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HomeMy WebLinkAbout03-5774 William P. Douglas, Esq. Supreme Court /,0, #37926 Douglas Law Office 27 W, High 51, Carlisle, P A 17013 Telephone (717) 243-1790 Jerrie 1. Holstine, Lindolee Jumper and Wilmot Jumper In the Court of Common Pleas of Cumberland County, Pennsylvania Plaintiffs vs No. 03- 5TI'i Civil Term Cecilia T. Pedersen 99 Day Street Norwood, MA 02062 Civil action law Jury Trial Demanded Defendant Praecipe to Issue a Writ of Summons Dear Mr. Long: CE.el'~& -r t:'~* Please issue a writ of summons against the defendant, Robt.l 1<:. L'Oftg, Jr. \~~~- ~.~ William P. Dou , Esq, Attorney for aintiff date: November 3, 2003 (:) C) (~ C W -<". -c S ;;t: ,-'- ~.:::) rnf~ -' -,r". ~-' \ 7'- ,.. (j1-' c.,:; 2f l~~) .- - ~ ',-j ::i"c :z: i c-:'j hC' - . ' ,,' :VC' - ,._J ., .A 7: ," -. :2, <.11 ~ ~ ;. tur f3 LJ sf ~ 1 p w-F J o Commonwealth of Pennsylvania County of Cumberland Jerrie L. Holstine, Lindolee Jumper and Wilmot Jumper Plaintiffs In the Court of Common Pleas of Cumberland County, Pennsylvania vs No. 03-577'1 Civil Term Cecilia T. Pedersen 99 Day Street Norwood, MA 02062 Defendant Gvil action law Jury Trial Demanded Writ of Summons To: Cecilia T. Pedersen 99 Day Street Norwood, MA 02062 .' You are hereby notified that Jerrie L. Holstine, Lindolee Jumper and Wilmot Jumper have brought an action against you. ~J(. -i'd' frolh,w+~/ AIeLu; /It, WM.I2L. a;~ty Pro~lr\Otary date: November 3, 2003 William P. Douglas, Esq. Douglas Law Office 27 W, High St. Carlisle, PA 17013-0261 717-243-1790 Attorney for Plaintiff E copy fROM REC In Testimon ' \ here II my hand and the seel of sa Car\lSle. PI, This oL-.-, Prn~~{'jr;-r1'f'V (') a c: c....) <- ;!': (J "t- lJU ~_:::J ~ VI. ril f r "'.c: 2:'.' ~ Y1 t:5' I -<.' Lo -- 6 ~c; ~~ .L: c:::, ~, .c. .<:: ~ ~(- CN ?'>-. C,' 0 ~. -.; :.0 ~ t:J -<. <=> ~ c::J; ;;;:- v & '':..f ~ .'..... , '-' J'_ ~;~ )('5 '_:.5111 ;::~ S:J -< JERRIE L. HOLSTINE, LINDO LEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 vs. CIVIL ACTION - LAW CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a rule upon Plaintiff to file a Complaint in the above matter within 20 days after service of the rule or suffer a judgment of non pros. By: THOMAS & HAFER oks R. LD, No, 70102 305 North Front Street Sixth Floor P,O, Box 999 Harrisburg, P A 17108-0999 (717) 255-7626 RULE NOW, J),:'{" I P o C .;;;''''' a:~f\': U'] r:;: ;1.... ~J -< r--> = = '-' t::J r:'"j ,-, r> :::ri --1 :r Ni:JJ 1--'- "l:Jm :J-'O ~6 ~:2~~ Cjin ::-:.;,! C> =:! ....... 'Y ,,~ C.) JERRIE L. HOLSTINE, LINDO LEE JUMPER and WILMONT JUMPER, Plaintiffs vs. CECILIA T. PEDERSEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 CIVIL ACTION - LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter our appearance on behalf of Defendant Cecilia T. Pedersen in the above matter. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP by: Broo s . Folan, qUIre I.D. No. 70102 305 North Front Street, 6th Flo POB 999 Harrisburg, P A 17108-0999 (717) 255-7626 270345,1 CERTIFICATE OF SERVICE AND NOW, this~ay of ~~ _, 20~, I, Coleen M, Polek. of the law firm of Thomas, Thomas & Hafer, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy ofthe same in the United States Mail, postage prepaid. to the following: William p, Douglas, Esq. Douglas Law Office 27 W. High Street Carlisle, P A 17013-0261 (!];rDJ- Coleen M, Polek o c-:: .~ ~~~~'r.~ 2./ r;. C.', ~-:;; -<'---, -< ....' = = ~. c:> pl " CJ -n --t :r: -q l'n-r-:- --in .')JO q(S ~-'r'. W7. )~'.~, .-": -- OJ r:,;'" N OJ DOUGLAS LAW OFFICE 27 W.HIGH ST. POD 261 CAJl.LISLE P A 17013 TELEPHONE 717-243-1790 WILLIAM P OOUGLAS. ESQ. Supreme Court J.D.# 3791/J Jerrie L. Holstine, Undolee Jumper and Wilmot Jumper In the Court of Common Pleas of Cumberland County, Pennsylvania Plaintiffs vs No. 03 - 5774 Civil Term Cecilia T. Pedersen Defendant Civil action law Jury Trial Demanded 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 DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND flUNG IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SEf FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO, THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAYBE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY ClAIMED IN THE COMPlAINT OR FOR ANY OTHER ClAIM OR RELIEF REQUESTED BY THE PlAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR lAWYER AT ONCE. IF YOU DO NOT HAVE A lAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A lAWYER. IF YOU CANNOT AFFORD TO HIRE A lAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle PA 17013 717-249-3166 BY~...Il-.(( ~ DATE: January 6, 2004 Complaint 1. The plaintiff, Jerrie L. Holstine, is an adult with a residence address of 228 N. Baltimore Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania. 2. The plaintiffs, Lindolee Jumper and Wilmot Jumper are adult individuals with a residence address of 1120 Rockledge Drive, South Middleton Township. Cumberland County, Pennsylvania. 3. The Defendant, Cecilia T. Pedersen, is an adult individual residing at 99 Day Street, Norwood, Massachusetts. 4. On or about, August 2, 2003, the plaintiffs were traveling South on Route 34 in South Middleton Township, Cumberland County. 5. At about the same time and place, the defendant was operating a Massachusetts registered rental vehicle on said roadway. 6. The defendant negligently attempted to make a u-turn on the roadway directly in the path of the vehicle occupied by the plaintiffs and caused a collision. 7. The impact occurred as a direct and proximate result of the defendant's negligence. 8. The defendant was negligent in the following respects: a) failing to maintain a proper lookout; b) failing to yield one half of roadway to oncoming traffic; c) failing to operate her vehicle in a safe and prudent manner; d) failing to ascertain that it was safe to change lanes of travel. 9. As a direct and proximate result of the negligence of the defendant the plaintiffs were injured, their injuries, and/ or aggravation of their pre- existing condition(s), include but are not liInited to: a) Jerrie L. Holstine - Surgery and three days in ICU for collapsed left lung and punctured right lung. Suffered cracked ribs and knee contusions. Suffering from traumatically induced high blood pressure since date of accident; b) Lindolee Jumper - fractures of both wrist/ arms, surgical repair and hospitalization; c) Wilmot Jumper - facial laceration and scar; 10. As a result of their injuries, the plaintiffs have incurred medical expenses in the past and may continue to incur the same in the future in amounts in excess of that covered by the Pennsylvania Motor Vehicle Financial Responsibility Act. 11. As a result of their injuries, the plaintiffs have incurred great pain and suffering and may continue to incur the same in the future. 12. As a result of their injuries the plaintiffs have incurred aggravation, inconvenience disfigurement, disability, and a loss of life's pleasures, property damage and may continue to incur the same in the future. 13. As a result of the injuries the plaintiffs, sustained on August 2, 2003, the plaintiffs have lost wages and the plaintiffs' economic horizons may be limited. Wherefore it is prayed that judgment be entered in favor of the plaintiffs and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. January 6, 2004 Respectfully s Initted, GJ) ~ Q. William P. Douglas, Attorney for Plain AFFIDAVIT I hereby swear or affirm that the foregoing is true and correct to the best of my knowledge and/or information and belief. This is made subject to the penalties of 18 Pa.C.S.A. g4904 relating to unsworn falsification to authorities. Date: January 6, 2004 o C :-:;;: -c'-'''''. IT,r~~' -~'; ,. < ;;,~ r' ~t ;;'f-.:; ~'c'~ ~5 -< " c:::\ ---- ....., c=) = .&'" C- """ ;z I C"\ -u :::.:: .::- ~ ::;i m::D r- :sm 6 o --it :r::;:j qc'i or;; ~ -~- 00 -< o en JERRIE L. HOLSTINE, LINDO LEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 03-5774 vs. CIVIL ACTION - LAW CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED NOTICE TO PLEAD You are hereby notified to plead to the enclosed Answer with New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. ANSWER WITH NEW MATTER AND NOW, comes Defendant Cecilia T. Pedersen, by and through its attorneys, Thomas, Thomas & Hafer, LLP, and files the following Answer with New Matter: I. Denied. Defendant is without information or belief as to the !ruth of the averments of paragraph I of Plaintiffs' Complaint and the same are therefore denied and proof thereof is demanded at time oftrial. 2. Denied. Defendant is without information or belief as to the !ruth of the averments of paragraph 2 of Plaintiffs' Complaint and the same are therefore denied and proof thereof is demanded at time oftrial. 3. Admitted. 4. Admitted based upon information and belief. 5. Admitted. 6. Denied as stated. It is specifically denied that Defendant negligently attempted to make a u-turn on the roadway. It is admitted only that Defendant was attempting a three-point turn when Plaintiffs' vehicle collided with the vehicle being driven by Defendant. Any and all other allegations contained in paragraph 6 are specifically denied and strict proofthereof is demanded at time of trial. 7. Denied. The allegations contained in paragraph 7 are conclusions ofIaw to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.c.P. 1029(e). 8. (a-d) Denied. The allegations contained in paragraphs 8 (a-d) are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. I029(e). 9. (a-c) Denied. The allegations contained in paragraphs 9 (a-c) are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 10. Denied. Defendant is without information or belief as to the truth of the averments of paragraph 10 of Plaintiffs' Complaint and the same are therefore denied and proof thereof is demanded at time of trial. I I. Denied. The allegations contained in paragraph 11 are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. I029(e). 12. Denied. The allegations contained in paragraph 12 are conclusions ofIaw to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 13. Denied. The allegations contained in paragraph 13 are conclusions ofIaw to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 2 WHEREFORE, Defendant Cecilia T. Pedersen respectfully requests that judgment be entered in its favor and against Plaintiffs Jerrie 1. Holstine, Lindolee Jumper and Wilmont Jumper. NEW MATTER 14. Plaintiffs' injuries and/or damages, if any, were caused by parties other than Defendant. 15. Plaintiffs' injuries and/or damages, if any, were caused in part by Plaintiffs' own contributory or comparative negligence. 16. Some or all of Plaintiffs' damages may be barred or reduced by the applicable provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, Defendant Cecilia T. Pedersen respectfully requests that judgment be entered in its favor and against Plaintiffs Jerrie 1. Holstine, Lindolee Jumper and Wilmont Jumper. Respectfully submitted, THOMAS, THO~~: ,Ii, 1I A JmR. LLP b~~ ;; : .:r:<1l ,Esquire~ LD. No. 70102 305 North Front Street, 6th Floor POB 999 Harrisburg, P A 17108-0999 (717) 255-7626 2749S3.1 Attorneys for Defendant 3 VERIFICATION I, Cecilia T. Pedersen, have read the foregoing Answer with New Matter and hereby affirm that it is true and correct to the best of my personal knowledge, infOlmation and belief This Verification and statement is made subject to the penalties of 18 Pa.C.S. g 4904 relating to unsworn falsification to authorities; I verify that all the statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa.C.S. g 4904. ~~ )7;Y~ CERTIFICATE OF SERVICE AND NOW, this3 ~ay of q k <<-J- , 200tI, Coleen M. Polek, ofthe law firm of Thomas, Thomas & Hafer, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: William P. Douglas, Esq. Douglas Law Office 27 W. High Street Carlisle,PA 17013-0261 ~ Coleen M. Polek q C <': -c.t.S n-~ 1"1 !~. i-~! ~t0 <.. J;C) "=0 >-c: ~ ....., <=> ~ ..,., 1"'"1 co , U1 ~ ~~ -om ~~ Qo orn =... )> :0 -< -0 :x r:-:> C) c.:> JERRIE L. HOLSTINE, LINDO LEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 vs. CIVIL ACTION - LAW CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED vs. JERRIE L. HOLSTINE, Additional Defendant NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and Notice are served, by entering a written appearance personally or by an attorney, and filing in writing with this 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. Cwnberland County Bar Association 32 S. Bedford Street Carlisle, P A 17013 800-990-9108 NOTICIA Le han demando a usted en la corte. Si usted qui ere defendrse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plaza al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrito e en persona 0 por obogado y archivar en la corte en forma escrita sus defensas 0 sus objectiones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. USTED PUEDE PERDER DINERO 0 SUS PROPIEDADES 0 OSTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA OR LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 S. Bedford Street Carlisle, P A 17013 800-990-9108 JERRIE L. HOLSTINE, LINDO LEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 vs. CIVIL ACTION - LAW CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED vs. JERRIE L. HOLSTINE, Additional Defendant DEFENDANT'S JOINDER COMPLAINT AGAINST JERRIE L. HOLSTINE AND NOW, comes original Defendant, Cecilia T. Pedersen, by and through her attorneys, Thomas, Thomas & Hafer, LLP, and brings the following Joinder Complaint: I. This is a civil action for personal injuries arising out of a two-vehicle accident that occurred on or about August 2, 2003, on State Route 34 in South Middleton Township, Cumberland County, Pennsylvania. 2. Plaintiffs filed a Complaint against Defendant on or about January 6,2004, alleging that Defendant was responsible for said motor vehicle accident. A copy of Plaintiffs' Complaint is attached hereto as Exhibit A. 3. Defendant filed her Answer with New Matter on February 5, 2004. A copy of Defendant's Answer with New Matter is attached hereto as Exhibit B. 4. Jerrie L. Holstine is an adult individual who resides at 228 North Baltimore Avenue, Apt. 3, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 5. Jerry L. Holstine was the operator of a vehicle in which Lindolee Jumper and Wilmot Jumper were passengers at the time of the August 2, 2003 accident. 6. Plaintiffs, Lindolee Jumper and Wilmot Jumper, claimed that they injured themselves as a result of that motor vehicle accident. 7. If Plaintiffs, Lindolee Jumper and Wilmot Jumper, injured themselves as a result of the motor vehicle accident, the accident and related injuries were or may have been caused by the actions of Jerrie L. Holstine in operating her motor vehicle. 8. As a result of her negligence, Jerrie L. Holstine is or may be solely responsible for any and all injuries and/or damages alleged by Plaintiffs, Lindolee Jumper and Wilmot Jumper, in their Complaint. 9. Alternatively, if Plaintiffs Lindolee Jumper and Wilmot Jumper's accident and related injuries were the result of someone's fault other than their own, Jerrie L. Holstine is jointly and severally liable with Defendant Cecilia T. Pedersen, liable over to Defendant Cecelia 1. Pedersen or liable to Defendant Cecilia T. Pedersen for contribution and/or indemnification. WHEREFORE, if the incident in question was the fault of anyone other than Plaintiffs themselves, then Jerrie L. Holstine is solely responsible for the incident and related injuries or, in the alternative, Jerrie L. Holstine is jointly and severally liable with Defendant Cecilia T. Pedersen, liable over to Defendant Cecilia T. Pedersen or liable to Defendant Cecilia T. Pedersen for contribution and/or indemnification. Respectfully submitted, b. TRO:~~~&H~LP ~ . ,lmd, E'q,lre LD. No. 70102 - . 305 North Front Street, 6th Floor POB 999 Harrisburg, P A 17108-0999 (717) 255-7626 Attorneys for Defendant Cecilia T. Pedersen 2 VERIFICATION The undersigned, having read the attached document, hereby verifies that the attached pleading is based on information which has been gathered by counsel in the course of this lawsuit. The language of the pleading is that of counsel. Furthermore, the matters contained in this pleading are of a procedural nature only among counsel and the court. The undersigned verifies that he has read the attached pleading and that it is true and correct to the best of his information and belief. This Verification is made subject to the penalties of 18 Pa. C.S. g 4904, relating to unsworn falsification to authorities. ~d~..... DOUGLAS LAW OFFICE 27 W.illGH ST. POD 261 CAJl.LISLE P A 17013 TELEPHONE 717-243-1790 WILLIAM P. OOUGLAS. ESQ. Supreme Court I.D.# 3791/J Jerrie L. Holstine, Lindolee Jumper and Wilmot Jumper In the Court of Common Pleas of Cumberland County, Pennsylvania Plaintiffs vs o ~;.; No. 03 -5774 Civil Term;:,:~f~ ;?: '.-r_.' Zt,",," ::),<- ~'~J >~; S! Cecilia T. Pedersen Defendant Civil action law Jury Trial Demanded NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE ClAIMS SEf FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND flUNG IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE ClAIMS SEf FORTH AGAINST YOU. YOU ARE WARNED THA TIF YOU FAIL TO DO SO, THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAYBE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY ClAIMED IN THE COMPLAINT OR FOR ANY OTHER ClAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT IDRING ALA WYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle PA 17013 717-249-3166 BY~..IL_A~ . I DATE: January 6, 2004 ,"" 0 = = -rr .G' <- :t!::n >- ::;!: rn~_. I :g~ en '?c:J --0 :r-=B -'0. ~~ tJ "'-.10 ~ 9 )~ c:> ~ -J EXHIIII'r A Complaint 1. The plaintiff, Jerrie L. Holstine, is an adult with a residence address of 228 N. Baltimore Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania. 2. The plaintiffs, Lindolee Jumper and Wilmot Jumper are adult individuals with a residence address of 1120 Rock1edge Drive, South Middleton Township. Cumberland County, Pennsylvania. 3. The Defendant, Cecilia T. Pedersen, is an adult individual residing at 99 Day Street, Norwood, Massachusetts. 4. On or about, August 2, 2003, the plaintiffs were traveling South on Route 34 in South Middleton Township, Cumberland County. 5. At about the same time and place, the defendant was operating a Massachusetts registered rental vehicle on said roadway. 6. The defendant negligently attempted to make a u-turn on the roadway directly in the path of the vehicle occupied by the plaintiffs and caused a collision. 7. The impact occurred as a direct and proximate result of the defendant's negligence. 8. The defendant was negligent in the following respects: a) failing to maintain a proper lookout; b) failing to yield one half of roadway to oncoming traffic; c) failing to operate her vehicle in a safe and prudent manner; d) failing to ascertain that it was safe to change lanes of travel. 9. As a direct and proximate result of the negligence of the defendant the plaintiffs were injured, their injuries, and/ or aggravation of their pre- existing condition(s), include but are not limited to: a) Jerrie L. Holstine - Surgery and three days in ICU for collapsed left lung and punctured right lung. Suffered cracked ribs and knee contusions. Suffering from traumatically induced high blood pressure since date of accident; b) Lindolee Jumper - fractures of both wrist/ arms, surgical repair and hospitalization; c) Wilmot Jumper - facial laceration and scar; 10. As a result of their injuries, the plaintiffs have incurred medical expenses in the past and may continue to incur the same in the future in amounts in excess of that covered by the Pennsylvania Motor Vehicle Financial Responsibility Act. 11. As a result of their injuries, the plaintiffs have incurred great pain and suffering and may continue to incur the same in the future. 12. As a result of their injuries the plaintiffs have incurred aggravation, inconvenience disfigurement, disability, and a loss of life's pleasures, property damage and may continue to incur the same in the future. 13. As a result of the injuries the plaintiffs, sustained on August 2, 2003, the plaintiffs have lost wages and the plaintiffs' econoInic horizons may be liInited. Wherefvre it is prayed that judgment be entered in favor of the plaintiffs and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. January 6, 2004 Respectfully s Initted, GJ) - _ Q. William P. Douglas, Attorney for Plain AFFIDAVIT I hereby swear or affirm that the foregoing is true and correct to the best of my knowledge and/or information and belief. This is made subject to the penalties of 18 Pa.C.S.A. 94904 relating to unsworn falsification to authorities. Date: January 6, 2004 JERRIE L. HOLSTINE, LINDO LEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 03-5774 vs. CIVIL ACTION - LAW o c: 3:: 'Vl1:] n~'rT; ~t2 (f)":'c; -<"" ~c: :Z:'~ <;:;cO ~c ~ CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED -0 ::;::: ~ o (,,) You are hereby notified to plead to the enclosed Answer with New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. NOTICE TO PLEAD ANSWER WITH NEW MATTER ...., = = ..,- ..., rT1 OJ I U1 o -n :r n,:!J -ohl :o'i' 00 :I! -ri o~ 2m o >! :D -< AND NOW, comes Defendant Cecilia T. Pedersen, by and through its attorneys, Thomas, Thomas & Hafer, LLP, and files the following Answer with New Matter: I. Denied. Defendant is without information or belief as to the truth of the averments of paragraph 1 of Plaintiffs' Complaint and the same are therefore denied and proof thereof is demanded at time ofilia!. 2. Denied. Defendant is without information or belief as to the truth of the averments of paragraph 2 of Plaintiffs' Complaint and the same are therefore denied and proof thereof is demanded at time of tria!. 3. Admitted. 4. Admitted based upon information and belief. 5. Admitted. 6. Denied as stated. It is specifically denied that Defendant negligently attempted to make a u-tum on the roadway. It is admitted only that Defendant was attempting a three-point turn when Plaintiffs' vehicle collided with the vehicle being driven by Defendant. Any and all EXHI8IT j B other allegations contained in paragraph 6 are specifically denied and strict proof thereof is demanded at time of trial. 7. Denied. The allegations contained in paragraph 7 are conclusions oflaw to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 8. (a-d) Denied. The allegations contained in paragraphs 8 (a-d) are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. l029(e). 9. (a-c) Denied. The allegations contained in paragraphs 9 (a-c) are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 10. Denied. Defendant is without infonnation or belief as to the truth of the averments of paragraph 10 of Plaintiffs' Complaint and the same are therefore denied and proof thereof is demanded at time of trial. II. Denied. The allegations contained in paragraph 11 are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 12. Denied. The allegations contained in paragraph 12 are conclusions oflaw to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 13. Denied. The allegations contained in paragraph 13 are conclusions of law to which no response is required. To the extent a response is deemed to be required, the allegations are denied pursuant to Pa.R.C.P. 1029(e). 2 WHEREFORE, Defendant Cecilia T. Pedersen respectfully requests that judgment be entered in its favor and against Plaintiffs Jerrie L. Holstine, Lindolee Jumper and Wilmont Jumper. NEW MATTER 14. Plaintiffs' injuries and/or damages, if any, were caused by parties other than Defendant. 15. Plaintiffs' injuries and/or damages, if any, were caused in part by Plaintiffs' own contributory or comparative negligence. 16. Some or all of Plaintiffs' damages may be barred or reduced by the applicable provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. WHEREFORE, Defendant Cecilia T. Pedersen respectfully requests that judgment be entered in its favor and against Plaintiffs Jerrie L. Holstine, Lindolee Jumper and Wilmont Jumper. Respectfully submitted, T, .,HOMAS, T~ _"' ft., LLF b~~ : y. ':eok.,s .:;:ai ,Esquire l.D. No. 70102 305 North Front Street, 6th Floor POB 999 Harrisburg, P A 17108-0999 (717) 255-7626 274983.1 Attorneys for Defendant 3 VERIFICATION I, Cecilia T. Pedersen, have read the foregoing Answer with New Matter and hereby affirm that it is true and correct to the best of my personal knowledge, infonnation and belief. This Verification and statement is made subject to the penalties of 18 PaC.s. ~ 4904 relating to unswom falsification to authorities; I verify that all the statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa.C.S. g 4904. /tu~ ~7Y~A~ CERTIFICATE OF SERVICE AND NOW, this 3 ~ay of 1- k ~. ,200ft, Coleen M. Polek, of the law firm of Thomas, Thomas & Hafer, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: William P. Douglas, Esq. Douglas Law Office 27 W. High Street Carlisle, PA 17013-0261 @ra Coleen M. Polek 0 ,..., c- = 0 ;;;- c-.:> .......;'" .-:- " foot ...., :r" ,.." ,- = rn- r.... (,/) I -om -,- I..D ctJ6 r-::' ,- C' -~:C) -0 --::!( ::r.:'"' :i-~'. ::,c! :J: c,:n " :;"0 .:::;; S':' c')rn :) ~ -- .JJ ....... -~ DOUGLAS LAW OFFICE 27 W. mGH ST. POD 261 CAJl.LISLE P A 17013 TELEPHONE 717-243-1790 WILLIAM P. DOUGLAS, ESQ. Supreme Court 1.0.# 3791/J Jerrie L. Holstine, Lindolee Jumper and Wilmot Jumper Plaintiffs In the Court of Common Pleas of Cumberland County, Pennsylvania vs Cecilia T. Pedersen No. 03 - 5774 Civil Term Defendant Civil action law Jury Trial Demanded Reply to New Matter 14. Denied. The allegations of the original complaint are incorporated herein and reference is made thereto. 15. Denied. Denied as a legal conclusion to which no response is necessary. 16. Denied. The plaintiffs were injured by an out of state driver operating a vehicle registered in Massachusetts and therefore may not be subject to any limiting provisions of the of the Pennsylvania Motor Vehicle Responsibility Act. Wherefore it is prayed that the N= Matter of the defendant be dismissed judgment be entered in favor of the plaintiffs and against the defendant. February 18, 2004 Respectfully subInitted, '~~.\) \9.0 William P. Dougla~ Attorney for pi~ijf AFFIDAVIT I hereby swear or affirm that the foregoing is true and correct to the best of my knowledge and/or information and belief. This is made subject to the penalties of 18 Pa.C.S.A. g4904 relating to unsworn falsification to authorities. . \...wL=-, William P. Douglas, Esq. Date: February 18,2004 C:, ~~i_., ~'t' -.~ -< () G~ ,j:;i:~ - u1 '" "" c;::, ""'" - l.O -n _... - 9. ~-; rt1:I:! /- -r-J/"l' -'-?' ..,,-, O( :t! -r1 r5::O .~~o ~5 f71 ~ ."J:.) -< ;::: Co ~) SHERIFF'S RETURN - REGULAR CASE NO: 2003-05774 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOLSTINE JERRIE L ET AL VS PEDERSEN CECILIA T JODY SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT JOINING ADDL was served upon HOLSTINE JERRIE L the ADD'TL DEFEND. , at 0841:00 HOURS, on the 17th day of February, 2004 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to JERRIE L HOLSTINE a true and attested copy of COMPLAINT JOINING ADDL together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 .00 .00 10.00 .00 28.00 So Answers: .r~~''''''rO.e:'7~ R. Thomas Kline 02/18/2004 THOMAS THOMAS HAFER Sworn and Subscribed to before By: 06rt~J, DeputOheriff me this ~ 't:: day of J' ~ "1 ;l ()O 'T A. D . ~) .0. ~ .- ~rothonotary I ~ F:IFILES\DATAFILEIDonegaB050ICurrent\257,pral/tde Created; 3/10/04 6:03PM Revised 3/101046:08PM 3050257 JERRIE L. HOLSTINE, LINDO LEE JUMPER and WILMONT JUMPER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 03-5774 CIVIL ACTION -LAW CECILIA T. PEDERSEN, Defendant v. JERRIE L. HOLSTINE, Additional Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Additional Defendant Jerrie L. Holstine in the above matter. MARTSON DEARDORFF WILLIAMS & OTTO By '-r~1AA- ~Jt~ Thomas J. Willi s, EsqUire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Additional Defendant Jerrie L. Holstine Dated: March II, 2004 CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: William P. Douglas, Esquire DOUGLAS AND DOUGLAS P.O. Box 261 Carlisle, P A 17013 Brooks R. Foland, Esquire THOMAS, THOMAS & HAFER 305 North Front Street, 6th Floor POB 999 Harrisburg, P A 17108 MARTS ON DEARDORFF WILLIAMS & OTTO ncia D. Eckenroad Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: March II, 2004 "', = ~ (.~ ~- ~ -I ~ ::]1- Hi:G :;:Q .- -om -uO 0' 2:~ i~~ >C) :;...::fT1 C) --' :..-1 '~ 0'1 ~JJ l~ -< PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) 'IO THE PROTHONJTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) x for JURY trial at the next tenn of civil court. for trial without a jury. ----------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (check one) X) Civil Action - Law Jerrie L. Holstine, Appeal from Arbitration Lindolee Jumper and Wilmont Jumper (other) ( Plaintiff) vs. The trial list will be called on Cecilia T. Pedersen and Al1gnc:t- 1() ?()().6, Trials conrnenoe on ~~pt-o~hQY 11J ?O().6, (Defendant) Pretrials will be held on Angon' 1 R ?OOL. (Briefs are due 5 days before pretrials. ) vs. Additional Defendant (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) Jerrie L. Holstine No. 03 Civil 5774 19 Indicate the attorney who will try case for the party who files this praecipe: William P. Douglas, Esquire Indicate trial counsel for other parties if known: Brooks R. Foland, Esquire, 255-7626, Attorney for D"fendant Thomas J. Williams, Esquire, Attorney for Additional Defendant This case is ready for trial. Signed: ~~, Plaintiffs Print NaIre: Date: June 14, 2004 Attorney for: ~ = ,;:- 'e -;.C I"l - '- (.,-:; j -<) o 1'\ ::;l-n _1.-_ r11m -o~ -8 b ...1..,.-; .""L-n c~5 -;:-cn (~ .~~ -'" ~ _0>" - N .' o CO JERRIE L. HOLSTINE, LINDO LEE JUMPER and WILMONT JUMPER, Plain tiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 vs. CIVIL ACTION - LAW CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND TIllNGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Counsel of Record Defendant intends to serve a subpoena identical to the one that is attached to this Notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. Ifno objection is made, the subpoena will be served. THOMAS, THOMAS & HAFER, LLP Date: July 15, 2004 :r;L R ~LAND' FSQUIRE ' 305 N. Front Street, P.O. Box 999 Harrisburg, PA 17108 (717) 237-7141 Attorney for Defendant CERTIFICATE OF SERVICEl AND NOW, this ~day of July, 2004, I, Barbara Onorato, a Paralegal in the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, first class, postage prepaid, to the following: William P. Douglas, Esquire Douglas Law Office 27 W. High Street Carlisle, PA 17013-0261 ~5~~ Barbara Onorato, Paralegal JERRIE L. HOLSTINE, LINDO LEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 vs. CIVIL ACTION - LAW CECILIA T. PEDERSEN, Defendant JURY TRIAl" DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Carlisle Medical Center Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all medical records. reoorts. tTi~atment notes. diagnostic studies. writings. correspondence. etc.. for treatment rendered on behalf of Lindolee Jumper. d/o/b: 4/17/64. ssn: 176-52-8163. at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108- 0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to th(: 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: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, P A 17108-0999 TELEPHONE: (717) 237-7141 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal ofthe Court Prothonotary/Clerk, Civil Division Deputy JERRIE L. HOLSTINE, LINDOLEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLA~D COUNTY, PENNSYL VANIA NO. 03-5774 vs. CIVIL ACTION - LAW CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Dr. David Baker Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all medical records. reports. treatment notes. diagnostic studies. writings. correspondence. etc.. for treatment rendered on behalf of Lindolee Jumper. d/o/b: 4/17/64. ssn: 176-52-8163. at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108- 0999. 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 cornply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7141 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy JERRIE L. HOLSTINE, LINDO LEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 vs. CIVIL ACTION - LAW CECILIA T. PEDERSEN, Defendant JURY TRIAlL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Belvedere Family Practice Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all medical records. reports. treatment notes. diagnostic studies. writings. correspondence. etc.. for treatment rendered on behalf of Lindolee Jumper. d/o/b: 4/17/64. ssn: 176-52-8163. at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108- 0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to th,~ party making this request at the address listed above. You have the right to seek in advance, file 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: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7141 SUPREME COURT 10#: 70102 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy JERRIE L. HOLSTINE, LINDO LEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 03-5774 VS. CIVIL ACTION - LAW CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RUJLE 4009.22 TO: Custodian of Records, Eat N Park Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of any and all employment records. including attendance records. wage information. disabilitv records. medical records or reports. wriitings. correspondence. etc.. for treatment rendered on behalf of Lindolee Jumper. d/o/b: 4/17/64. ssn: 176-52-8163. at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108- 0999. 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: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7141 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal ofthe Court Prothonotary/Clerk, Civil Division Deputy JERRIE L. HOLSTINE, LINDOLEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 vs. CIVIL ACTION - LAW CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Weis Markets Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all emplovment records. including attendance records. wage information. disability records. medical records or reports. writings. correspondence. etc.. for treatment rendered on behalf of Lindolee Jumper. d/olb: 4/17/64. ssn: 176-52-8163. at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108- 0999. 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: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7141 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy n "" 0 r-=o ~~ c;::;, " .L- -., ,. (- :I! c:: " "', 1'"- rn r: -0 IT! -u? ill () (' .:: J,J ,0 -T, -U () -(1 ..::;- Cl ~'" -"-.' C'') :1.- C,) IT! l W ., ""'-:j "', ~~; , -< JERRIE L. HOLSTINE, LINDOLEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAJ"lD COUNTY, PENNSYL VANIA NO. 03-5774 vs. CIVIL ACTION - LAW CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RUL1B: 4009.21 TO: Counsel of Record Defendant intends to serve a subpoena identical to the one that is attached to this Notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. Ifno objection is made, the subpoena will be served. THOMAS, THOMAS & HAFER, LLP Date: July 15, 2004 By: /7 BR~AND, ESQUIRE 305 N. Front Stref:t, P.O. Box 999 Harrisburg, PA 17108 (717)237-7141 Attorney for Defendant CERTIFICATE OF SERVICE; AND NOW, this day of July, 2004, I, Barbara Onorato, a Paralegal in the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, first class, postage prepaid, to the following: William P. Douglas, Esquire Douglas Law Office 27 W. High Street Carlisle, PA 17013-0261 )?j~AL ~Adi B1r1J,ara Onorato, Paralegal JERRIE L. HOLSTINE, LINDO LEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 vs. CIVIL ACTION - LAW CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Carlisle Medical Center Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all medical records. reports. treatment notes. diagnostic studies. writings. correspondence. etc.. for treatment rendered on behalf of Wilmont Jumper. d/o!b: 11/21/59. ssn: 163-56-7169. at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108- 0999. 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: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7141 SUPREME COURT 10#: 70102 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy - 0 "., 0 ceo <:; C;;;I -n -e- , '-- --, " ':.i-' -r c::: rii -~'"'! f-'-' f:' "m \.D ~(JY :"2 c) -G ~:~r~ -'" <C.) , .~\ ['...) :~~ JERRIE L. HOLSTINE, LINDO LEE JUMPER and W1LMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 CIVIL ACTION - LAW vs. CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Counsel of Record Defendant intends to serve a subpoena identical to the one that is attached to this Notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoenas. If no objection is made, the subpoena will be served. THOMAS, THOMAS & HAFER, LLP Date: July 15, 2004 By:./L --- BROOKS R. FOLAND, ESQUIRE 305 N. Front Street, P.O. Box 999 Harrisburg, PA 17108 (717) 237-7141 Attorney for Defendant CERTIFICATE OF SERVICE AND NOW, this /(f{ day of July, 2004, I, Barbara Onorato, a Paralegal in the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, first class, postage prepaid, to the following: William P. Douglas, Esquire Douglas Law Office 27 W. High Street Carlisle, PA 17013-0261 &~wJ.- sir'bara Onorato, aralegal JERRIE L. HOLSTINE, LlNDOLEE JUMPER and WlLMONT JUMPER, Plaintiffs IN THE COURf OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 CIVIL ACTION - LAW vs. CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, EatN Park, Carlilsle Pike, Carlisle, PA Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all emplovment records. disability slips. attendance records. wage information. medical records. writings. correspondence. etc.. for treatment rendered on behalf of Jerrie L. Holstine. d/ofb: 6/8/64. ssn: '161-60-8150. at: Thomas. Thomas & Hafer. LLP. 305 N. Front SL P.O. Box 999. Harrisburg. PA 17108- 0999. 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: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7141 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Division Deputy JERRIE L. HOLSTINE, LlNDOLEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 CIVIL ACTION - LAW vs. CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Donegal Insurance Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all claim records., statements. medical records. reports. treatment notes. diagnostic studies. writings. correspondence. etc.. for treatment rendered on behalf of Jerrie L. Holstine. d/o!b: 6/8/64. ssn: 161-60-8150. at: Thomas. Thomas & Hafer. LLP. 305 N. Front SL P.O. Box 999. Harrisburg. PA 17108- 0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to thf: 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: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, P A 17108-0999 TELEPHONE: (717) 237-7141 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy JERRIE L. HOLSTINE, LlNDOLEE JUMPER and WlLMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 CIVIL ACTION - LAW vs. CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Shermans Dale Family Practice Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all medical records. reports. treatment notes. diagnostic studies. writings. correspondence. etc.. for treatment rendered on behalf of Jerrie L. Holstine. d/olb: 6/8/64. ssn: 161-60-8150. at: Thomas. Thomas & Hafer. LLP. 305 N. Front S1.. P.O. Box 999. Harrisburg. PA 17108- 0999. 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: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7141 SUPREME COURT 10#: 70102 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy JERRIE L. HOLSTINE, LINDO LEE JUMPER and WILMONT JUMPER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5774 CIVIL ACTION - LAW vs. CECILIA T. PEDERSEN, Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records, Dr. Lisa Hardy Within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following documents or things: Complete copies of anv and all medical records. reports. treatment notes. diagnostic studies. writings. correspondence. etc.. for treatment rendered on behalf of Jerrie L. Holstine. d/o/b: 6/8/64. ssn: 161-60-8150. at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108- 0999. 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: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7141 SUPREME COURT 10#: 70102 ATTORNEY FOR: Defendant BY THE COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy Q "-> "'" Cj ".-.- L;) "n "< ~- if, (- -:1 ~(,t' c::: 0.~ - , ,'--. fr1r-'- <:> r-n D:, I.D "":I) Q --c :;--~() r:-,,::,: ~-r. ~i~ :? C?,~~ ~< <' ...:t'.. >. Cj rrr C_ c..) .;;~ .-~i 1',.. --_J N ~b , -<. -< DOUGLAS LAW OFFICE 27 W.HIGH ST. POB 261 CARLISLE PA 17013 TELEPHONE 717-243-1790 William P. Douglas, Esq. Supreme 0, ID # 37926 I Jerrie 1. Holstine, Lindolee Jump r and Wilmot Jumper PI intiffs In the Court of Common Pleas of Cumberland County, Pennsylvania vs No. 03 - 5774 Civil Term Cecilia T. Pedersen , DefLdant Civil action law 1 Jury Trial Demanded Praecipe to ~ettle and Discontinue Dear Mr. Long, Please mark the above ca tioned matter settled and discontinued. William P. Dougla Attorney for PIa December 27, 2005 o ,-- ,.., = C;;,;;> C.J1 ,0. Cl f"q c-> I",~ O:J ~ .-l :C-r. r~~~ "J'-t-' .)S:~. ~:~~ (') :,,)pi ::-~ "l:~" ~ "'1.1 0">