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HomeMy WebLinkAbout03-6076 KAREN J. CHASE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ex3 - 007t;, DUSTIN R. RADER, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS To The Prothonotary: Please issue a Writ of Summons in the above captioned action and forward the Writ to the Sheriff of Cumberland County for service. The address of the Defendant is: Dustin R. Rader 112 Parkview Drive New Cumberland, PA 17070 Respectfully Submitted, Date: J/J J' /03 ~ ~ .......... -.c:. .{' ;.\ :i ~ ~ '\ "'- Of ~ is ~ '" " 'y T"': [ii'-' .,,;'>':" 2. cr' ~ ~': ~~. ,,--- ....' C> C' c:-- " . 87 '.'-~J ~L, - .. (0 .(; Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS KAREN J. CHASE Plaintiff Court of Common Pleas Vs. No. 2003-6076 In CivilAction-Law DUSTIN R RADER 112 PARKVIEW DRIVE NEW CUMBERLAND, P A 17070 Defendant To DUSTIN R. RADER You are hereby notified that KAREN J. CHASE the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date November 19, 2003 CURTIS R. LONG Protho~tary BY~ If)J De;:futy Attorney: Name: LAWRENCE J. NEARY, ESQ. Address: 108-112 WALNUT STREET HARRISBURG PA 17101-1609 Attorney for: Plaintiff Telephone: 717-2384798 Supreme Court ill No. 25827 TRUE COpy FR01,iJ ,..,'="0,....... In Te'ttim . ", n:::::.., nv ~ 1~"":C' I her,] U!1Iil r;i,! iIi'lI1;.md Tlli 'j, ~ sa! ou at Carlisle, Pa, ay 01 v. (,8 - '" Ilr; Prothon ry CASE NO: 2003-06076 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE KAREN J VS RADER DUSTIN R CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS RADER DUSTIN R the was served upon DEFENDANT , at 1242:00 HOURS, on the 10th day of November, 2003 at 3402 CHOCO WAY MECHANICSBURG, PA 17055 BETTY PYLE, GRANDMOTHER by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 22.08 .00 10.00 .00 50.08 Sworn and Subscribed to before ~( day of Cl/J?) ?J A.D. So Answers: ~~//~ R. Thomas Kline 12/11/2003 LAWRENCE NEARY By:. A,/ , ~7~ Deputy SHERIFF'S RETURN - REGULAR CASE NO: 2003-06076 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE KAREN J VS RADER DUSTIN R CPL. MICHAEL BARRICK Amended Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS RADER DUSTIN R the was served upon DEFENDANT , at 1242:00 HOURS, on the lOth day of December, 2003 at 3402 CHOCO WAY MECHANICSBURG, PA 17055 BETTY PYLE, GRANDMOTHER by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Amended Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 22.08 .00 10.00 .00 50.08 Sworn and Subscribed to before me this }!Y day of . ..7 ~--It1'~ ,;J tIO 'f A. D . ( t'.k_ () Jt~;-<-, ~ /p~thonotary I So Answers: ;:/ r%~~.::?/~ R. Thomas Kline ------ (/ , \ ."/ Jefferson J. Shipman, Esquire I.D. .51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendant KAREN J. CHASE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DUSTIN R. RADER, Defendant NO: 2003-6076 JURY TRIAL DEMANDED TO THE PROTHONOTARY: PRAECIPE PLEASE enter the appearance of the undersigned on behalf of the Defendant, Dustin R. Rader, in the above-captioned matter. GOLDBERG, KATZMAN & SHIPMAN, P.C. /<U< rson J. Shipm n, .0. Box 1268 HarriSburg, PA 17108-1268 Attorneys for Defendant DATE: 1/1 ~~ 105372 .1 CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon the person(s) indicated below by depositing a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania and addressed as follows on ,~q~i I I Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101 Attorney for Plaintiff GOLDBERG, KATZMAN & SHIPMAN, P.c. 17108 '" (-"~ c::. -.:. roo, <- =:':: -- ['.) -CJ (~) ...:' ,Tl <...,:"' en en '-, n "::-h .-1 :r:"'T! rnp.. -1"'1 fT1 ::-::9' '-,-'q " 1.J ::~"j Jefferson J. Shipman, Esquire 1.D. *51785 GOLDBERG, KATZ~ & SHIPMAN, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 counsel for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KAREN J. CHASE, Plaintiff vs. CIVIL ACTION - LAW NO: 2003-6076 DUSTIN R. RADER, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiffs to file a Complaint within twenty (20) days after service hereof, or suffer judgment of non pros. GOLDBERG, KATZMAN & SHIPMAN, P.C. ~ rson J. Ship Esquire .0. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant DATE: 0c;ff BYY TO: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101 Attorney for Plaintiff A Rule is hereby issued upon Plaintiff to file a Complaint against Defendant within twenty (20) days of service hereof, or suffer judgment of non pros. ~. L . (2~A-k.. J2 .~. _ DATE "JJ.0 -;(11 J..CXYI Curt Long, Pro tho ary 105371.1 CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon the person(s) indicated below by depositing a copy of the same in the United states mail, postage prepaid, at Harrisburg, Pennsylvania and addressed as follows on ~/It/~~ Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101 Attorney for Plaintiff GOLDBERG, KATZMAN & SHIPMAN, P.C. ,/,,( son J. Ship an, Esquire 20 Market Street P.O. Box 1268 Harrisburg, Pennsylvania 17108 Attorneys for Defendant -. r--.' C:.:l =~ o -;j :::-J ~,:- -n li1r= -,~rn ~:)C) t,) I _=.!C) ".j--f; ~_..) :2 ~ - ~- ( -', r-~I <- ::;.'. ;de: 1'.) -rj -:,. C;,? en ~-i KAREN J. CHASE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2003-6076 DUSTIN R. RADER, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take action within twenty (20) days after this Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Two Liberty Avenue Carlisle, Pennsylvania 17013-3387 Telephone: (717) 249-3166 Date: c!{ J iri. /0 ~ I , KAREN J. CHASE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2003-6076 CIVIL ACTION - LAW JURY TRIAL DEMANDED DUSTIN R. RADER, Defendant COMPLAINT AND NOW, comes the Plaintiff, Karen J. Chase, by her attorney, Lawrence J. Neary who respectfully represents as follows: 1. Plaintiff, Karen J. Chase, is a single adult individual residing at 1308 Kelton Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant, Dustin R. Rader, is an adult individual now residing at 3402 Choco Way, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. On November 19, 2001 at or about 11 :30 a.m., Plaintiff was the operator of a motor vehicle traveling south on 18th Street in Lower Allen Township, Cumberland County, Pennsylvania, at which time and place the Defendant, who was traveling in the same direction, caused or allowed his vehicle to collide into the rear end of the Plaintiff's vehicle. 4. This accident resulted solely from the negligence and recklessness of the Defendant herein and was due in no manner whatsoever to any act or failure to act on the part of the Plaintiff. 5. The negligence and recklessness ofthe Defendant consisted of the following: a. Failure to properly operate and control his motor vehicle. b. Driving at an excessive rate of speed under the circumstances. c. Operating his vehicle without due regard for the rights, safety and position of the Plaintiff at the point aforesaid. d. Following another vehicle more closely than is reasonable and prudent under the circumstances. e. Operating his vehicle in violation of the statutes ofthe Commonwealth of Pennsylvania pertaining to the operation of vehicles on the streets and highways. 1. Failing to keep a reasonable and proper look out on the highway for other vehicles. g. Failing to stop his vehicle within the assured clear distance ahead. h. Failing to exercise a degree of care, caution and skill reasonable required under all the circumstances. i. Failing to have his vehicle under proper control so as to prevent this vehicle from striking the Plaintiff's vehicle. j. Failing to notice the vehicle of the Plaintiff. k. Failing to take evasive action in order to avoid impacting with the Plaintiff's vehicle. 6. As a result of this accident, Plaintiff has suffered serious injuries which have resulted in a serious impairment of a bodily function and permanent disfigurement, including neck pain, right sided pain, right sided neck strain, low back pain, numbness in the right arm and left arm, tenderness in the paracervical muscles, painful cervical range of motion, herniated disc at C5-6 level, acute exacerbation of chronic neck pain, cervical mylelopathy, anterior cervical discectomy at C5-6 and fusion, cataract formation and extraction in the left eye with posterior chamber lens implant, cataract formation and 2 extraction and lens implant in the right eye; severe damage to the nerves and nervous system, and various other ills and injuries. 7. As a further result of this accident, Plaintiff has been obliged to receive and undergo medical attention and care and to incur various expenses which expenses may exceed the sum recoverable under the limits in 75 P.S. 9 1711 and may be obliged to continue to expend such sums or incur such expenditures for an indefinite time in the future. 8. As a further result of this accident, Plaintiff has suffered a loss of earnings and impairment of earning capacity which such loss of income and/or impairment of earning capacity or power may exceed the sum recoverable under the limits in 75 P.S. 91711. 9. As a further result ofthis accident, Plaintiff has suffered severe physical pain, mental anguish, inconvenience, humiliation, and loss of life's pleasures and may continue to suffer the same for an indefinite time in the future. WHEREFORE, Plaintiff demands judgment against the Defendant in an amount in excess of $35,000.00 plus costs of suit. Respectfully Submitted, Date: .;( / (J.. ) ~ + I ( 3 VERIFICATION I verify that the statements made in the attached Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: I/"(J /dtf- I . ~~.~~ CERTIFICA TE OF SERVICE I, Lawrence J. Neary, attorney for the Plaintiff, hereby certify that I have on the date shown below served a copy of the foregoing Complaint to the person and in the manner indicated below: UNITED STATES FIRST CLASS MAil, POSTAGE PREPAID Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman, P.C. P.O. Box 1268 Harrisburg, PA 17108-1268 Respectfully Submitted, Date: o?J/~ 10+ I ' e o <;~.~ -0 i" ,',\ .-> "" C? ~ .." g 't._ .'.;..- ~-, :2 --' Q, -' -r:-n rn r-: -nn1 -"'1' (J,e) ~J-: :;4 (~~ ~~~ \::~ ~.tJ '-< ~-: -" 9 u> u> Jefferson J. Shipman, Esquire I.D. '51785 GOLDBERG, KATZMAN' SHIPMAIl, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendant KAREN J. CHASE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DUSTIN R. RADER, Defendant NO: 2003-6076 JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Plaintiff YOU ARE HEREBY notified to plead to the within New Matter of Defendants within twenty (20) days of service hereof. GOLDBERG, KATZMAN & SHIPMAN, P.C. on J. Shipma , Esquire .0. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant DATE: s/I%f 107049.1 Jefferson J. Shipman, Esquire I.D. '51785 GOLDBERG, KATZMAN' SHIPMl\N, P.C. 320 Market Street P. O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendant KAREN J. CHASE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DUSTIN R. RADER, Defendant NO: 2003-6076 JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT, DUSTIN RADER. TO PLAINTIFF'S COMP~NT AND NOW, comes the Defendant, Dustin Rader, by and through his attorney, Jefferson J. Shipman, and files the following Answer and New Matter to Plaintiff's Complaint: 1. Admitted upon information and belief. 2. Admitted. 3. Admitted in part, denied in part. It is admitted that on November 19, 2002 at or about 11:30 A.M., the Plaintiff was the operator of a motor vehicle traveling south on lsth Street in Lower Allen Township, Cumberland County, Pennsylvania, It is also admitted that the Defendant, Mr. Rader, was traveling in the same direction and that there was contact made between the front of his vehicle and the rear of the Plaintiff's vehicle. The remaining averments of Paragraph No, 3 are denied as conclusions of law and fact. 4. Denied. The averments contained in Paragraph 4 are conclusions of law and fact to which no response is required. 5. Denied. The averments contained in Paragraph 5, subparagraphs (a) through (k) 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. 6. Denied. After reasonable investigation, Mr. Rader is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 6, relating to Plaintiff's alleged injuries, and the same are therefore denied and strict proof demanded at the time of trial. 7. Denied. After reasonable investigation, Mr. Rader is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 7 and the same are therefore denied and strict proof demanded at the time of trial. 2 8. Denied. After reasonable investigation, Mr. Rader is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 8, relating to Plaintiff's alleged loss of income and or impairment of earning capacity, and the same are therefore denied and strict proof demanded at the time of trial. 9. Denied. After reasonable investigation, Mr. Rader is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 9, relating to Plaintiff's alleged physical pain, mental anguish, inconvenience, humiliation and loss of life's pleasures, and the same are therefore denied and strict proof demanded at the time of trial. WHEREFORE, the Defendant, Dustin R. Rader, respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. NEW MATTER By way of additional answer and reply, Defendant interposes the following New Matters: 3 10. This action is subject to the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. S1701, ~ ~. 11. That Plaintiff's claims may be limited or barred by the Limited Tort Option pursuant to 75 Pa. C.S.A. S1705, ~~. 12. That if it should be found that there was any negligence on the part of the Defendant, which negligence is expressly denied, any such negligence was not a proximate cause of any damages to the Plaintiff. 13. That if the Plaintiff suffered the injuries alleged in the Complaint, those injuries may have been caused in whole or in part by the negligence of the Plaintiff and recovery in this action is barred or diminished in accordance with the Pennsylvania Comparative Negligence Act. 14. That the Plaintiff may have failed to mitigate her damages. 15. That the Plaintiff's alleged cause of action may be barred by the applicable statute of limitations. 16. That the Plaintiff's injuries and damages were not caused of any acts, omissions, or breaches of duty by the Defendant. 4 WHEREFORE, the Defendant, Dustin R. Rader, respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. Respectfully submitted: GOLDBERG, KATZMAN & SHIPMAN, P.C. J fe s n J. Sh pman, Esquire Attorney I.D. 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Defendant 107047.1 5 VERIFICATION I, Dustin R. Rader, hereby acknowledge that I am a Defendant in this action, and I have read the foregoing Answer and New Matter and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject me to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. a~ Li/ Dustin R. Ra er Date: 107047.1 CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon the person(s) indicated below by depositing a copy of the same in the United states mail, postage prepaid, at Harrisburg, Pennsylvania and addressed as follows on March 8, 2004: Lawrence J. Neary, Esquire 108-112 Walnut street Harrisburg, PA 17101 Attorney for Plaintiff GOLDBERG, KATZMAN & SHIPMAN, P.C. . Je fe on J. S pman, Esquire 3 Market Street P.O. Box 1268 Harrisburg, Pennsylvania 17108 Attorneys for Defendant 105375.1 (j ,..., 0 e:J c:::;} -n ,L- ::1-: --I -T". ;,;: "' r; 1 ::oJ ::.-u ;'1 -r' ?_~ yl (~) . '.",.' -, j ,:1 , ., ~) :- rn t;., "---'~j, r" _J -, Johnson. Duffie, Stewart & Weidner By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com Attorneys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KAREN J. CHASE, v. Defendant NO. 2003-6076 CIVIL ACTION - LAW JURY TRIAL DEMANDED DUSTIN R. RADER, CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.:l2 TO: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101-1609 Attorney for Plaintiff As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas attached thereto, was mailed, via Certified Mail, or dellivered 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 recElived; and (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. By: fferson ,I. Shipman, Esquire Attorney 1.0: No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Date: q/ /3 }()l-f CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of records by depositing the same in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, on the i 3M day of 5(l f ~ (V\ b <: r, 2004, addressed as follows: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101-1609 By: Jeff rson J. Shipman, Esquire Attorney I.D. No. 51785 301 Market Street P.O. Box 1109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys flJr Defendant Johnson. Duffie, Stewart & Weidner By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com AttomE~Ys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KAREN J. CHASE, v. NO. 2003-6076 DUSTIN R. RADER, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101-1609 Attorney for Plaintiff PLEASE TAKE NOTICE that Defendant intends to serve four 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, thiS subpoenas may be served. UFFIE, STEWART & WEIDNER By: Date: 'b l:J '1/ 0 '7 on J. Shipman, Esquire Atto ey I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of records by depositing the same in the United States Mail, certified postage prepaid, at Lemoyne, Pennsylvania, on the! JJ-j+h day of /i-uJ" ,t ,2004, addressed as follows: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101-1609 UFFIE, STEWART & WEIDNER on J. Shipman, Esquire Atto ey I.D. No. 51785 301 Market Street P.O. Box 1019 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant . By: KAREN J. CHASE, Plaintiff COMMONWEALTH OF PENNSYLVANI,~ COUNTY OF CUMBERLAND IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-6076 CIVIL TERM vs. DUSTIN R. RADER, Defendant CIVIL ACTION - LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Hershev 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 foliowing documents or things:anv and ali medical records. corres[)ondence. reoorts and diaanostic test results oertainina to Karen J. Chase SSN: 198-44-9848 DOB: 6/3/5~ at Johnson. Duffie. Stewart & Weidner. 301 Market Street. P.O. Box 109. Lemovne. PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance. the reasonabie 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 I~ompeliing you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: Jefferson J. Shioman. Esauire 301 Market Street Lemovne. PA 17043 717-761-4540 51785 TELEPHONE: SUPREME COURT 10 #: BY THE COURT: ;jn~-L' Prothonotary/Clerk, Civil Divisio DATE: 0.. ~. J" ., ^6'f ~ <...... d,n~ ~(? ?f/?A..rY. r Deputy (Eff.7/97) KAREN J. CHASE, Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-6076 CIVIL TERM vs. DUSTIN R. RADER, Defendant CIVIL ACTION - U\W SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE4009.22 TO: Hummelstown Familv Practice (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you arei ordered by the court to produce the foUowing documents or things: anv and aU medical records. correslJondence. reoorts and diaonostic test results oertainino to Karen J. Chase SSN: 198-44-9848 DOB: 6/3/S8 at Johnson. Duffie. Stewart & Weidner. 301 Market Street. P.O. Box 109. Lemovne. PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party m<lking 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 ilubpoena 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: Jefferson J. Shioman. Esouire 301 Market Street Lemovne. PA 17043 717-761-4540 51785 TELEPHONE: SUPREME COURT ID #: BY THE COUFn: 0.tA-b.' . Prothonotary/Clerk, Civil Dlvisi DATE: {)u.~.;I..3 ~C>dj Seal of e Cour! (... a ~/?-J'-P /pL7A'----yl._____ Deputy (Elf. 7/97) KAREN J. CHASE, Plaintiff COMMONWEALTH OF PENNSYLVANI,~ COUNTY OF CUMBERLAND IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-6076 CIVIL TERM vs. DUSTIN R. RADER, Defendant CIVIL ACTION - LAW SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Tristan Associates (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: anv and all medical records. corres[)ondence. reoorts and diaonostic test results oertainino to Karen J. Chase SSN: 198-44-9848 DOB: 6/3/5j! at Johnson. Duffie. Stewart & Weidner. 301 Market Street. P.O. Box 109.. Lemovne. PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order I~ompeliing you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: Jefferson J. Shioman. Esquire 301 Market Street Lemovne. PA 17043 717-761-4540 51785 TELEPHONE SUPREME COURT ID #: BY THE COURT: (J .(/,-h - . Prothonotary/Clerk, Civil Division '---- ~ /1", ~' [? DATE: J)u~ .JJJ ~ Seal of he Couh Deputy (Elf. 7/97) vs. COMMONWEALTH OF PENNSYLVANI,~ COUNTY OF CUMBERLAND IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-6076 CIVIL TERM KAREN J. CHASE, Plaintiff DUSTIN R. RADER, Defendant CIVIL ACTION - LA.W SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Holv Soirit Hosoital (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: anv and all medical records. corresoondence. reoorts and diaanostic test results oertainina to Karen J. Chase SSN: 198-44-9848 DOB: 6/3/5Ia at Johnson. Duffie. Stewart & Weidner. 301 Market Street. P.O. Box 109. Lemovne. PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party mailing 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 #: Jefferson J. Shioman. Esauire 301 Market Street Lemovne. PA 17043 717-761-4540 51785 BY THE COURT: pro~!n~;:~fe'rk' cL DiVision " 6~ p 7f~u~; ~ DATE flu fie :1.1 :l~oY' Seal of t Cour~ (Elf. 7/97) ....., = c) C:::;, -'1"1 .r- ~""i,:,) (/) --J u. r" :1. '. rn ~TI -i) j"". ,'--n ?g~.) J:"" () '1, ~: ; H1C_~ ~T': r. ,r_,-n ';;.:.r) C- f',' C5irl - ' , =2. = ',J W .< Johnson. Duffie, Stewart & Weidner By: Jefferson J. Shipman 1.0. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com Attonneys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-6076 KAREN J. CHASE, v. DUSTIN R. RADER, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.2~t TO: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101-1609 Attorney for Plaintiff As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas attached thereto, was mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoenas were sought to be served; (2) A copy of the Notice of Intent including the proposed subpoenas, is attached to this Certificate; (3) No objection to the subpoenas has been received; the twenty day waiting period was waived; and (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. DUFFIE, STEWART WEIDNE~ ~~ By: Je rson J. Shipman, Esquire Attorney 1.0. No. 51785 301 Market Street P.O. Box 10'9 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Date: ~l;;Jlj()r CERTIFICATE OF SERVICIi I HEREBY CERTIFY that I served a true ancl correct copy of the foregoing document upon all counsel of records by depositing the same in the United States Mail, .. sF first class postage prepaid, at Lemoyne, Pennsylvania, on the dl day of J'L,Vl e. ,2005 addressed as follows: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101-1609 . By: . ... "81M..a.M.J f Je erson J.&hipman, Esquire Attorney I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Johnson. Duffie, Stewart & Weidner By: Jefferson J. Shipman I.D.No.51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 lis@jdsw.com Attomeys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-6076 KAREN J. CHASE, v. DUSTIN R. RADER, CIVIL ,ll.CTION - LAW Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101-1609 Attomey for Plaintiff PLEASE TAKE NOTICE that Defendant intends to serve three 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 maybe served. JOHNSON, DUFFIE, STEWART & WEIDNER Date: c./ qJ <lb' By: Je rso ,Shipman, Esquire Att mey I.D. No. 51785 301 Market Street P.O. Box 1Cl9 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant . CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of records by depositing the same in the United States Mail, certified postage prepaid, at Lemoyne, Pennsylvania, on thl3 q+h day of ~,( (1 e , 2005, addressed as follows: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101-1609 UFFIE, STEWART & WEIDNER Jeff son J. Shipman, Esquire Attorney 1.0. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PJ\ 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant By: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Karen Chase, Plaintiff vs. File No. 2003-607' Dustin R. Rader, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Harvev U. Fracht. M.D. of Hershev 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. corresl~ondence. reports and diaonostic test results includino all pharmacy records pertainino to Karen Chase SSN: 198-44-9848 DOB: 6/3/58 at Johnson. Duffie. Stewart & Weidner. 301 Market Street. P.O. Box 109 lemovne. PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOllOWING PERSON: NAME: ADDRESS: Jefferson J. Shipman. Esouire 301 Market Street lemovne. PA 17043 717-761-4540 51785 Defendant TELEPHONE: SUPREME COURT 10 #: ATIORNEY FOR BY THE COURT: ~<d~' Prothonotary/Clerk, Civil '-- ..#~ ~P. '/flY.b"-'-< / Deputy DATE ~ )/1,)E. P ::;VY'J ~ Seal of the Court (Eft. 7197) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Karen Chase, Plaintiff vs. File No. 2003-60i~ Dustin R. Rader, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: G. Timothv Reiter. M.D. of Hershev 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. correslDondence. reports and diaonostic test results from June 2004 to the present pertainino to Karen Chase SSN: 19B-44-984B DOB: 6/3/5B at Johnson. Duffie, Stewart & Weidner. 301 Market Street. P.O. Box 109. Lemovne. PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: Jefferson J. Shioman. Esauire 301 Market Street Lemovne, PA 17043 717-761-4540 517B5 Defendant TELEPHONE: SUPREME COURT 10 # ATTORNEY FOR: BY THE COURT '---- ./?a~P.'plH'~7J r Deputy {Jh~ Prothonotary/Clerk, Civil Division DATE: ~D3S (Eft 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Karen Chase, Plaintiff vs, File No, 2003-607' Dustin R, Rader, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dr. John J, Schietroma (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: anv and all medical records, correspondence. reeorts and diaonostic test results from eertainino to Karen Chase SSN: 19B-44-9B4B DOB: 6/3/5B at Johnson, Duffie, Stewart & Weidner. 301 Market Street. P.O. Box 109, Lemovne, PA 17043, You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above, You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order c:ompelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: SUPREME COURT ID #: ATIORNEY FOR: Jefferson J. Shieman, Esouire 301 Market Street Lemovne, PA 17043 717-761-4540 51785 Defendant BY THE COURT ~ -1/1-61 Prothonotary/Clerk, Civil Division DATE: '- L, ~ ~ d.~ Seai of the Co rt '- /t./U;M ~P. 7pr.l7/2/L f DeputY' (Elf. 7197) (') ....., ~ ..:.:.::;:') ~:; {:::;:> cfO '-- -l :x: " c; rn:::!) ...'- r- ,,) -(73 ~.iJ 1'-' 9(:) ..", ;' ::~~ ,~ , :,~ (, t."'! l'':; i~i 1 -- ~;: ". -:! ,,) ;Q -, co - Johnson. Duffie, Stewart & Weidner By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com Attorneys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KAREN J. CHASE, v. NO. 2003-6076 DUSTIN R. RADER, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 TO: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101-1609 Attorney for Plaintiff As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas attached thereto, was mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoenas were sought to be served; (2) A copy of the Notice of Intent including the proposed subpoenas, is attached to this Certificate; (3) No objection to the subpoenas has been received; the twenty day waiting period was waived; and (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. JOHLj' _D~7'.~~:~~:~~~~~~E~~~:: A H . ~ /,.' .I" ,v~ By: I J erson J. Shipman, Esquire Attorney 1.0. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Date: <il / n( Or; CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of records by depositing the same in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, on the (I M day of HIAJIA'l T- , 2005 addressed as follows: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101-1609 '- By: J erson J. Shipman, Esql,li$.,...,lL Attorney 1.0. No. 51785 .. ...;'il',H;lf' 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Johnson. Duffie, Stewart & Weidner By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com Attomeys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KAREN J. CHASE, v. NO. 2003-6076 DUSTIN R. RADER, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101-1609 Attorney for Plaintiff PLEASE TAKE NOTICE that Defendant intends to serve two 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. Date: ~/ /&/o"f DUFFIE, STEWART WEIDNE~ By: Je rson J. Shipman, Esquire Attorney I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of records by depositing the same in the United States Mail, certified postage prepaid, at Lemoyne, Pennsylvania, on the /11+11 day of A'^Jl1 ,sf , 2005, addressed as follows: Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101-1609 , DUFFIE, STEWART & WEIDNER . By: Je rson J. ShipmC!n, Esquire Attorney I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant ,.." COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Karen Chase, Plaintiff vs. File No. 2003-6076 Dustin R. Rader, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Hershev 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: MRI of the Cervical seine factual fllml dated 7/22104 and CT of Cervical seine factual fllml dated 7/22/04 eertainina to Karen Chase SSN: 198-44-9848 DOB: 6/3/58 at Johnson. Duffie, Stewart & Weidner. 301 Market Street. P.O. Box 109, Lemovne. PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: Jefferson J. Shieman. Esauire 301 Market Street Lemovne. PA 17043 717-761-4540 51785 Defendant TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: BY THE COURT: '----- ~t'V1P P. 77z0( /7/1' u--- Deputy DATE: .-fJ I.J 9. 1/ ::JI)O-.S Seal oflhe Coul1 (Elf. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Karen Chase, Plaintiff vs. File No. 2003-6075 Dustin R Rader, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Tristan Associates (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are or-dered by the court to produce the following documents or things: MRI of the Cervical sDine factual film) dated 9t25/02 DertaininQ to Karen Chase SSN: 198-44-9848 DOB: 6/3/58 at Johnson. Duffie. Stewart & Weidner. 301 Market Street. P.O. Box 109. lemovne. PA 17043. You may deliver or mail legibie 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: Jefferson J. Shioman. Esquire 301 Market Street Lemovne. PA 17043 717-761-4540 51785 Defendant TELEPHONE: SUPREME COURT 10 #: ATTORNEY FOR: /Z;o~P/2~:~~ Deputy "'- DATE (J/~. ///:JnoS Seal of e Court (Eff.7/97) n ~:; r--' .::::::' c::;:) <:J"l. ". 1,..-:::: (..') , ~. ":;::~ ~ co o -fi --' :C-n nlr~ ('1 ""'() \~J -U, (~(~) ~-[:.:n <;.?,C:) ;~';, 1: n. :::-:, 5; :< -0 ::.:. <f! ......' (..0 i - Lawrence J. Neary, Esquire 108-112 Walnut Street Harrisburg, PA 17101-1609 (717) 238-4798 (717) 238-4793 - Fax Email: Ijnearyesq@aol.com KAREN J. CHASE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-6076 CIVIL ACTION - LAW JURY TRIAL DEMANDED DUSTIN R. RADER, Defendant PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the above captioned action ended, settled and discontinued and all costs have been paid. t-j/).I!OG I I Respectfully Submitted, ", . I J '-t Date: . . CERTIFICATE OF SERVICE I, Lawrence J. Neary, Esquire, attorney for the Plaintiff, hereby certify that I have on the date shown below served a copy of the foregoing Praecipe to Discontinue to the person and in the manner indicated below: UNITED STATES FIRST CLASS MAil, POSTAGE PREPAID Jefferson J. Shipman, Esquire Johnson, Duffie, Stewart and Weidner, P.C. 301 Market Street Lemoyne, PA 17043 Respectfully Submitted, I Date: If le.)/ / If b f /1 il Lawre . ce J. Ne ,Esquire . Attwn'ey for Plai iff /, 108-112 Walnut Street I i Harrisburg PA 17101-16Q~) (717)238-4798 . (717)238-4793 - Fax PA I.D. No. 25827 /