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Home My WebLink About07-6803?a LORY JONES, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. 0 7-&FrP 3 CIVIL TERM ALEXANDER J. WILLINGHAM, : CIVIL ACTION - LAW Defendant PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Kindly issue a writ of summons in the above-captioned action. The Defendant resides as follows: Alexander J. Willingham 6945 Wertzville Road Enola, PA 17025 ro5rs? A2 1 0 4 le. ') R. Mark Thomas, Esquire 101 S. Market Street Mechanicsburg, PA 17055 (717)796-2100 LORY JONES, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : V. :NO. 0-7-6 8'63 CIVIL TERM ALEXANDER J. WILLINGHAM, CIVIL ACTION - LAW Defendant . WRIT OF SUMMONS To: Alexander J. Willingham 6945 Wertzville Road Enola, PA 17025 You are hereby notified that Lory Jones has commenced an action against you. is ?r Prothonotary C99L d cis t? cmm CD co -a .r- cn -c? t D SHERIFF'S RETURN - REGULAR CASE NO: 2007-06803 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JONES LORY VS WILLINGHAM ALEXANDER J KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon WILLINGHAM ALEXANDER J the DEFENDANT , at 2126:00 HOURS, on the 4th day of December , 2007 at 6945 WERTZVILLE ROAD ENOLA, PA 17025 by handing to ROBERT WILLINGHAM, FATHER a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge 1 Sworn and Subscibed to before me this of So Answers: 18.00 9.60 .58 10.00 .00 38.18 day R. Thomas Kline 12/05/20" R MARK THOMAS By: A. D. r _ ?% Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com Attorneys for Defendant LORY JONES, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ALEXANDER J. WILLINGHAM, Defendant CIVIL ACTION -LAW NO. 07-7.2{rCIVIL TERM JURY TRIAL DEMANDED TO THE PROTHONOTARY: PRAECIPE PLEASE issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer judgment of non pros. ?-? , DUFFIE, STEWART & WEIDNER DATE: 119416 I tJeft Fs -on J. Shipman, E Attorneys for Defendant RULE TO: R. Mark Thomas, Esquire, 101 South Market Street, Mechanicsburg, PA 17055, Attorney for Plaintiff And now, this day of JQ!»a.r , 2008 you are hereby notified to file a Complaint within twenty (20) days of service in the above-captioned matter or a'efault judgment will be entered against you. ?y t _- "// Curtin Long, l CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on % lof R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER 4Je Wo-nYiipman, E uire I.D. #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant 321866 W `_,y Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com LORY JONES, Plaintiff V. ALEXANDER J. WILLINGHAM, Defendant TO THE PROTHONOTARY: Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW A6 NO. 07-CIVIL TERM JURY TRIAL DEMANDED PRAECIPE PLEASE enter the appearance of the undersigned on behalf of the Defendant, Alexander J. Willingham, in the above-referenced matter. JOH ON, DUFFIE, STEWART & WEIDNER J er 0,6-j. Shipman, Esquir 1. #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant DATE: / [? CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER Je rson J. Shipman, Esquire I. D #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant 321868 r- ? {' ^? - ;" _ {__ __! __ -' __i . C ., '-w LORY JONES, V. Plaintiff ALEXANDER J. WILLINGHAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-6803 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED NO CE 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 LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717)-249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans With Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. LORY JONES, Plaintiff V. ALEXANDER J. WILLINGHAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-6803 CIVIL TERM : CIVIL ACTION -LAW : JURY TRIAL DEMANDED AVISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presenter comparecencia escrita en person o por abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notification por cualquier dinero reclamado en la demands o por cualquier otra wueja o compensacion reclamados por el Demandant. USTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS DERCHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENT. SI USTED NO TIENE O NO CONOCE UN ABOGADO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717)-249-3166 LORY JONES, V. Plaintiff ALEXANDER J. WILLINGHAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6803 CIVIL TERM CIVIL ACTION -LAW JURY TRIAL DEMANDED COMPLAINT Lory Jones, by and through her counsel, R. Mark Thomas, Esquire, hereby files a complaint against the Defendant, Alexander J. Willingham, and in support thereof, respectfully represents: 1. Plaintiff, Lory Jones, is an adult individual who currently resides at 10 George Circle, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant, Alexander J. Willingham, is an adult individual whose last known address was 6945 Wertzville Road, Enola, Cumberland County, Pennsylvania. 3. On or about December 8, 2005, at approximately 4:34 p.m., Plaintiff, Lory Jones, was traveling northbound on North York Street approaching the intersection of North York Street with Heinz Street. 4. Plaintiff slowed down and stopped with her left turn signal on to turn left onto Heinz Street her car was suddenly and without warning rammed in the backside by the car being driven by the Defendant, who was also traveling northbound on North York Street, directly behind Plaintiff. 5. As a result of the collision, Plaintiff was thrown about violently within her car and suffered injuries as a result of this impact. COUNTI 6. Paragraphs 1 through 5 are incorporated herein as if set forth at length. 7. Defendant, Alexander J. Willingham, carelessly, recklessly, and negligently drove his vehicle into the rear of the vehicle being driven by Plaintiff, causing Plaintiff to suffer severe and serious injuries as will be more fully described hereinafter. 8. The carelessness, recklessness, and negligence of Defendant, Alexander J. Willingham, consisted of the following: a. Failing to have his vehicle under proper and adequate control under at the time of collision; b. Operating his vehicle in a careless and reckless manner without due regard for the rights and safety of those lawfully upon the roadway, one of whom was Plaintiff; C. Failing to observe Plaintiffs car having come to a stop with its left turn on for the purpose of making a left hand turn; d. Failing to bring his car to a stop prior to crashing into the rear of Plaintiffs car; and e. Failing to prevent a collision with Plaintiffs vehicle when there was sufficient time and space to either stop or avoid a collision with Plaintiff s vehicle. 9. By reason of the aforesaid carelessness, recklessness, and negligence of the Defendant, Plaintiff suffered severe and permanent injuries to her spinal column, back, neck, and shoulders. 10. By reason of the aforesaid carelessness, recklessness, and negligence of Defendant, Plaintiff has in the past and will in the future undergo severe pain and suffering. 11. By reason of the aforesaid carelessness, recklessness, and negligence of Defendant, Plaintiff has in the past and will in the future be unable to attend to her usual duties and occupation, all of which will be to her great financial detriment and loss. 12. In addition to the aforesaid physical injuries, Plaintiff, as a direct result of Defendant's carelessness, recklessness, and negligence has been caused to suffer loss in the form of anxiety, humiliation, frustration, loss of the feeling of well-being, limitation of activities, and loss of enjoyment of life. 13. As a further result of Defendant's carelessness, recklessness, and negligence, Plaintiff has been and will in the future be obliged to undergo medical care, to expend various sums of money, and to incur various expenses for the injuries which she has suffered. 14. As a further result of Defendant's carelessness, recklessness, and negligence, Plaintiff has and will suffer a loss of her earnings and/or impairment of her earning capacity and this loss will continue for an indefinite period of time in the future. WHEREFORE, Plaintiff prays that this Honorable Court will enter judgment in favor of Plaintiff and against Defendant in an amount that exceeds the jurisdictional amount requiring compulsory arbitration pursuant to local rule. Respectfully submitted, 4 ?e4ll P/, 9 R. Mark Thomas, Esquire Attorney No. 41301 101 South Market Street Mechanicsburg, PA 17055 Telephone: (717) 796-2100 Attorney for Plaintiff VERIFICATION I, Lory Jones, hereby verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: February /- . 2007 JA'sl,^4f " I Q - A ? Lory Js CERTIFICATE OF SERVICE I, R. Mark Thomas, Esquire, hereby certify that I have served a true and correct copy of the within document on the following person by depositing a true and correct copy of the same in the U.S. Mail at Mechanicsburg, Pennsylvania, First Class Postage pre-paid, addressed to: Jefferson J. Shipman JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Date: February 12, 2008 R. Mark Thomas, Esq. C? ? -.rs r* ? -Ti -Nsy ` y; }4 Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com (717) 761-4540 LORY JONES, Plaintiff V. ALEXANDER J. WILLINGHAM, Defendant Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 07-6803 CIVIL TERM JURY TRIAL DEMANDED NEW MATTER NOTICE TO: R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff You are hereby notified to plead to the enclosed New Matter within twenty (20) days from the date of service. JOHNSON, DUFFIE, STEWART & WEIDNER rson J. Shipm n, Esquire 4ee P.O. Box 109 Lemoyne, PA 17043 DATE: ?_/ 241 /(Or Attorneys for Defendant Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com LORY JONES, V. Plaintiff Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW ALEXANDER J. WILLINGHAM, Defendant NO. 07-6803 CIVIL TERM JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT, ALEXANDER J. WILLINGHAM AND NOW, comes the Defendant, Alexander J. Willingham, by and through his counsel, Johnson, Duffie, Stewart & Weidner, and Jefferson J. Shipman, Esquire, and files the following Answer and New Matter to Plaintiff's Complaint: 1. Admitted upon information and belief. 2. Admitted. 3. Admitted. 4 Admitted in part, denied in part. It is admitted that Mr. Willingham contacted the rear of the Plaintiffs vehicle as it was slowing or stopped. The remaining averments of Paragraph 4 are denied as stated.. 5. Denied. After reasonable investigation, Mr. Willingham is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 5 and the same are therefore denied. COUNT I 6. Mr. Willingham incorporates herein by reference his answers to Paragraphs 1 through 5 above as though fully set forth herein at length. 7. Denied. The averments contained in Paragraph 7 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. 8. Denied. The averments contained in Paragraph 8, and subparagraphs a. through e., are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. a. Denied. It is specifically denied that Mr. Willingham failed to have his vehicle under proper and adequate control; b. Denied. It is specifically denied that Mr. Willingham operated his vehicle in a careless and reckless manner without due regard for the rights and safety of those lawfully upon the roadway; C. Denied. It is specifically denied that Mr. Willingham failed to observed Plaintiff's car having come to a stop with its left turn signal on in order to make a left hand turn; d. Denied. It is specifically denied that Mr. Willingham was negligent in allegedly failing to bring his car to a stop prior to impacting the rear of Plaintiff's car; and e. Denied. It is specifically denied that Mr. Willingham was negligent in allegedly failing to prevent a collision with Plaintiffs vehicle. 9. Denied. The averments contained in Paragraph 9 are, in part, conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After reasonable investigation, Mr. Willingham is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 9 and the same are therefore denied and strict proof demanded at the time of trial. 10. Denied. The averments contained in Paragraph 10 are, in part, conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After reasonable investigation, the answering Defendant, Mr. Willingham, is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 10 and the same are therefore denied and strict proof demanded at the time of trial. 11. Denied. The averments contained in Paragraph 11 are, in part, conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After reasonable investigation, Mr. Willingham is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 11 and the same are therefore denied and strict proof demanded at the time of trial. 12. Denied. The averments contained in Paragraph 12 are, in part, conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After reasonable investigation, the answering Defendant, Mr. Willingham, is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 12 and the same are therefore denied and strict proof demanded at the time of trial. 13. Denied. The averments contained in Paragraph 13 are, in part, conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After reasonable investigation, Mr. Willingham is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 13 and the same are therefore denied and strict proof demanded at the time of trial. 14. Denied. The averments contained in Paragraph 13 are, in part, conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After reasonable investigation, Mr. Willingham is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 13 and the same are therefore denied and strict proof demanded at the time of trial. WHEREFORE, the Defendant, Alexander J. Willingham, respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. NEW MATTER 15. That the Plaintiffs alleged cause of action may be barred in whole or in part by the Pennsylvania Motor Vehicle Financial Responsibility Law and by the limited tort option. 16. That if it should be found that there was any negligence on the part of the answering Defendant, Alexander Willingham, which is denied, then in that event any such negligence was not a substantial factor nor a factual cause of the Plaintiffs alleged harm. 17. That injuries in this alleged cause of action may have been caused in whole or in part by third parties or entities not presently involved in this action. 18. That the Plaintiff's alleged injuries may have been pre-existing. WHEREFORE, the Defendant, Alexander J. Willingham, respectfully requests that judgment be entered in his favor and that Plaintiffs Complaint be dismissed with prejudice. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER Q y erson J. Shipman, Esquire Attorneys for Defendant DATE: Z? 4.4 ?fi? 321866 VERIFICATION I, Alexander J. Willingham, have read the foregoing Answer, hereby affirm that it is true and correct to the best of my personal knowledge, or information and belief. This Verifica!iori and xWement?- subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. s Alexander J. Willin am DATE: ^_ 324192 0 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on 2-12-1, Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER y ViFsoii-J. J. Shipman, Esquire I.D. #: 51785 P.O. Box 109 Lemoyne, PA 17043 321688 Attorneys for Defendant ^a r, l? Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 As@jdsw.com LORY JONES, Plaintiff V. ALEXANDER J. WILLINGHAM, Defendant Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-6803 CIVIL TERM JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 TO: R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas attached thereto, was mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoenas were sought to be served; (2) A copy of the Notice of Intent including the proposed subpoenas, is attached to this Certificate; (3) No objection to the subpoenas has been received; and (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. JO4Aftor UFFIE, STEWART WE IDNER By JShipman, Esquire I. D. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com DATE : /?toIg Attorneys for Defendant ? , y ?he? 1M '4 s 7 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, first class mail, postage prepaid, in Lemoyne, Pennsylvania, on WX?4/al R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff JOHN T FIE, STEWART WEIDNER By Jefferson J. Shipman, Esquire I.D. #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant Johnson, Duffle, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com Attorneys for Defendant LORY JONES, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ALEXANDER J. WILLINGHAM, Defendant CIVIL ACTION - LAW NO. 07-6803 CIVIL TERM JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff PLEASE TAKE NOTICE that Defendant intends to serve four (4) subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of records and serve upon the undersigned objections to the subpoenas. If no objections are made, the subpoenas may be served. JOHNS UFFIE, STEWART & EIDNER By Jeffers J. Shipman, Esquire Attorne s I.D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com DATE : SNq Attorneys for Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, certified mail, postage prepaid, in Lemoyne, Pennsylvania, on R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER By J. Shipman, Esquire Jeffers1785 I.D. #: P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant 326178 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lory Jones, Plaintiff File No. 07- 6SO--3 C; v l vs. Alexander J. Willingham, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Hershey Medical Center (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: any and all medical records reports office notes, correspondence, diagnostic test results pertaining to Lory Jones DOB: 3/30/67 SSN: 404-11-6267 at Johnson Duffle Stewart & Weidner, 301 Market Street P.O. Box 109 Lemoyne. PA 17043. 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: Jefferson J. Shipman, Esquire ADDRESS: 301 Market Street Lemoyne. PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: a %5/ al',, ..2- tr. Prothonotary/Clerk, Civil Di ion f ? ty De ut DATE: - ?a Seal Off the Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lory Jones, / Plaintiff File No. C)2 - 6t5-C- 3 iv VS. Alexander J. Willingham, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Mechanicsburg Family Practice Center (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: any and all medical records reports office notes, correspondence, diagnostic test results pertaining to Lory Jones DOB: 3/30/67 SSN: 404-11-6267 at Johnson Duffie Stewart& Weidner, 301 Market Street P.O. Box 109 Lemoyne, PA 17043. 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: Jefferson J. Shipman. Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID 51785 ATTORNEY FOR: Defendant BY THE COURT: /,r 1 62 - Prothonotary/Clerk, Civil Divi ion Deput DATE: L?Gt?I , Sea66f the Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lory Jones, Plaintiff File No. 0'7.- 66'C>.3 4!;'v : j vs. Alexander J. Willingham, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Pinnacle Health Physical Therapy (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: any and all medical records physical therapy records, reports, office notes correspondence diagnostic test results pertaining to Lory Jones DOB: 3/30/67 SSN;404-11- 6267 at Johnson Duffie Stewart & Weidner, 301 Market Street P.O. Box 109. Lemoyne, PA 17043. 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: Jefferson J. Shipman, Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043. TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: 17 -1- Prothonotary/Clerk, Civil Divisioff ice= lW-1141 De ty DATE: 4u, s-'; ?gg?' S the Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lory Jones, Plaintiff File No. 07- 6ko--; vs. Alexander J. Willingham, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Magnetic Imaging Center (Name of Person or Entityl Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: MRIs of Cervical Spine (ACTUAL Films) and corresponding report; Lory Jones DOB: 3/30/67 SSN: 404-11-6267 at Johnson Duffie Stewart & Weidner, 301 Market Street P.O. Box 109 Lemovne, PA 17043. 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: Jefferson J. Shipman. Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Divisicf -?? Al. f-- Deputy DATE: J- Sea of the Court (Eff. 7/97) ?°s C?? .-? c, .? , ? ?p -. _ry;T.. ....,? r ;_ ,., t ' . ?.,, a _.... `_ ?: , ?-<: j Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com LORY JONES, Plaintiff V. ALEXANDER J. WILLINGHAM, Defendant Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 07-6803 CIVIL TERM JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 TO: R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas attached thereto, was mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoenas were sought to be served; (2) A copy of the Notice of Intent including the proposed subpoenas, is attached to this Certificate; J (3) No objection to the subpoenas has been received, the twenty day waiting period was waived; and (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. JOHNSO DUFFIE, STEWART & WEIDNER • By Jeffers J. ipman, Esquire Attorn s I.D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com DATE : Attorneys for Defendant 4 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, first class mail, postage Q? prepaid, in Lemoyne, Pennsylvania, on fd 1,-),/ R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER By Jeffersdh J. Shipman, Esquire I.D. #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com LORY JONES, V. Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ALEXANDER J. WILLINGHAM, Defendant : CIVIL ACTION -LAW NO. 07-6803 CIVIL TERM JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff PLEASE TAKE NOTICE that Defendant intends to serve two (2) subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of records and serve upon the undersigned objections to the subpoenas. If no objections are made, the subpoenas may be served. JOHNS DUFFIE, STEWART WEIDNER By Jeffershn J%,Shipman, Esquire Attorn s I.D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com DATE : /o/a/ fig" Attorneys for Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, certified mail, postage prepaid, in Lemoyne, Pennsylvania, on 10 /b b) 6 K R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER By 4Jeffer. Shipman, Esquire I.D. #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant 326178 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lory Jones, Plaintiff File No. 07-6803 vs. Alexander J. Willingham, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Orthopedic Institute of Pennsylvania (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: any and all medical records.. reports, office notes, correspondence, diagnostic test results pertaining to Lory Jones DOB: 3/30167 SSN: 404-11-6267 at Johnson. Duffle, Stewart & Weidner, 301 Market Street. P.O. Box 109. Lemoyne, PA 17043. 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: Jefferson J. Shipman. Esquire ADDRESS: 301 Market Street Lemoyne. PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: AS/ r honotary/Clerk, Civil Divisi epu y DATE: lobalog Seal f th Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lory Jones, vs. Plaintiff File No. 07-6803 Alexander J. Willingham, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Arlington Orthopedics (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: any and all medical records, reports, office notes correspondence diagnostic test results pertaining to Lorv Jones DOB: 3/30/67 SSN: 404-11-6267 at Johnson, Duffie, Stewart & Weidner, 301 Market Street P.O. Box 109, Lemoyne PA 17043. 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: Jefferson J. Shipman, Esquire ADDRESS: 301 Market Street Lemoyne. PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: LCthonotary/Clerk, Civil Divisio . r.J eputy DATE: b'k/02 _ Seal of th Court (Eff. 7/97) - ,? M r O ern CO Johnson, uffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51 785 301 Market Street P. O. Box 1 09 Lemoyne, ennsy (717) 761 540 &Qdsw.c m LORY JON V. Plaintiff ALEXAND?R J. WILLINGHAM, Defendant TO: R. I 101 pursuant to 17043-0109 Attorneys for Defendant Thomas, Esquire th Market Street csburg, PA 17055 for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-6803 CIVIL TERM JURY TRIAL DEMANDED As a prerequisite to service of a subpoena for documents and things Rule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas attached th reto, was mailed, via Certified Mail, or delivered to each party at least twenty (2) attached tc prior to the date on which the subpoenas were sought to be served; A copy of the Notice of Intent including the proposed subpoenas, is his Certificate; (3) 1 No objection to the subpoenas has been received; and (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. JOHNS, DUFFIE, STEWART & WEIDNER By Jeff son J. Shipman, Esquire Attorneys I.D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com DATE : ?b b 9 Attorneys for Defendant CERTIFICATE OF SERVICE following, prepaid, in R. Mark Th 101 South Mechanicsl Attorney foi certify that a copy of the foregoing has been duly served upon the depositing the same in the United States Mail, first class mail, postage oyne, Pennsylvania, on b )mas, Esquire Aarket Street urg, PA 17055 Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER By Jeffe son J. Shipman, Esquire I. D. #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant w Johnson, uffie, Stewart & Weidner By: Jeffers on J. Shipman, Esquire I.D. No. 51 785 301 Markel Street P. O. Box 09 Lemoyne, ennsylvania 17043-0109 (717) 761 540 jjs@jdsw.c m Attorneys for Defendant LORY JONES, V.. Plaintiff ALEXANDER J. WILLINGHAM, Defendant E TO: R. M rk Thomas, Esquire 101 outh Market Street Mec anicsburg, PA 17055 Atto ev for Plaintiff identical to date listed t to the subo, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 07-6803 CIVIL TERM JURY TRIAL DEMANDED : TAKE NOTICE that Defendant intends to serve one (1) subpoena one that is attached to this notice. You have twenty (20) days from the w in which to file of records and serve upon the undersigned objections a. If no objections are made, the subpoena may be served. DATE : i-)) k d n JOHNrf4, DUFFIE, STEWART & WEIDNER By Jeff rson J. Shipman, Esquire Attorneys I.D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com Attorneys for Defendant CERTIFICATE OF SERVICE I hei following, prepaid, in R. Mark Tr 101 South Mechanics Attorney fc 326178 certify that a copy of the foregoing has been duly served upon the depositing the same in the United States Mail, certified mail, postage oyne, Pennsylvania, on q,L 6) 0 imas, Esquire larket Street urg, PA 17055 Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER By Jefferson J. Shipman, Esquire I . D. #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lory Jones, vs. Plaintiff File No. 07-6803 Alexander J. illingham, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: (Name of Person or Entity) Withi , twerty (20) days after service of this subpoena, you are ordered by the court to produce the following ocuments or things: any and all claim records/reports medical records/reports regarding claim # 006 680750101037 nertaininn to I nrv .Innae rvnR• iianra7 COM- AAA „ at You ay deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE SUPREME Ci ATTORNEYF RTID#: Jefferson J. Shipman Esquire 301 Market Street Lemoyne. PA 17043 717-761-4540 51785 Defendant BY THE COURT: I./ aw"- P . othonotary/Clerk, Civil V- . DATE: 17 p Seal th Coen urt (Eff. 7/97) i I: E_)' - JE_ OF THE Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I. D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA LORY JONES, V. ALEXANDER J. WILLINGHAM, Defendant Attorneys for Defendant CIVIL ACTION - LAW NO. 07-6803 CIVIL TERM JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 TO: R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas attached thereto, was mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoenas were sought to be served; (2) A copy of the Notice of Intent including the proposed subpoenas, is attached to this Certificate; (3) No objection to the subpoenas has been received, the waiting period for objections was waived; and (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. JOHNSON, DUFFIE, STEWART & WEIDNER Jeff son J. Shipman, Esquire Attorneys I.D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com DATE : 110),M Attorneys for Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, first class mail, postage prepaid, in Lemoyne, Pennsylvania, on R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER By Jeffer on J. Shipman, Esquire I. D. #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com Attorneys for Defendant LORY JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ALEXANDER J. WILLINGHAM, Defendant : CIVIL ACTION -LAW NO. 07-6803 CIVIL TERM JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff PLEASE TAKE NOTICE that Defendant intends to serve six (6) subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of records and serve upon the undersigned objections to the subpoenas. If no objections are made, the subpoenas may be served. JOHNS N, DUFFIE, STEWART & WEIDNER gy Jeff son J. Shipman, Esquire Attorneys I.D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com DATE : q/75-/6 C? Attorneys for Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following, by depositing the same in the United States Mail, certified mail, postage prepaid, in Lemoyne, Pennsylvania, on R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 Attorney for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER By Jeff rson J. Shipman, Esquire I.D. #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant 326178 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lory Jones, Plaintiff File No. 07-6803 vs. Alexander J. Willingham, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Orthopedic Institute of Pennsylvania (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: any and all medical records, reports, office notes, correspondence diagnostic test results from 9/1108 through 10/31/09 pertaining to Lory Jones DOB: 3/30/67 SSN: 404-11-6267 at Johnson Duffie Stewart & Weidner, 301 Market Street P.O. Box 109, Lemoyne, PA 17043. 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: Jefferson J. Shipman, Esquire ADDRESS: 301 Market Street Lemoyne. PA 17043. TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: ??? 4 Pr honotary/ , tvit vision Deputy DATE: Se of the Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lory Jones, Plaintiff File No. 07-6803 vs. Alexander J. Willingham, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Hershey Medical Center (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: any and all medical records, reports, office notes, correspondence diagnostic test results from 911/08 through 10/31109 pertaining to Lory Jones DOB: 3/30167 SSN: 404-11-6267 at Johnson Duffie Stewart & Weidner, 301 Market Street P.O. Box 109, Lemoyne, PA 17043. 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: Jefferson J. Shipman, Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: Az'6-??z Pr onotary/Cler 'vil ivision Deputy DATE: ---1 C.-7r 624!? Se of the Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lory Jones, Plaintiff File No. 07-6803 vs. Alexander J. Willingham, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Arlington Orthopedics (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: any and all medical records, reports, office notes, correspondence, diagnostic test results from 911108 through 10/31/09 pertaining to Lory Jones DOB: 3130/67 SSN: 404-11-6267 at Johnson, Duffie, Stewart & Weidner, 301 Market Street, P.O. Box 109, Lemoyne, PA 17043. 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: Jefferson J. Shipman, Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: 16 LqY4?4 Prot notary/Cler ision Deputy DATE: ,2 Seal of the Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Lory Jones, vs. Plaintiff File No. 07-6803 Alexander J. Willingham, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Physicians of Rehabilitation. Industrial & Spine Medicine (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: any and all medical records, reports, office notes, correspondence, diagnostic test results pertaining to Lory Jones DOB: 3/30/67 SSN: 404-11- 6267 at Johnson, Duffie, Stewart & Weidner, 301 Market Street, P.O. Box 109, Lemoyne, PA 17043. 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: Jefferson J. Shipman. Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: Lt? ?e - P thonotary/Cle ision Deputy DATE: `?' - -2 o Sea of the Court (Eff. 7/97) FILED- RCE OF THE PrTN01.40TAR1l' 2009 OCT -2 PM 12: 58 r ? * 1 Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com T(7 "!-TAr Y 2010 A13R c9 AID I I ::33 Attorneys for Defendant IV_i.,.Ji 1 f y LORY JONES, Plaintiff V. ALEXANDER J. WILLINGHAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6803 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY: Please mark the above captioned action settled and discontinued, including all counterclaims, crossclaims and joinders of additional parties. By: R. Mark Thomas JOHNSON, DUFFIE, STEWART & WEIDNER 44JAeszor JDISCONTINUANCE CERTIFICATE 7-t AND NOW, this y day of AP,- / , 2010, suit has been marked as above directed. /5% 9"?e? k, 397593 PROTHONOTARY Cy CERTIFICATE OF SERVICE AND NOW, this a: day of April, 2010, the undersigned does hereby certify that she did this date serve a copy of the foregoing praecipe upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: R. Mark Thomas, Esquire 101 South Market Street Mechanicsburg, PA 17055 JOHNSON, DUFFIE, STEWART & WEIDNER ? , zj".' 1, By: chelle H. Spangler :397593