCS office. DATE: 06~1012002 CC.- BRIAN N. ZULLI, ESQ. - 01-179 MOS on behalf of BRTA~ N. ZULLI, ESq. Attorney for DEFENDANT Any questions regarding this m~tter, contact Tm~MCS GROUP INC. 1601 MARKET STRUT ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-189570 96489--C01 DORA L. MOORE VS JOSEPH UHRINEK COMMONWEALTH OF PENNSYLVANI.4 COUNTY OF CUMBERLAND File No. 01-6255 SU~PoO~ENA TO PRODUCE DOCUMENTS OR THING,~ . OR DISCOVERY PURSUANT TO RULE 4009.2~ TO: CUSTODIAN OF RECORDS FOR: US OFFICE OF PERSONNEL Mi~GMT. (Name of Pennon or Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following document~ or things: SEE ATTACHED at MCS GROUP INC.~ 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA 19103 (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 th.:s subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: BRIAN ZULLI, ES(~. ADDRESS:_. 2411 NORTH FRONT STREET HARRISBURG PA 17110 TELEPHONE.. (215} 246-0900 ' SUPREME COURT ID #: AI-I'ORNEY FOR: THE DEFENDANT DATE: 07/01/2002 Seal of the Court Pmtho.notary/Clerk. Ct~I ~ivislon /~ Deputy ' EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: US OFFICE OF PERSONNEL MNGMT. C/O NATIONAL PERSONNEL 9700 PAGE BLVD. ST. LOUIS, MO 63132 RE: 96489 DORA L. MOORE ANY AND ALL MILITARY RECORDS FROM PRIMIS MILITARY LOCATED AT 1549 OLD BRIDGE RD, LAKE RIDGE, VA, 22192 Any and all employment records, files and memorandums, compensation, time and attendance records,personnel records, payroll and salary reports and all medical records as an employee. Da.t? Requested: up to and including the present. Subject :DORA L. MOORE 4462 ADSALL DRIVE, WOODBRIDGE, VA 22193 Social Security ~ 422-70-7232 Date of Birth: 06-13-1950 , SU10-379360 9 6 489 --LO1 CER?IFICATE PREKEQUISITIg TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DORA MOORE COURT OF COMMON PLEAS TERM, UHRINEK -VS- CASE NO: 01-6255 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI, 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: 07/01/2002 MCS on behalf of BRIAN N. ZULLI, ESq. Attorney for DEFENDANT DEll-342552 9 6489 --LO2 CO~i~4OS~ALTH OF PENNSYLVANIA COUNTY OF C~31~4BERLAND IN THE MATTER OF: DORA M00RE UHRINEK -VS- COURT OF C0~940N PLEAS TERM, CASE NO: 01-6255 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE T~INGS FOR DISCovz~ P~UANT TO R~A,E 4009.2i US OFFICE OF PERSONNEL USAA CASUALTY INSURANCE CO. U.S. DEPT. OF AGRICULTURE ALBERT T. V~NT~, MD. FT. BELVOIH ~ICAL CENTER INNOVA ~PLOYMENT INSURANCE EMPLOYM~NT WImXCAL RECORDS ~a~IGAL RECORDS NI~TtXCAL RECORDS N~nICAL RECORDS TO: SCOTT D. COOPER, ESQUIRE M~S on behalf of BRLqN N. ZULLI, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frc~ the date listed below in which to file of record and serve upon the ondersi~ned 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 c~e~letin$ the attached counsel card and returnin$ same to MCS or by contactin$ our local HCS office. DATE: 0611012002 CC: BRIAN N. ZULLI, ESQ. - 01-179 ~S on behalf of BRTA~ N. ZULLI, ESq. Attorney for DEI~NDANT Any questions regarding this matter, contact DE02-189570 96489--C01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DORA L. MOORE VS JOSEPH UHRINEK File No. 01-6255 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: USAA CASUALTY INSURANCE COMPANY {Name of Pe~on or Entity.) Within twenty, (20) days after service of this subpoena, you are ordered by the court to produce the following documefits or things: SEE ATTACHED ' at MCS GROUP INC. ~ 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA 19103 (Acich'~s) 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 thSs subpeen~, within twenty (20) days after i~s service, the pa~-ty ,:., .... , .... -'~- ' ~, you to comply' with it. $ e.,x'in~ t,.~ ~u~:p,~ t~ ~,a)' s:cl: ~ cou., o.,-~, compelhno THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOa, SFING PERSON: NAME: BRIAN ZULLI, ESQ. ADDRESS: 2411 NORTH FRONT STREET HARRIS BURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: THE DEFEI~rDANT 07/01/2002 DATE: ~ '~.~'q~-P BY THE COURT: Seal of the Court DEPOSITION SUBPOENA TO TESTIFY OR PRODUCE DOCUMENTS OR THINGS STATE OF TEXAS § To any Sheriff or Constable of the State of Texas or any ~r~on authorized to s~rve a subpoena under RULE 178, TEXAS RU~ ~'~ OF CIVIL PROCEDURE, GREETINGS: You ate hereby comrt~.nded to surm'non the following witness(es): USAA la~ma~e ~O00 Fredericbbur ~ ~M~o, T~ ~ (~1 to I~ end aplMer b~for~ ,. Not~? Public of my d~ignaUon for TI~MCSGROL~,INC., 1601 MARKET STREET, #800, PHILADELPHIA PA 19103 or it~ d~ign~.ted agent, on th~ forthwith d~y · certain written qu~tiona to b~ p~opounded of ~ at the offic~ of th~ custodian and th~m und~ o~th to nmka an~w~r~ of to th~ witm~ and to bring ~nd produc~ for in--on ~ pho~copy~g Aayaadallhum~a~¢~'m~b,b~J~k'dbmmll--!'~l~, ?OLICY #0~37201391C71015 A~Y AND ALL CLAIMS FTLES, A~D FIRST ?ARTY BENEFITS. and any oth~' such r~cord in th~ i~c~m~ion, cu~tmiy or control of ' · ' th~ ~d w~mu~, and ~vss7 such record to which th~ wi~ haw~cc~,l~vt~ningto:. DORA L. ~OORE, 4462 ADSALL DRTVE, ~OODBRIDGE VA 22193 SOCTAL SECURITY # ~22-70-7232 DATE OF BTRT~: 06/13/].950 · DATE OF LOSS: 05/26/2000 , i~ndmg on th~ dock~ of th~ CL~BERLAND COUNTY COURT OF ¢O~ION PLF./~S Thi- subpoena is issued undo' and by virtu~ of ,.utho~ty of *, notic~ duly ~ ~d on ~ with th~ ~bov~ ~ court, styled DORA MOORE vi. UHRINEK And there r~.mifl from d~y to ddty mM time to timo urtf~ dischm. Ko according to low. wrrNESS MY ItAND, ~ ~ ,~20 NOTARY PUBLIC OFFICI~'S REFURN lt~d ~l. diy of ,2L. dayof , a true copy hereof. ; 20--., EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: USAA CASUALTY INSURANCE CO. 9800 FREDERICKSBURG ROAD SAN ANTONIO, TX 78288 RE: 96489 DORA L. MOORE POLICy # 007201391C71015, FIRST PARTY BENEFITS Any and all claims files. Dates Requested: up to and including the present. Subject: DORA L. MOORE 4462 ADSALL DRIVE, WOODBRIDGE, VA 22193 Social Security ~ 422-70-72:32 Date of Birth: 06-1:3-1950 Date of Loss: 05/26/2000 · SU10-379362 96489--L02 CERTIFICATE PP-EREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DORA MOORE UHRINEK -VS- COURT OF CO~40N PLEAS TERM, CASE NO: 01-6255 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI, 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:..07/01/2002 MCS on behalf of BRIAN N. ZULLI, Esq. Attorney for DEFENDANT DEll-342553 9 6489 --LO 3 COI~I~05Vwq~ALTH OF PENNSi'I. VANIA COUNTY OF CUPIBERLAND IN THE MATTER OF: DORA MOORE UHRINEK -¥S- COU~T OF CO~ON PLEAS TERM, CASE NO: 01-6255 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO ~ US OFFICE OF PKRSOI~t. I~JGMT. USAA CASUALTY INSURANCE CO. U.S. DEPT. OF AGRIC0t.T~RE ALBKRT T. VKNTZKK, ND. FT. BELVOIR ~nlCAL CENTER [NNOVA UEgAB CWaUr-~S AZZAM, MD. ~PLOY~HT INSURANCE EMPLOYMENT HKDICAL RECORDS ~ICAL RKCORDS ~mlCAL RECORDS ~mlCAL RECORDS TO: SCOTT D. COOPER, ESQUIRE HCS on behalf of BRIAN N. ZULLI~ ESq. ~ntende to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below ~n 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 nmde, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by cmspletinS the attached counsel card and return/nS same to HCS or by contact~nS our local MCS office. DATE: 0611012002 CC: BRIAN N. ZULLI, ESQ. - 01-179 MDS on behalf of B~TA~' N. ZULLI~ ESq. Attorney for DEFgNDANT Any questions regarding this hatter, contact THEN CS GROUP INC. 1601NARKET SI~T ~800 PHILADKLPH~LA, PA 19103 (215) 246-0900 DE02-189570 96489--C01 DORA L. MOORE VS JOSEPH UHRINEK .COMMON-WEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. 01-6255 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.27 TO: CUSTODIAN OF RECORDS FOR: U.S. DEPT. OF AGRICULTURE INarne of Pewon or Ent'i .fy) Within i'Wenty (20) days aher service of this subpoena, you are ordered by the cour~ to produce the following documents or things: ' S~.E ATTACHED at MCS GROUP INC. 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA 19103 {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 patty 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 tau to produce the doc:,men~s ct things required by th;~ s',.'bpe,~n~, within twenty (20) days Mter its se~ice, th~ p~-~y o t ..... ~,b~.- ~ a tiaa)' $2¢k a cou.-: order compelllngyou to comply' with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLO~,~FING PERSON: NAME: _ BRIAN ZULLI, ESQ. ADDRESS:.. 2411 NORTH FRONT STREET HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: THE DEFENDANT DATE: __ 07/01/2002 Seal of the Cou~ EXPLANATION OF REQUIRF, D RF CORDS TO: CUSTODIAN OF RECORDS FOR: U.S. DEPT. OF AGRICULTURE 14TH & INDEPENDENCE AVE. ROOM 8-E S.W. WASHINGTON, DC 20250 RE: 96489 DORA L. MOORE Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dar.es Requested: up to and including the present. Subject :DORA L. MOORE 4462 ADSALL DRIVE, WOODBRIDGE, VA 22193 Social Security g:. 422-70-7232 Date of Birth: 06-13-1950 SU10-379364 9 6 489 --LO 3 CER?IFICA?E PRglIIgqUI$I?E TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DORA MOORE COURT OF COMMON PLEAS TERM, UHRINEK -VS- CASE NO: 01-6255 As a prerequisite to service of a subpoena for documents and thin§s pursuant to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI~ 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: 07/01/2002 MCS on behalf of BRIAN N. ZULLI, ESq. Attorney for DEFENDANT DEll-342554 9 6 489 --LO 4 CO~05Vw-t~ALTH OF PENNS~q--VANIA COUNTY OF ClJ~4BERLAND IN THE MATTER OF: DORA MOORE UHRINEK -VS- COURT OF COlOrON PLEAS TERM, CASE NO: 01-6255 DISCOVERY p~ US OFFICE OF PERSONNEL HNGHT. USAA CASUALTY INSURANCE CO. U.S. DEPT. OF AGHICu,.xu~ ALBnT T. v~rfZ~, MD. FT. BELVOIR ~ICAL CENTER INNOVA RENAB C~Am~.ES AZZAH, HD. m Lo swr INSURANCE EMPLOYMENT Mlt'nICAL RECORDS MEDICAL RECORDS MI~nICAL RECORDS I~VICAL RECORDS TO: SCOTT D. COOPER, ESQUIRE MCS on behalf of BRIA~ N. ZULLI, 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 ~hich to file of record and serve upon the undersigned an objection to the subpoena. If the t~e~ty 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 cc~pletin8 the attached counsel card and returnin$ sA--- to HCS or by contactin8 our local HCS office. - D~I'E: 0611012002 CC: BRIAN N. ZOLLI, ESQ. - 01-179 MS on behalf of BRIAN N. ZULLIr ESq. Attorney for D~,~DANT Any questions regarding this matter, contact THK MCS GROUP INC. 1601 MA~T SI~'T #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-189570 96489--C01 DORA L. MOORE VS JOSEPH UHRINEK COMMON-WEALTH OF PENNSYLVANLk COUNTY OF CUMBERLAND - File No. 01'6255 SUBPOENA TO PRODUCE DOCUMENT5 OR THING:, FOR DISCOVERY PURSUANT TO RULE 4009.?~ TO: CU.~STODIAN OF RECORDS FOR: ALBERT T. VENTZEK, M.D. IName of Pemon ar Enti~) Within tWenty, (20) days after service of this subpoena, you are ordered bv the court to pro~[uce the following documents or things: SEE ATTACHED at . MCS GROUP INC.~ 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA 19103 (A-~.~) 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 doc~ments or things required by th~s subpeena, within twenty (20) days after its service, th~ p~-ty - ~-- ~ n~a)' sick a cou.-t orde: compelling you to coalply whh it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLO~4FING PERSON: NAME: BRIAN ZULLI~ ESQ. ADDRESS:__ 2411 NORTH FRONT STREET HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: Aq-FORNEY FOR: THE DEFENDANT DATE: 07/01/2002 -- y~---~ ~ Seal of the Court COURT: P.~othonot~l'?/Cler.¢. Civ~visio~ / EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ^IRERT T. VENTZEK, MD. 2000 OPITZ BLVD. WOODBRIDGE, VA 22191 RE: 96489 DORA L. MOORE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates .,Re. quested: upto and including the present. Subject .DORA L. MOORE 4462 ADSALL DRIVE, WOODBRIDGE, VA 22193 Social Security & 422-70-7232 Date of Birth: 06-13-1950 SU10-379366 9 6 489 --LO 4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DORA MOORE UHRINEK -VS- COURT OF COMMON PLEAS TERM, CASE NO: 01-6255 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI, 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: 07/01/2002 MCS on behalf of BRIAN N. ZULLI, Esq. Attorney for DEFENDANT DEll-342555 9 6 489 --LO5 COI~fl~ON-w~ALTH OF PENNSYLVANIA COUNTY OF Cr31VfBERLAND IN THE MATTER OF: DORA MOORE UHRINEK -VS- COURT OF COMMON PLEAS TERM, CASE NO: 01-6255 NO~ICE O~F~N~_N~__~'~. SERVE ,~..S~UB~I~___E~_ ~0 PRODUCE ~ 'AND '£~ FOl~ DISCOVERY ~ US OFFICE OP PERSONNEL ~GNT. USAA CASUALI-f INSURANCE CO. U.S. DEPT. OP ASEI~unru~ ALBERT X. VENTZP:~, HD. FT. BELVOIR HEDICAL CENTL~ XNMOVA CRART-I~S AZZA]t, HD. XNSURANCE EHPLOYHENT ~a'nICAL RECORDS IqRllXCAL RECORDS I'm*nICAL RECORDS bk-XCAL RECORDS 1~: SC01~ D. COOPER, ESQUIRE HCS on beh-lf of Be?A~ N. ZULLI~ ESq. intends to serve a subpoena identical to the one that is attached to this notice. You have t~nty (20) days rrm the date listed belo~ in ~hich to file of record end serve upon the undersigned an objection to the subpoena. If the t~nty day notice period is ~mived or if no objection is ~ade, then the subpoena may be served. Cmsplete copies of any reproduced records may be ordered at your expense by c~.-~letin$ the attached counsel card and returning sa~e to ~CS or by contacting our local HC$ office. D~TE: 0611012002 CC: BItXAN N. ZULLI, ESQ. - 01-179 MCS un behalf of BRTA~ N. ZULLI, ESq. Attorney for D~oANT Any questions regarding this matter, contact T~CS GROUP INC. 160IHARKET SI~T ~800 PHXLADELPHXA, PA (215) DE02-189570 96489--C01 DORA L. MOORE VS JOSEPH UHRINEK COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. 01-6255 SUBPOENA TO PRODUCE DOCUMENTS OR THING£ FOR DISCOVERY PURSUANT TO RULE 4009_~ TO: CUSTODIAN OF RECORDS FOR: FT. BELVOIR MEDICAL CENTER INane of Pe~on or En~ty.~ · Within rwenrv ('~0) days after service of this subpoena, you are ordered bv the court to produce the following documents or SEE ATTACHED at . MCS GROUP INC., 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA 19103 (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, th~ p~-ty - ..~ ,v~z~ a n~a~, s:¢,~ a co'..':,' orde: compelling you to comply wi~h it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: _. BRIAN ZULLI, ESC~. ADDRESS: 2411 NORTH FRONT STREET HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: A]-I'ORNEY FOR: THE DEFENDANT D ATE: 07/01/2002 Seal of the Cou~ EXPLANATION OF REQUIRED R CORDS TO: CUSTODIAN OF RECORDS FOR: FT. BELVOIR MEDICAL CENTER 9501 FARRELL ROAD FT. BELVOIR, VA 22060 RE: 96489 DORA L. MOORE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. sDuates Requested: up to and including the present. bject: DORA L. MOORE 4462 ADSALL DRIVE, WOODBRIDGE, VA 22193 Social Security ~ 422-70-7232 Date of Birth: 06-13-1950 SU10-379368 9 6 489 --LO 5 CERTIFICATE PREREQUISITE TO SERVICE 0P A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DORA MOORE COURT OF CO}940N PLEAS TERM, UHRINEK -VS- CASE NO: 01-6255 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI, 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: 07/01/2002 MCS on behalf of BRIAN N. ZULLI, ESq. Attorney for DEFENDANT DEll-342556 9 6 489 --LO 6 COI~IPIOI~I~t~ALTH OF PENNSYLVANIA COUNTY OF CUlVlBERLAND IN THE MATTER OF: DORA M00RE UHRINEK -VS- COURT OF C0~40N PLEAS TERM, CASE NO: 01-6255 NOTICE OF INTENT TO SERVE A SUBPORw~ TO PPODUCE · I'ItINGS FOR DISCovKR~ PiJ~UAI~ TO RULE 4009.2] US OFFICE OF ,PERSONNEL MNGM~. USAA CASUALTY INSURANCE CO. U.S. DEPT. OF AGRICULTORE ALBnT T. VENTZKi[, MD. FT. BKLVOIE J~DICAL CENTER INNOVA REHAB CRamT.eS AZZAH, HD. TO: SCOTT D. COOPER, ESQUIRE EMPLOYHKNT INSURANCE EHPLOY~NT HKDICAL R~CORDS HKDICAL RECORDS M~nICAL RECORDS H~nXCAL RECORDS HCS on behalf of BRIAN N. ZULLI, ESq. /ntends to serve a subpoena identical to the one that is attached to this notice. You have t~enty (20) days from the date listed below in which to file of record and serve upon the undersi~ned 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. Cw.plete copies of any reproduced records may be ordered at your expense by c~let~nS the attached counsel card end return/nS s,m~ to MCS or by contact/nS our local HCS office. DATE: 0611012002 CC: BRIAN N. ZULLI, ESQ. - 01-179 tiCS on behalf of BRTAq N. ZULLI~ ESq. Attorney for DEFENDANT Any questions regard/nS this matter, contact 1601MARKET STRKKT ~800 PETI~DKLPHIA, PA 19103 (215) 246-0900 DE02-189570 96489--C01 DORA L. MOORE VS JOSEPH UHRINEK COMMON'WEALTH OF PENNSYLVANL% COUNTY OF CUMBERLAND File No. 01-6255 ' SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009_er TO: CUS.____TODL~_N OF RECORDS FOR: INNOVA REHAB (Name of Pemon or Enti~) Within twenty (20) days after se.,'vice of this subpoena,you are ordered by the court to produce the following documents ot things: SEE ATTACHED at MCS GROUP INC., 1601 MARKET STREET, SUITE 800, PHILADELPHIA PA 19103 (Addr~m) 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 · servin~ t': ~ .... documents or things required by this subpoena, within twenty (20) days after its se,vice, the p,-.-ty ....... F'--~ ~ n,a)' sic',: a cou:: orde: compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLO~fING PERSON: NAME:. BRIAN ZULLI~ ESQ. ADDRESS:. 2411 NORTH FRONT STREET F~kRR I SBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: THE DEFENI)ANT DATE: . 07/01/2002 Seal of the Cou~ BY THE COURT://~ ~ P"'° t h °n °t~rT/C] erk. C~'~D~vislo~ Deputy EXPIJANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: INNOVA REHAB 9900 MAIN STREET SUITE 200-A FAIRFAX, VA 22031 RE: 96489 DORA L. MOORE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject :DORA L. MOORE 4462 ADSALL DRIVE, WOODBRIDGE, VA 22193 Social Security ~.- 422-70-7232 Date of Birth: 06-13-1950 SU10-379370 9 6 489 --LO 6 CERTIFICATE PREKEQUISITE TO SERVICE 0F A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: DORA MOORE COURT OF COMMON PLEAS TERM, UIiRINEK -VS- CASE NO: 01-6255 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BRIAN N. ZULLI~ 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: 07/01/2002 MCS on behalf of BRIAN N. ZULLI~ Esq. Attorney for DEFENDANT DEll-342557 9 6489 --LO 7 COI~I~IO~Vw~ALTH OF PENNSYLVANIA COUNTY OF CI31~IBERLAND IN THE MATTER OF: DORA MOORE UHRINEK -VS- COURT OF COI~40N PLEAS TERM, CASE NO: 01-6255 NOTICE OF INTEIFF TO SERVE A SUBPORNA TO PRODUCE ~NTS FOR DISCov~$R~ PUN~u~FF TO k~ 4009.2] US 0PFICE OF P~RSONN~L USAA CASUALTY INSURANCE CO. U.S. D~PT. 0F AGRICULTUF~ ALBERT T. VENTZ~r, MD. PT. BELVOIR ~DIC~L CENTER INNOVA REHAB TO: SCOTT D. COOPER, ESQUIRE EHPLOYHENT INSU~AI~CE EHPLOYHENT HwnICAL RECORDS ~-ICAL RECORDS lmmlCAL RECORDS I~DICAL RECORDS MCS on behalf of BRTAN N. ZULLI~ 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. C~m~lete copies of any reproduced records ~ay be ordered at your expense by cmspleting the attached counsel card and returning same to NCS or by contacting our local MCS office. DAT~: 0611012002 CC: BR?AN No ZULLI, ESQ. - 01-179 l~S on behalf of BHIANN. Z~LLIr ESq. Attorney for DEFENDANT Any questions regarding this matter, contact TI~ MCS GROUP INC. 1601MARKET STuEI~T ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-189570 96489--(2:01 COMMON'WEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DORA L. MOORE VS JOSEPH UHRINEK File No. 01-6255 SUBPOENA TO PRODUCE DOCUMENTS OR THING,c, FOR DISCOVERY PURSUANT TO RULE 4009_~o TO: CUSTODIJ_N OF RECORDS FOR: CHARLES AZZAM, M%D. (NameofPe~onorEnfi~) Withinm~en~(20) days ~terse~ice°fthissubpoena, youareorderedbvthecountoproducethefoilowingdocumentsor things: SEE ATTACHED at 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 th~ subpven~, wi~hln twenty (20) day.~ after its se~ice, the p~-ty s e.~vi::g ti~!~ ~ ub,vccnc ti:ay si~k a courl orde: compelling you to c ' ' THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLO'~FING PERSON: NAME: BRIAN ZULLI, ESQ. ADDRESS: 2/'11 NORTH FRONT STREET HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: THE DEFENDANT DATE: 07/0i/2002 Seal of the Cou~ BY THE COURT: ~//~~ P,'~,hon o~ary./Clerk. Civil EXPI ANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CHARLES AZZAM, MD. 1916 OPITZ BLVD. WOODBRIDGE, VA 22191 RE: 96489 DORA L. MOORE Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: to and including the present. Subject: DORA L.uII~IoORE 4462 ADSALL DRIVE, WOODBRIDGE, VA 22193 Social Security ~. 422-70-7232 Date of Birth: 06-13-1950 SLI10-379372 96489--L07