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HomeMy WebLinkAbout07-7258c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MEHO MUSKIC and NO. Q^f -- "f?s'? ?I O ?, REMZIJA MUSKIC, Plaintiffs, V. : CIVIL DIVISION RUTH YOUNG , Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND Pursuant to PA RCP No. 1018.1 LAW OFF-S OF ?D.eLE d.. Yoax. Yaxxeri?nxus?i dos YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth against you 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 default judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 1-800-990-9180 EN LA CORTE DE ALEGATOS COMUN DEL CONDADO DE CUMBERLAND, PENNSYLVANIA DIVISION CIVIL MEHO MUSKIC and NO. REMZIJA MUSKIC, Plaintiffs, V. : CIVIL DIVISION I).A L.N. R*WANNTI E. P -C. Y.... eP......swvu RUTH YOUNG , Defendant JURY TRIAL DEMANDED AVISO PARA DEFENDER Conforme a PA RCP Num. 1018.1 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 presentar comparecencia escrita en persona 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 notificacion por cualquier dinero reclamado en la demanda o por cualquier otra queja o compensacion reclamados por el Demandante. USTED PUEDE PERDER DINERO, O PROPRIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOUS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION TWO LIBERTY STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 1-800-990-9180 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MEHO MUSKIC and REMZIJA MUSKIC, Plaintiffs, V. RUTH YOUNG , Defendant CIVIL DIVISION JURY TRIAL DEMANDED COMPLAINT 1. The Plaintiffs, Meho Muskic and Remzija Muskic, husband and wife, are adult individuals residing at 321 Bayley Street, Carlisle, Pennsylvania 17013. 2. The Defendant, Ruth Young, is an adult individual residing at 556 N. Bedford Street, Carlisle, Pennsylvania 17013. 3. On December 23, 2005, Plaintiff Meho Muskic was the operator of a motor vehicle. 4. On December 23, 2005, the Defendant was operator of a motor vehicle. 5. On December 23, 2005, at approximately 1:00 p.m., Plaintiff, Meho Muskic, Aw aFF??ES of Yo¢e. Pe.vnriveuu9??-.ten was operating his vehicle on York Road in Carlisle and was stopped for traffic. 6. At that same time and place, the Defendant was operating her vehicle behind the Plaintiff's vehicle when she failed to stop before striking the rear of Plaintiff's vehicle, resulting in injuries and damages to the Plaintiff. 7. This accident occurred as a result of the negligence of the Defendant and was due in no manner to any act, or failure to act, on the part of the Plaintiff. e 8. This matter is alleged to exceed the applicable limits of arbitration, and a jury trial is hereby demanded. COUNTI MEHO MUSKIC V. RUTH YOUNG 9. The allegations contained in paragraphs 1 through 8, inclusive, are incorporated herein as fully as though set forth at length 10. The negligence of the Defendant consisted of the following: a) Failing to properly operate and control her motor vehicle; b) Failing to keep alert and maintain a proper lookout for the presence of other motor vehicles on the streets and highways; C) Operating her vehicle in careless disregard for the safety of others and the Plaintiff in particular, in violation of 75 Pa.C.S. §3714; d) Operating her vehicle too fast for the conditions then and there existing, in violation of 75 Pa.C.S. §3361; e) Following too closely to Plaintiffs vehicle, in violation of 75 Pa.C.S. §3310; f) Failing to stop or take other evasive action before striking the rear of Plaintiffs vehicle; Lnw OFFICES OF 33A ,EI Yue¢. Yavrv 'cE ?nrus. ?ii.x g) Failing to stop her vehicle within the assured clear distance ahead, in violation of 75 Pa.C.S. §3361; and h) Failing to exercise reasonable care to avoid striking the rear of Plaintiffs vehicle when the Defendant knew, or should have known, of the presence of Plaintiffs vehicle. 2 11. As a result of the negligence of the Defendant, the Plaintiff suffered serious and permanent injuries, including but not limited to, lumbar disc injury, lumbar radiculopathy, lumbar sprain/strain, bilateral leg and knee pain, and a severe shock to his nerves and nervous system. 12 As a result of the negligence of the Defendant, the Plaintiff incurred medical bills and expenses for the injuries he has suffered, and he will continue to incur medical expenses in the future. 13. As a result of the negligence of the Defendant and its employees, the Plaintiff has suffered, or may suffer, a severe loss of his earnings and impairment of his earning capacity, and the loss of income and impairment of earning capacity will, or may, continue in the future. 14. As a result of the negligence of the Defendant, the Plaintiff has undergone, and in the future may undergo, great mental and physical pain and suffering, mental anguish and humiliation, loss of life's pleasures, and a severe limitation in his pursuit of daily activities, all to his great loss and detriment. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter judgment against the Defendant in an amount in excess of the mandatory arbitration limits. Fxvxrvvvwxu`171- 3 COUNT 11 REMZIJA MUSKIC V. RUTH YOUNG 15. The allegations contained in paragraphs 1 through 14 are incorporated herein and made part hereof as fully as though set forth at length. 16. Solely as a result of the negligence of the Defendant, and the resulting injuries to her spouse, Plaintiff Remzija Muskic, has been deprived of the assistance, companionship and consortium of her husband, all of which has been to her great loss and detriment. Said losses may continue for an unknown time into the future. WHEREFORE, Plaintiff respectfully requests This Honorable Court to enter judgment against the Defendant in an amount in excess of the mandatory arbitration limits. RESPECTFULLY SUBMITTED: LAW OFFICES OF DALE E. ANSTINE, P.C. Gregory E. Martin, Esquire torney I.D. #38894 Two West Market Street P.O. Box 952 York, Pennsylvania 17405 (717)846-0606 4 VERIFICATION I HEREBY VERIFY that the information set forth in the foregoing COMPLAINT, is true and correct to the best of my knowledge, information and belief. I understand that any false statements contained herein are subject to the penalties of 18 Pa. C.S.§4904, relating to unsworn falsification to authorities. Dated: (/- U Meho Muskic kPrAli'JA emzija Muskic N CD fV M (\, c?_a C? 1 e? ? r 7ti7 Y 1 i s ,- c.Ea ?; rra 0 SHERIFF'S RETURN - REGULAR CASE NO: 2007-07258 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MUSKIC MEHO ET AL VS YOUNG RUTH DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon YOUNG RUTH the DEFENDANT , at 1800:00 HOURS, on the 5th day of December , 2007 at 556 N BEDFORD STREET CARLISLE, PA 17013 by handing to RUTH YOUNG a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge ? - i?la Sworn and Subscibed to before me this of So Answers: 18.00 4.80 .58 10.00 R. Thomas Kline .00 33.38 12/06/2007 DALE E ANSTINE By: day 'Deputy Sheriff , A.D. 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 MEHO MUSKIC and REMZIJA MUSIC, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW RUTH YOUNG, NO. 07-07258 CIVIL TERM Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: PLEASE enter the appearance of the undersigned on behalf of the Defendant, Ruth Young, in the above-captioned matter. JOHNSON, DUFFIE, STEWART & WEIDNER Je ersbn J. Shipman, Esquire I.E. #: 51785 P!0. Box 109 J Lemoyne, PA 17043 DATE: 1 ?/ d 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, postage prepaid, in Lemoyne, Pennsylvania, on 7 V Gregory E. Martin, Esquire Law Offices of Dale E. Anstine 2 West Market Street P.O. Box 952 York, PA 17405 JOHNSON, DUFFIE, STEWART & WEIDNER 45iers n J. Sh ipman, Esquir . . 1785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant Young 319987 iF P F 1 ?,?' co + ; 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 Attorney for Defendant MEHO MUSKIC and REMZIJA MUSIC, Plaintiff V. RUTH YOUNG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-07258 CIVIL TERM JURY TRIAL DEMANDED NEW MATTER NOTICE TO: Gregory E. Martin, Esquire Law Offices of Dale E. Anstine 2 West Market Street P.O. Box 952 York, PA 17405 Attorneys for Plaintiff You are hereby notified to plead to the enclosed New Matter within twenty (20) days from the date of service. - '? JQHNSOJN, DUFFIE, STEWART & WEIDNER DATE: ///P/Xv/ JJ ff&son J. Shipman, Esquire D. #: 51785 .O. Box 109 Lemoyne, PA 17043-0109 Telephone: 717-761-4540 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 MEHO MUSKIC and REMZIJA MUSIC, Plaintiff V. RUTH YOUNG, Defendant Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-07258 CIVIL TERM JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT. RUTH YOUNG. TO PLAINTIFFS' COMPLAINT AND NOW, comes the Defendant, Ruth Young, by and through her counsel, Jefferson J. Shipman, Esquire and Johnson, Duffie, Stewart & Weidner, and files the following Answer and New Matter in response to Plaintiffs' Complaint: 1. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 1 and the same are therefore denied and strict proof demanded at the time of trial. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted in part, denied in part. It is admitted only that there was an accident on December 23m 2005 on York Road in Carlisle. The remaining averments in Paragraph 5 are denied as stated. 6. Admitted in part, denied in part. It is admitted only that contact was made with Plaintiff's vehicle. The remaining averments in Paragraph 6 are denied as stated. Further, the averments contained in Paragraph 6 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. 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. It is denied that the matter exceeds the applicable limits of arbitration. COUNT I MERO MUSKIC v. RUTH YOUNG 9. Ms. Young incorporates hereby by reference her answers to Paragraphs 1 through 8 above as though fully set forth herein at length. 10. Denied. The averments contained in Paragraph 10, and subparagraphs (a) through (h), are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained in Paragraph 10 and each and every subparagraphs (a) through (h) are denied as stated. (a). Denied. It is specifically denied that the Defendant failed to properly operate and control her motor vehicle; (b). Denied. It is specifically denied that the Defendant failed to keep alert and maintain a proper look-out for the presence of other motor vehicles on the streets and highways; (c). Denied. It is specifically denied that the Defendant was operating her vehicle in careless disregard for the safety of others and the Plaintiff in particular. It is further specifically denied that Ms. Young was in violation of 75 Pa. C.S.A. §3714 nor any section of the Vehicle Code; (d). Denied. It is specifically denied that the Defendant operated her vehicle too fast for the conditions then and there existing. Further, it is denied that Ms. Young was in violation of 75 Pa. C.S.A. §3361. Further, it is denied that Ms. Young was in violation of any provision of the Pennsylvania Motor Vehicle Law; (e). Denied. It is specifically denied that the Defendant was following too closely to Plaintiff's vehicle. Further, it is specifically denied that Ms. Young was in violation of 75 Pa. C.S.A. §3310. Further, it is denied that Ms. Young was in violation of any provision of the Pennsylvania Motor Vehicle Law; (f). Denied. It is specifically denied that the Defendant failed to stop or that other evasive action before striking the rear of the Plaintiffs' vehicle; (g) Denied. It is specifically denied that the Defendant failed to stop her vehicle within the assured clear distance ahead. Further, it is specifically denied that Ms. Young was in violation of 75 Pa. C.S.A. §3361. Further, it is denied that Ms. Young was in violation of any provision of the Pennsylvania Motor Vehicle Law; and (h) Denied. It is specifically denied that the Defendant failed to exercise reasonable care to avoid striking the rear of the Plaintiff's vehicle when Defendant knew, or should have known, of the presence of Plaintiff's vehicle. it is admitted only that there was contact made between the vehicles. The remaining averments of subparagraph (h) of Paragraph 10, are specifically denied. 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, answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 11 relating to Plaintiff's alleged injuries 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, answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the remaining averments in Paragraph 12 relating to Plaintiff's alleged medical bills and expenses for the alleged injuries that he allegedly suffered 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, answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the remaining averments in Paragraph 13 relating to Plaintiff's alleged loss of earnings and impairment of earning capacity and alleged loss of income and impairment of earning capacity in the future, and the same are therefore denied and strict proof demanded at the time of trial. 14. Denied. The averments contained in Paragraph 14 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, answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the remaining averments in Paragraph 14 relating the Plaintiff's alleged mental and physical pain and suffering, mental anguish and humiliation, loss of life's pleasures, and alleged severe limitation to his pursuit of daily activities and the same are therefore specifically denied and strict proof demanded thereof at the time of trial. WHEREFORE, the Defendant, Ruth Young, respectfully requests that judgment be entered in her favor and that Plaintiffs' Complaint be dismissed with prejudice. COUNT II REMZIJA v. RUTH YOUNG 15. Ms. Young incorporates hereby by reference her answers to Paragraphs 1 through 14 above as though fully set forth herein at length. 16. Denied. The averments contained in Paragraph 16 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, answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of Paragraph 16 relating to Plaintiff's allegedly being deprived of the assistance, companionship and consortium of her husband, all of which is alleged to be of her great loss and detriment at the present and into the future, consequently, all of these averments are hereby specifically denied and strict proof thereof will be required at the time of trial. WHEREFORE, the Defendant, Ruth Young, respectfully requests that judgment be entered in her favor and that Plaintiff's Complaint be dismissed with prejudice. NEW MATTER By way of additional answer and reply, the answering Defendant interposes the following New Matter defenses: 17. That the Plaintiffs alleged cause of action may be barred in whole or in part by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 18. That the Plaintiffs' alleged cause of action may be barred by the Limited Tort Option. 19. That the Plaintiffs' alleged cause of action may be barred by the Comparative Negligence Act. 20. That the Plaintiffs' injuries were pre-existing the date of this accident. 21. That the Plaintiffs' alleged cause of action and, specifically, any alleged injuries may have been caused by third parties or entities not presently involved in this action. 22. That the Plaintiffs' alleged cause of action may have been caused by an intervening superceding cause. 23. That if it should be found that there was any negligence on the part of Ms. Young, which is specifically denied, then in that event any such negligence was not a substantial factor, nor factual cause of any harm to the Plaintiffs. WHEREFORE, the Defendant, Ruth Young, respectfully requests that judgment be entered in her favor and that Plaintiffs' complaint be dismissed with prejudice. Respectfully submitted, N, DUFFIE, STEWART & WEIDNER JOf sbn J. Shipman, Esquire Att rneys I.D. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com Attorneys for Defendant VERIFICATION I, Ruth Young, have read the foregoing Answer and New Matter and hereby affirm that it is true and correct to the best of my personal knowledge, or information and belief. This Verification and statement is made subject to the penalties of 18 Pa. C.S. §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. §4904. Rut Young DATE: 319959 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 ?? f Gregory E. Martin, Esquire Law Offices of Dale E. Anstine 2 West Market Street P.O. Box 952 York, PA 17405 Attorneys for Plaintiffs JOHNSON, DUFFIE, STEWART & WEIDNER Jeff so Shipman, Esquire I.D. #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant Young 319989 (7 ? _ s .- cam . 4_ ?„?? '..) __{?._ ?? _ :.,? 5.?: :. .. _. ? = ? ?.,. t ? ?? . t 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 bs@jdsw.com MEHO MUSKIC and REMZIJA MUSKIC, Plaintiffs V. RUTH YOUNG, Defendant TO: Gregory E. Martin, Esquire Law Offices of Dale E. Anstine 2 West Market Street P.O. Box 952 York, PA 17405 Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-07258 CIVIL TERM JURY TRIAL DEMANDED 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 twenty 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 By Jeffer n J!Shipman, Esquire 1. D. # 51785 , P.O. Box 109 Lemoyne, PA 17043 DATE: all f ??- 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 a1-7 I -T Gregory E. Martin, Esquire Law Offices of Dale E. Anstine 2 West Market Street P.O. Box 952 York, PA 17405 JOHNSON, DUFFIE, STEWART & WEIDNER By Jeffer n J. Shipman, Esquire I.D. #: 51785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant Young Johnson, Duffle, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. 0. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com MEHO MUSKIC and REMZIJA MUSKIC, Plaintiffs V. RUTH YOUNG, Defendant Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-07258 CIVIL TERM JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Gregory E. Martin, Esquire Law Offices of Dale E. Anstine 2 West Market Street P.O. Box 952 York, PA 17405 PLEASE TAKE NOTICE that Defendants intend to serve nine (9) 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. JOHNSON, DUFFIE, STEWART & WEIDNER By a-'?) Jeffer n . Shipman, Esquire I.D. # 51785 P.O. Box 109 Lemoyne, PA 17043 DATE: I / x31-6 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 1 Gregory E. Martin, Esquire Law Offices of Dale E. Anstine 2 West Market Street P.O. Box 952 York, PA 17405 JOHNSON, DUFFIE, STEWART & WEIDNER By Jeffers J. Shipman, Esquire I . D. #: 1785 P.O. Box 109 Lemoyne, PA 17043 Attorneys for Defendant Young COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Meho Muskic and Remzija Muskic, Plaintiffs vs. Ruth Young, Defendant File No. 07-07258 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Cumberland Valley Pain Clinic (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, correspondence, diagnostic test results, pertaining to Meho Muskic DOB: 8/3/63 SSN: 157-06-8500 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: ADDRESS: TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: BY THE COURT: A 1j Prot notary/Cle it Divisi n Deputy DATE: _ ) IS o8 Seal f Me Court Jefferson J. Shipman, Esquire 301 Market Street Lemoyne, PA 17043 717-761-4540 51785 Defendant (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Meho Muskic and Remzija Muskic, Plaintiffs vs. Ruth Young, Defendant File No. 07-07258 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Orthopedic & Spine 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, reports, correspondence, diagnostic test results pertaining to Meho Muskic DOB: 8/3/63 SSN: 157-06-8500 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: ADDRESS: TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: DATE: l 8 o8 Seal of the Courts Jefferson J. Shipman. Esquire 301 Market Street Lemoyne. PA 17043 717-761-4540 51785 Defendant BY THE COURT: onotary/Clek, it ion Prot, Deputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Meho Muskic and Remzija Muskic, Plaintiffs vs. Ruth Young, Defendant File No. 07-07258 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Harrisburg Hospital/Pinnacle Health (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: an and all medical records a orts correspondence, diagnostic test results, pertaining to Meho Muskic DOB: 8063 SSN: 157-06-8500 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: ADDRESS: TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: DATE: / hOS Se dl of the Court Jefferson J. Shipman, Esquire 301 Market Street Lemoyne, PA 17043 717-761-4540 51785 Defendant BY THE COURT: Prot onbtary/Clerk ivis' n Deputy (Eff. 7/97) COMMONWEALTH OF PENN YLVANIA COUNTY OF CUMBERLAND Meho Muskic and Remzija Muskic, Plaintiffs vs. Ruth Young, Defendant File No. 07-07258 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO ULE 4009.22 TO: Belvedere 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 heports correspondence, diaonostic tes at Johnson, Duffie, Stewart & Weidner, 301 Market Street P.O. Oox 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: ADDRESS: TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: DATE: /$ D8 Seal f We Court Jefferson J. Shipman. Esquire 301 Market Street Lemoyne. PA 17043 717-761-4540 51785 Defendant BY THE COURT: f Proth nbtary/Clerk, , 1 ' ivi on Deputy (Eff.7/97) COMMONWEALTH OF PENN§YLVANIA COUNTY OF CUMBERLAND Meho Muskic and Remzija Muskic, Plaintiffs vs. Ruth Young, Defendant File No. 07-07258 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Appalachian Orthopedic 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, correspondence diagnostic test results, pertaining to Meho Muskic DOB: 8/3/63 SSN: 157-06-8500 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: ADDRESS: TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: DATE: 11181b 9 Seal o the Court Jefferson J. Shipman. Esquire 301 Market Street Lemovne. PA 17043 717-761-4540 51785 Defendant Deputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Meho Muskic and Remzija Muskic, Plaintiffs vs. Ruth Young, Defendant File No. 07-07258 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO ULE 4009.22 TO: Carlisle Regional 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 correspondence diagnostic tes at Johnson. Duffie, Stewart & Weidner, 301 Market Street P.O. Pox 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: ADDRESS: TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: DATE: l l8 08 Seal f the Court Jefferson J. Shipman. Esquire 301 Market Street Lemoyne. PA 17043 717-761-4540 51785 Defendant BY THE COURT: Protho tary/Clerk, ivisf n Deputy (Eff. 7/97) COMMONWEALTH OF PENN§YLVANIA COUNTY OF CUMBERLAND Meho Muskic and Remzija Muskic, Plaintiffs vs. Ruth Young, Defendant File No. 07-07258 TO: Orthopaedic Surgeons of Central Pennsylvania (Name of Person or Entity) Within twenty (20) days after service of this subpoena, ou are ordered by the court to produce the following documents or things: an and all medical records a orts correspondence, diagnostic tes at 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: ADDRESS: TELEPHONE: SUPREME COURT ID ATTORNEY FOR: DATE: //12 ky Seal of/the/Court Jefferson J. Shipman. Esquire 301 Market Street Lemoyne. PA 17043 717-761-4540 51785 Defendant BY THE'COURT: Proth tary/Clerk, ivi n Deputy (Eff.7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Meho Muskic and Remzija Muskic, Plaintiffs vs. Ruth Young, Defendant File No. 07-07258 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Zurich American Insurance Company (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 insurance recordt reports correspondence estimates including medical records regarding Claim # 2550258477 pertaining to Meho Muskic DOB: 8/3/63 SSN: 157-06-8500 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 _ DATE: / Slog Seal o th Court BY THE COURT: Prot notary/Clerk, iv' ivis' n Deputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Meho Muskic and Remzija Muskic, Plaintiffs vs. Ruth Young, Defendant File No. 07-07258 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: AIG Insurance Company (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 insurance records reports correspondence estimates including medical records regarding Policy No AIG 2336087 accident date of 12/23/05 pertaining to Meho Muskic DOB: 8/3/63 SSN: 157-06-8500 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 DATE: ($ As Seal f t He Court BY THE COURT: Proth notary/Clerk, ivi n Deputy (Eff. 7/97) Gy ?? c?a rr, r=' co :t !`.) _? r M MEHO MUSKIC and REMZIJA MUSKIC Plaintiffs V. RUTH YOUNG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-07258 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Jefferson J. Shipman., counsel for the Defendant in the above action respectfully represent that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiffs in the action is under $50,000. There is no counterclaim. The following attorneys are interested in the case as counsel, or are otherwise disqualified to sit as arbitrators: Gregory E. Martin, for Plaintiffs and Jefferson J. Shipman, for Defendants. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. )ectfully submitted, ,?TEWART & WEIDNER NSON, DUFFIE, F w 1 X411 J. Shipman, Attorney for Defendant ORDER OF COURT AND NOW, this day of 2008, in consideration of the foregoing petition, the following are appointed arbitrators in the above-captioned action: By the Court, P.J. 330300 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 41/z 1 O r Gregory E. Martin, Esquire Law Offices of Dale E. Anstine 2 West Market Street P.O. Box 952 York, PA 17405 Attorneys for Plaintiffs JOHNSON, DUFFIE, STEWART & WEIDNER Je ers5KJ. Shipmah, Esquire 1.131. #: 51785 PAD. Box 109 Lemoyne, PA 17043 Attorneys for Defendant Young 319989 od IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MEHO MUSKIC and REMZIJA MUSKIC, Plaintiffs V. RUTH YOUNG Defendant NO. 07-07258 CIVIL ACTION -LAW JURY TRIAL DEMANDED PETITION TO WITHDRAW AS COUNSEL 1. Petitioner, Gregory E. Martin, is a licensed attorney in the Commonwealth of Pennsylvania, with offices located at 2 West Market Street, York, Pennsylvania 17401. 2. The Respondents, Meho Muskic and Remzija Muskic (Plaintiffs captioned above), are adult individuals residing at 321 Bayley Street, Carlisle, Pennsylvania 17013. 3. Petitioner was retained by Respondent Meho Muskic to represent him for injuries allegedly sustained as the result of a motor vehicle accident that occurred on December 23, 2005. Remzija Muskic's claim is for loss of consortium. 4. The above-captioned action was instituted by way of the filing of a complaint on November 23, 2005. 5. The Defendant has been represented in this matter by Jefferson J. Shipman, Esquire, of the law firm of Johnson, Duffle, Stewart & Weidner, 301 Market Street, P.O. Box 109, Lemoyne, Pennsylvania 17043-0109. 6. Respondents have been uncooperative in the preparation of their claim, and Petitioner Yoar, Pexxe?wx?w5???os believes that there is a fundamental disagreement with the clients. 7. Petitioner wrote to Respondent Meho Muskic on May 22, 2008 and expressed his Doncerns and asked the Respondent to sign an affidavit agreeing to counsel's withdrawal of representation. 8. Respondent Meho Muskic signed a statement dated May 24, 2008 agreeing to Petitioner's request to withdraw as counsel in the above-captioned action. See Exhibit "A". 9. The matter was listed for compulsory arbitration by defense counsel and by order of the Honorable Edgar B. Bayley dated May 6, 2008, a board of arbitrators was appointed. See Exhibit "B". 10. An arbitration hearing has not yet been scheduled and Petitioner would ask that a reasonable time be allowed for Respondents to obtain new counsel. WHEREFORE, Petitioner respectfully requests that this Honorable Court permit the withdrawal of counsel in the above-captioned case, and the termination of representation of Meho and Remzija Muskic. RESPECTFULLY SUBMITTED: LAW OFFICES OF DALE E. ANSTINE P.C. Greg Dpf. Martin, Esquire Attorney I.D. #38894 Two West Market Street P.O. Box 952 York, PA 17405 (717) 846 - 0606 Yov. Pa.oeriv a i?aos IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MEHO MUSKIC and REMZIJA MUSKIC, Plaintiffs V. RUTH YOUNG Defendants : NO. 07-07258 : CIVIL ACTION -LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this day of June, 2008, I, Gregory E. Martin, Esquire, a member of the Law Offices of Dale E. Anstine, P.C., hereby certify that I have, this date, served a copy of the within and foregoing document by certified and first class United States Mail, postage pre-paid, addressed to the party or attorney of record as follows: Meho and Remzija Muskic 321 Bayley Street Carlisle, PA 17013 Jefferson J. Shipman, Esquire Johnson, Duffie, Stewart & Weidner P.O. Box 109 Lemoyne, PA 17043 Respectfully submitted: LAW OFFICES OF DALE E. ANSTINE, P.C. 3D.a ?,H E.sLwsTax;m, 9a. t'. Y ae. Pen.ertvwnu5txon 3 ALLSTATE LEGAL' 800-222-0510 e I, MEHO MUSKIC, DO HEREBY AGREE THAT GREGORY E. MARTIN, ESQUIRE AND THE LAW OFFICES OF DALE E. ANSTINE, P.C. CAN WITHDRAW AS COUNSEL ON MY BEHALF FOR THE MOTOR VEHICLE ACCIDENT THAT OCCURRED ON DECEMBER 23, 2005. THIS MATTER IS CAPTIONED IN CUMBERLAND COUNTY COURT OF COMMON PLEAS AS: MEHO MUSKIC AND REMZIJA MUSKIC PLAINTIFFS :07-07258 - CIVIL TERM V. RUTH YOUNG DEFENDANT DATED: ?2?-oe CIVIL ACTION - LAW JURY TRIAL DEMANDED M CA 0 M uskia? MEHO MUSKIC 0 ALL--T - LEGAL 800-222-0510 ED11 RECYCLED 0 0 MEHO MUSKIC and REMZIJA MUSKIC Plaintiffs V. RUTH YOUNG, 'APR 2 5 2008 MAY 0 7 2008 1 :[3y. ...... IN THE COURT OF COMMON PLEAS OF ebMSE41AND COUNTY, PENNSYLVANIA NO. 07-07258 CIVIL TERM CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED rr- r PETITION FOR APPOINTMENT OF ARBITRATORS ? yC TO THE HONORABLE, THE JUDGES OF SAID COURT: = rvi-r, Jefferson J. Shipman., counsel for the Defendant in the above action respectfully repre*ent that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiffs in the action is under $50,000. There is no counterclaim. The following attorneys are interested in the case as counsel, or are otherwise disqualified to sit as arbitrators: Gregory E. Martin, for Plaintiffs and Jefferson J. Shipman, for Defendants. WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. spectfully submitted, HNSON, DUFFIE, 5TEWART 8, WEIDNER efferson J. Shipman, Attorney for Defendant ORDER OF COURT AND NOW, this 4k day of /V t7,f 2008, in consideration of the foregoing petition, the following are appointed arbitrato in the above-captioned action: By the Court, 330300 R rRUE, OL C? C? ° ... ` oN ?r JUN 10 20081 Gregory E. Martin, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MEHO MUSKIC and NO. 07-07258 REMZIJA MUSKIC, Plaintiffs yore.. Perexerivnus ?? wn v. :CIVIL ACTION - LAW RUTH YOUNG, Defendant JURY TRIAL DEMANDED ORDER i AND NOW, this 10 day of upon due consideration of the Petition to Withdraw as Counsel, it is hereby Ordered and Directed that Gregory E. Martin, Esquire, and the Law Offices of Dale E. Anstine, P.C., are permitted forthwith to withdraw as counsel in the above- captioned matter; and the Plaintiffs shall be permitted E,r days to obtain new counsel before the scheduling of the arbitration hearing. cx_ cr: © G Q c JCL r .,.7 •,i.JU.i ? `gam ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MEHO MUSKIC AND REMZIA MUSKIC Plaintiffs V. RUTH YOUNG Defendant : CIVIL ACTION-LAW : NO. 07-07258 CIVIL TERM : JURY TRIAL DEMANDED PETITION TO COURT ADMINISTRATORS OFFICE REQUESTING ASSIGNMENT OF INTERPETER FOR PLAINTIFF AND now comes Meho muskic and Remzija Muskic by and through their attorney Anthony B. Andrezeski, Esquire. 1. Plaintiff Petitioners in the above captioned civil action are natives of the former country of Yugoslavia now regionally referred to as Bosnia. 2. Plaintiffs have a very limited understanding and command of the English language. 3. Plaintiffs are scheduled for Arbitration in the Law Office of Coyne & Coyne P.C. 3901 Market Street, Camp Hill PA 17011 before November 19, 2008. 4. For testimony and answers to be properly understood by all parties an interpreter is required. 5. Petitioners ask a proper translator of the Bosnian language be appointed by the Court Administrator. Now therefore, Anthony B. Andrezeski, Esquire asks the Court Administrator to appoint an interpreter of the Bosnian language for the Arbitration Hearing to be conducted before November 19, 2008 at the Law Office of Coyne & Coyne,3901 Market Street, Camp Hill PA 17011. This attorney also asks the Office of Court Administration to inform him of any other requirement to accomplish this action&nt For the Plaintiffs Meho and Remzija Muskic ony B. A drezeski, Esq ID 88995 317 ErFord Rd. Camp Hill, PA 17011 Phone 717-433-4191 A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MEHO MUSKIC AND REMZIA MUSKIC Plaintiffs v RUTH YOUNG Defendant : CIVIL ACTION-LAW NO. 07-07258 CIVIL TERM JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Anthony B. Andrezeski, Esquire verify and affirm under penalty of law the Petition to Court Administrator for Appointment of Interpreter has been sent via United States Post Office first class mail to the following: Jefferson J. Shipman, Esquire 301 Market Street PO Box 109 Lemoyne, PA 17043-0109 Henry F. Coyne, Esquire 3901 Market Street Camp Hill, PA 17011-4227 John A. Abom, Esquire 36 South Hanover Street Carlisle, PA 17013 Jane E. Adams, Esquire 64 South Pitt Street Carlisle, PA 17013 Anthony B. ndrezeski, ID 88995 317 Erford Rd. Camp Hill, PA 17011 Phone 717-433-4191 i k Esq. Date: 10/17/2008 t"} r.s c? ? {:; - ? -? r? _ ? `?:?tY ' ?? , ' .? An ? ? s _? ? ? r ? y P? ^< ?h:' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MEHO MUSKIC AND REMZIA MUSKIC : CIVIL ACTION-LAW Plaintiffs V. RUTH YOUNG : NO. 07-07258 CIVIL TERM Defendant : JURY TRIAL DEMANDED PROTHONOTARY Please enter my appearance in the above captioned civil action. Y *no y B. A drezeski, Esq. ID 88995 317 Erford Rd. Camp Hill, PA 17011 717-433-4191 Date: 10/17/2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MEHO MUSKIC AND REMZIA MUSKIC Plaintiffs RUTH YOUNG Defendant : CIVIL ACTION-LAW V. : NO. 07-07258 CIVIL TERM : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE 1, Anthony B. Andrezeski, Esquire verify and affirm under penalty of law my entry of appearance in above captioned case has been sent via United States Post Office first class mail to the following: Jefferson J. Shipman, Esquire 301 Market Street PO Box 109 Lemoyne, PA 17043-0109 Henry F. Coyne, Esquire 3901 Market Street Camp Hill, PA 17011-4227 John A. Abom, Esquire 36 South Hanover Street Carlisle, PA 17013 Jane E. Adams, Esquire 64 South Pitt Street Carlisle, PA 17013 Date: 10/17/2008 Anthony B. Andrezeski, Esq. ID 88995 317 Erford Rd. Camp Hill, PA 17011 Phone 717-433-4191 ca C MEHO MUSKIC and REMZIJA MUSKIC IN THE COURT OF COMMON PLEAS OF Plaintiffs CUMBERLAND COUNTY, PENNSYLVANIA RUTH YOUNG Defendant We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. 016 J'ku. Signature Signa Henry F. Coyne, Esquire John A. Abom, Esquire Chairman Abom & Kutulakis, LLP Coyne & Coyne, P.C. 36 South Hanover Street 3901 Market Street Carlisle, PA 17013 Camp Hill, PA 17011 c 1 A^ a 0 No. 07-07258 CIVIL TERM CIVIL ACTION - LAW OATH AWARD ea dams, Esquire Carlisle, PA 17013 ??ooay We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) W Date of Hearing: kk ej-2 Date of Award:. Mat, \7? Arbitrator, dissents. ame if applicable.) 1?d 44 A-Ao Henry F. Co e, squire e A. Abo s -e J hn J E. Adams, Esquire NOTICE OF ENTRY OF AWARD Now, the Rt?day of7&aer ?, 2008, at ")A O.m., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' ompensation t e paid upon appeal thonotary By: Deputy Ni r ? r v? ?7