HomeMy WebLinkAbout08-1096ORIGINAL
R. J. MARZELLA & ASSOCIATES, P.C.
BY: Zachary D. Campbell, Esquire
Pennsylvania Supreme Court I.D. No. 93177
3513 North Front Street
Harrisburg, PA 17110
E-Mail: zcampbell@rjmarzella.com Attorneys for Plaintiffs
Telephone: (717 2347828 Christine Harris and Kenneth Harris
Facsimile-, (717) 2346883
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CHRISTINE HARRIS and KENNETH HARRIS
Docket No.: Q$- ??(P l:?lvi(
Civil Law
Plaintiffs
V.
MICHAEL HILLEGAS, Jr.
Defendant
JURY TRIAL DEMANDED
NOTICE TO DEFEND
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
Court your defense 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 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
32 South Bedford Street
Carlisle, PA
(717)249-3166
Docket:
NOTICIA
Le han demandado a usted en la corte. Si usted guiere defenderse de estas demandas
expuestas en las paginas siguintes, usted tiene viente (20) dias de plaza al partir de la fecha de la
demanda y la nontificacion. Usted debe presentar una apariencia escrita o en persona o por
abogado y archivar en la corte en forma escrita sus defensas o sus objectiones a las demandas en
contra de su p esona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede
entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es
pedido en la peticion de demanda. Usted pueda perder dinero o sus propiedades o otros derechos
importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTA. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA
EN PERSONA O LLAME POR TELEFONO A LA LFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PEUDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA
(717)249-3166
Dated: 02 11 LL
2
Respectfully submitted,
R. J. Marzella & Associates, P.C.
By:
Zachar e2tification bell, Esquire
No. 93177
Docket:
R. J. MARZELLA & ASSOCIATES, P.C.
BY: Zachary D. Campbell, Esquire
Pennsylvania Supreme Court I.D. No. 93177
3513 North Front Street
Harrisburg, PA 17110
E-Mail: zcampbell@rjmarzella.com Attorneys for Plaintiffs
Telephone: (717) 234-7828 Christine Harris and Kenneth Harris
Facsimile-, (717) 234-688
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Docket No.: 0j- /a 94 CL;d
CHRISTINE HARRIS and KENNETH HARRIS Civil Law
Plaintiffs
V.
MICHAEL HILLEGAS, Jr.
Defendant JURY TRIAL DEMANDED
COMPLAINT
Parties to the Action
1. Plaintiff, Christine Harris, is an adult individual, residing at 22 Rabbit Lane,
Newville, Pennsylvania, 17241.
2. Plaintiff, Kenneth Harris, is an adult individual and husband of Plaintiff,
Christine Harris, 22 Rabbit Lane, Newville, Pennsylvania, 17241.
3. Defendant, Michael Hillegas, (hereinafter, "the Defendant") is an adult
individual, at all times relevant hereto, resided at 540 Brentwater Road, Camp Hill,
Pennsylvania, 17011.
I
Docket:
Summary of Causes of Action
4. On or about April 4, 2006, at approximately 4:00 p.m., Courtney Parker,
was driving with her Aunt, Christine Harris, on Third Street near the intersection with
Market Street in Lemoyne, Pennsylvania.
5. At the time of the accident at issue in this Complaint, Mrs. Harris was
seated in the front passenger seat of the automobile that her niece was operating and
she was properly wearing her seatbelt.
6. Mrs. Parker was driving up the incline of Third Street traveling away from
the intersection of Market and Third Streets in Lemoyne.
7. As the women drove up the hill, the traffic in front of them slowed for a
traffic signal ahead.
8. Unbeknownst to Mrs. Parker and Mrs. Harris, the Defendant was traveling
directly behind her vehicle on Third Street at a high rate of speed.
9. The Defendant accelerated up the incline on Third Street.
10. However, it is believed and therefore averred that the Defendant was not
paying attention and did not see the vehicles stopped in traffic immediately ahead of
him.
11. Due to the speed the Defendant maintained, he could not stop and avoid
the vehicle that Mrs. Harris was traveling in and his vehicle violently struck the rear of
Plaintiff's vehicle.
12. Both Mrs. Parker and Mrs. Harris' bodies were jerked forward and then
back by the force of the collision.
2
Docket:
13. Although wearing a seatbelt at the time of the collision, the force of the
impact caused Mrs. Harris' head to violently jerk forward and then back before colliding
into the headrest of the vehicle.
14. Mrs. Harris was immediately stunned and disoriented after the collision.
15. She turned to her pregnant niece to make sure she was all right.
16. Mrs. Parker and Mrs. Harris were able to extricate themselves from the
vehicle, which did not sustain significant damage because of its large size.
17. Mr. Hillegas also was able to pull himself out of his vehicle, which was a
Ford Mustang and sustained significant damage in the collision.
18. The Defendant's vehicle struck the Plaintiffs vehicle with such force that it
became lodged underneath the rear of the Mrs. Parker's vehicle.
19. An off-duty, deputy fire chief witnessed the rear end collision and stopped
I to ensure that no one was seriously injured.
20. Mrs. Harris immediately began suffering pain in her neck and back, while
sitting at the accident scene.
21. Mrs. Harris was concerned for the well being of her niece, who was
almost six months pregnant at the time of the accident.
22. Mrs. Parker immediately decided to call her Obstetrician-Gynecology
practice because of her concern that her unborn child may have been injured during the
collision.
23. Mrs. Parker was instructed by her physician to proceed to the nearest
hospital emergency room.
3
Docket:
24. Mrs. Parker contacted her husband via telephone and they were
transported to the hospital.
25. Because her immediate concern was for her niece, Mrs. Harris did not
I seek immediate treatment at the hospital.
26. However, a nurse in the room where Mrs. Parker was being monitored in
I the hospital noticed that Mrs. Harris was in pain and provided her with Tylenol.
27. Fortunately, no immediate health concerns were discovered for Mrs.
Parker or her unborn child and she was discharged after several hours at the hospital.
28. That night, Mrs. Harris' pain continued to worsen in her head, back and
especially neck.
29. As a result, Mrs. Harris immediately made an appointment to be evaluated
by her family physician, Dr. Donald Kovac.
30. The following day, on or about April 5, 2006, Mrs. Harris was diagnosed
with cervical and lumbar strains, prescribed Flexeril and ordered to follow up in a week.
31. As instructed, Mrs. Harris returned to her family physician on or about
April 10, 2006, with continued complaints of neck pain and stiffness.
32. At that time, her physician prescribed a higher dosage of a different
muscle relaxant and ordered her to follow up as needed.
33. Over the next two weeks, Mrs. Harris continued to suffer from severe pain
in her neck, continued headaches and difficulties sleeping because of the pain.
4
Docket:
34. Mrs. Harris returned to see her family physician on or about May 10,
2006, and he ordered her to begin physical therapy at the Rehabilitation Options of the
Carlisle Regional Medical Center in Carlisle, Pennsylvania.
35. Mrs. Harris began physical therapy on or about May 25, 2006.
36. Over the course of the five (5) months, Mrs. Harris underwent several
sessions of physical therapy, which provided some relief from her neck pain.
37. From May 25, 2006 until October 18, 2006, Mrs. Harris attended two to
three physical therapy sessions per week.
38. Mrs. Harris was eventually discharged from physical therapy, because it
was believed that she had reached the optimum amount of relief that she could expect
to achieve at that point with physical therapy.
39. Mrs. Harris continued to suffer from neck pain and headaches. She
attempted to continue with a home exercise program shown to her at physical therapy,
but still suffered from severe pain.
40. In the summer of 2006, Mrs. Harris was referred to an orthopedic surgeon
for treatment.
41. A MRI was obtained of Mrs. Harris' neck, which revealed a disc protrusion
in her neck.
42. The orthopedic surgeon referred Mrs. Harris to the Carlisle Regional Pain
Management Clinic.
43. In August 2006, Mrs. Harris began treating with Dr. Daniel Chess at the
?ain Management Clinic.
5
Docket:
44. From August 2006 to January 2007, Mrs. Harris underwent three (3)
epidural steroid injections and two trigger point injections by Dr. Chess, which provided
little if no relief to Mrs. Harris.
45. Mrs. Harris also was forced to utilize a TENS unit for the pain in her neck,
while she underwent additional physical therapy during this time.
46. At that point, since she has received the maximum number of allowable
injections, she was discharged from pain management treatment and it was
recommended that she consult with a neurosurgeon because of the continued severe
neck pain and headaches.
47. Mrs. Harris eventually was referred to the Neurology Center, P.C. in May
2007 and was treated by Dr. Ravi Dukkipati.
48. Over the next seven months, Mrs. Harris received several injections of
Botox into her neck on the advice of Dr. Dukkipati.
49. Although these injections alleviated some of her symptoms, Mrs. Harris
continues to suffer from near constant pain in her neck.
50. To date, Mrs. Harris is still treating with her physicians, including Dr.
Dukkipati, because she continues to suffer from pain related to her injuries caused by
the accident.
51. It is believed and therefore averred that Mrs. Harris will endure future
medical treatment, including but not limited to injections and surgical intervention on
her neck.
Docket:
52. As a direct and proximate result of the negligence of the Defendant,
Plaintiff, Mrs. Harris, has suffered severe injuries, physical pain, and mental suffering.
53. As a direct and proximate result of the negligence of the Defendant as
alleged herein and incorporated by reference, Plaintiff, Mrs. Harris, has been and will
continue to be forced to incur liability for medical treatment, medicines, hospitalizations
and similar miscellaneous expenses and a claim is made therefore.
54. As a direct and proximate result of the negligence of the Defendant as
alleged herein and incorporated by reference, Plaintiff, Mrs. Harris, has undergone and in
the future will undergo great physical pain and suffering, great inconvenience in carrying
out their daily activities, loss of life's pleasures and enjoyment, and emotional distress
and a claim is made therefore.
55. As a direct and proximate result of the negligence of the Defendant as
alleged herein and incorporated by reference, Plaintiff, Mrs. Harris, has undergone and in
the future will be subject to great humiliation, disfigurement and embarrassment and a
claim is made therefore.
56. As a direct and proximate result of the negligence of the Defendant as
alleged herein and incorporated by reference, Plaintiff, Mrs. Harris, has sustained in the
past and will sustain in the future a loss of earnings and a claim is made therefore.
57. As a direct and proximate result of the negligence of the Defendant as
alleged herein and incorporated by reference, Plaintiff, Mrs. Harris, has been advised and
therefore avers, that the damages and injuries alleged herein are permanent and a claim
is made therefore.
7
Docket:
58. As a direct and proximate result of the negligence of the Defendant as
alleged herein and incorporated by reference, the vehicle driven by Defendant Michael
Hillegas, Jr., collided with the rear of Plaintiffs vehicle causing Plaintiff to sustain severe,
extensive and permanent personal injuries that required medical treatment and therapy,
and may require medical treatment and therapy in the future, and a claim is made
therefore.
59. As a direct and proximate result of the negligence of Defendant, Plaintiff,
Kenneth Harris, has been deprived of the care, companionship, and services of his wife,
Christine Harris, for all of which damages are claimed.
COUNTI
CHRISTINE HARRIS V. MICHEAL HILLEGAS
60. The allegations contained in Paragraphs 1 through 59 of Plaintiffs'
Complaint are incorporated herein by reference as if fully set forth.
61. Regarding the accident, which is the subject matter of this Complaint,
Defendant Michael Hillegas, Jr. was negligent, careless, and reckless in the operation of a
motor vehicle in the following particulars:
(a) operating his vehicle in violation of the ordinances of the Commonwealth
3f Pennsylvania pertaining to the operation of motor vehicles, including but not limited
:o reckless driving and traveling at an unsafe speed;
(b) failing to have the vehicle under proper and adequate control in order to
top or avoid striking the Plaintiffs vehicle;
Docket:
(c) failing to keep an appropriate lookout to avoid striking the Plaintiffs
vehicle;
(d) failing to maneuver his vehicle appropriately in order to avoid striking
Plaintiffs vehicle;
(e) operating the vehicle without due regard for the rights, safety, well-being,
and position of Plaintiff under the circumstances;
(f) failing to lawfully stop at a traffic control device;
(g) failing to bring his vehicle to a stop safely behind the vehicle Mrs. Harris
was traveling in, which was lawfully stopped on the roadway.
(h) failing to operate his vehicle at a safe rate of speed under the
circumstances; and
(i) negligently driving at an unsafe speed.
WHEREFORE, Plaintiff, Christine Harris, demands judgment against Defendant
Michael Hillegas, Jr., in an amount in excess of FIFTY THOUSAND DOLLARS ($50,000.00),
together with interest and costs thereon as allowed by law.
COUNT 11- LOSS OF CONSORTIUM
KENNETH HARRIS V MICHAEL HILLEGAS jR
62. The allegations contained in Paragraphs 1- 59 and Count I of Plaintiffs'
Complaint are incorporated herein by reference as if fully set forth.
9
Docket:
63. As a direct and proximate result of the negligence of Defendant, Plaintiff,
Kenneth Harris, has been deprived of the care, companionship, services, society and
consortium of his wife, Christine Harris, for all of which damages are claimed.
WHEREFORE Plaintiff, Kenneth Harris, demands judgment against Defendant,
Michael Hillegas, Jr., in an amount in excess of FIFTY THOUSAND DOLLARS ($50,000.00),
together with interest and costs thereon as allowed by law.
Dated; 2 1-7/ZOOg
Respectfully submitted,
R. J. Marzella & Associates, P.C.
By: 7-i?
Z ha Campbell, Esquire
Atto 1 ntification No. 93177
to
Docket:
VERIFICATION
We, Christine and Kenneth Harris, do hereby swear and affirm that the facts and
matters set forth in the foregoing document are true and correct to the best of our
knowledge, information and belief.
We understand that the statements made therein are made subject to the
penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities.
1 a px
Dat d
l 1"'
, J0 Dated
(. ? 1 O
Christine Harris
TA 0.1ZT?J111
Kenneth Harris
Ln r
p
'
C'3 l
O
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-01096 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HARRIS CHRISTINE ET AL
VS
HILLEGAS MICHAEL JR
NOAH CLINE
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
HILLEGAS MICHAEL JR
the
DEFENDANT
, at 1735:00 HOURS, on the 27th day of February-, 2008
at 540 BRENTWATER ROAD
CAMP HILL, PA 17011
MICHAEL HILLEGAS JR
by handing to
a true and attested copy of COMPLAINT & NOTICE
INTERROGATORIES, REQUEST FOR
PRODUCTION OF DOCUMENTS
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
31/.16 Y 1.
So Answers:
18.00
13.44 ??
.58 10.00 R. Thomas Kline
.00
? 42.02 02/28/2008
RJ MARZELLA
Sworn and Subscibed to
before me this
By: ,
?Z-
day Deputy Sheriff
of A. D.
Jeffrey T. McGuire
Attorney I.D. #73617
CALDWELL & KEARNS
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
Attorneys for Defendant
CHRISTINE HARRIS and
KENNETH HARRIS,
Plaintiffs
vs.
MICHAEL HILLEGAS, Jr.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
DOCKET NO. 08-1096 Civil Term
: CIVIL LAW
JURY TRIAL DEMANDED
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of Michael Hillegas, Jr., Defendant in the above-
captioned matter.
Dated: '->?b 6S By:
submitted,
& KEARNS
JeftrX T. McGuire, Esquire
t rney I.D. No. 73617
631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
CERTIFICATE OF SERVICE
I hereby certify that I have served a copy of the within document thiso2t?' day of
2006, on the following by depositing a true and correct copy of the
same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to:
Zachary D. Campbell, Esquire
R. J. MARZELLA & ASSOCIATES, P.C.
3513 North Front Street
Harrisburg, PA 17110
CALDWELL & KEARNS
0662 1-094/1 30590
nip
,
r
y~ t?
Caldwell & Kearns, P.C.
Jeffrey T. McGuire, Esquire
Attorney I.D. No. 73617
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
(717) 232-2766 (fax)
jmcguire@caldwellkeams.com
Attorneys for Defendant
COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND
CHRISTINE HARRIS AND KENNETH
HARRIS,
Plaintiffs,
vs.
MICHAEL HILLEGAS, JR.,
Defendant.
FILE NO. 08-1096
CIVIL LAW
JURY TRIAL DEMANDED
CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO
RULE 4009.22
As a prerequisite to service of a subpoena for documents and things pursuant to Rule
4009.22, Defendant certifies that:
1
2
3
4.
A Notice of Intent to Serve Subpoena with a copy of the subpoena attached thereto
was mailed or delivered to each party at least twenty days prior to the date on which
the subpoena is sought to be served;
A copy of the Notice of Intent to Serve Subpoena, including the proposed subpoena,
is attached to this certificate;
No objection to the subpoena has been
The subpoena which will be served'is i
the Notice of Intent to Serve
Date: By:
; and
to the subpoena which is attached to
J,e f y T//IcGuire, Esquire
Nd'
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
Attorney for Defendant
E
?.
Caldwell & Kearns, P.C.
Jeffrey T. McGuire, Esquire
Attorney I.D. No. 73617
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
(717) 232-2766 (fax)
.mcguire@caldwellkearns.com
Attornevs for Defendant
COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND
CHRISTINE HARRIS AND KENNETH
HARRIS,
Plaintiffs,
FILE NO. 08-1096
CIVIL LAW
vs.
MICHAEL HILLEGAS, JR.,
Defendant.
JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND
THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
To: Zachary D. Campbell, Esquire
R.J. MARZELLA & ASSOCIATES, P.C.
3513 North Front Street
Harrisburg. PA 171 10
Defendant intends to serve a subpoena identical to the one that is attached to this notice.
You have twenty (20) days from the date listed below in which to file of record and SCI-Ve upon the
undersigned an objection to the subpoena. If no objection is made the subpoena may be served.
Respectfiijs?.?bmitted,
Date: By:
CALDWELL &KEARNS
Fee McGu)'fe, Esquire
7361: z
North Front Street
Harrisburg, PA 17110
(717) 232-7661
Attorney for Defendant
COMMONWEALTH OF PENNSYLVAI\LI\
COUNTY OF CUMBERLAND
CHRISTINE HARRIS and KENNETH
HARRIS,
Plaintiffs, File , --
v.
MICHAEL HILLEGAS, JR.,
Defendant.
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
Custpdi n of Record
TO: j ppjalachian Orthope5ic Center Ltd.
?nt,,oQ (lri, f arl is1P, P? 1701
(]vame of Person or Entity)
Within nventy (20) days after service of this subpoena. you are ordered by the court to produce the
following documents or things:
at 3631 North Front?Sr?et, Ha?z??btrrc,_P1?-131-10 ----
(Address)
You rrmv 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 tlus subpoena v,,Ithin 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 RL•QIIEST OI--TIIE FOLLOWING PERSON:
NAN,IE:_Jeffrev_ McG uire Esquire
ADDRESS: _3SL3-1-i?Qr_t_h__Front Street
- -H,aLLisburq_, __PA__ 17-1-10
TELEPHONIE: 71 7 - 2 32- 7 6 61
SUPREME COURT ID 7 3 h 1 7 _____-_
ATTORNEY FOR:Defendanty. BY THE COURT:
Prothonotary, Civil Division
Date:
'Sea] of die Court i?epur:
EXHIBIT A
Entire medical, billing, and diagnostic file, including but not limited to any and all
records, correspondence to and from the consulting and/or treating physicians, files.
memoranda, handwritten notes, history and physical reports. medication/prescription
records, medical billing and payment records, x-ray films and tests with subsequent
reports, including any and all such items as may be stored in a computer database or
otherwise in electronic form, relating to any examination, consultation, diagnosis, care or
treatment pertaining to:
NAME: Christine L. Harris
DOR: 09/17/1959
Date of Loss: 04/041106
Dates Requested: Any and all records from 09/17/1959 to present
06621094-130595
• Caldwell & Kearns. P.C.
Jeffrey T. McGuire, Esquire
Attorney I.D. No. 73617
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
(717) 232-2766 (fax)
jmcyuirencaldwellkearns.com
Attorneys for Defendant
COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND
CHRISTINE HARRIS AND KENNETH
HARRIS,
Plaintiffs,
FILE NO. 08-1096
CIVIL LAW
vs.
MICHAEL HILLEGAS, JR.,
Defendant.
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
AND NOW thisZU?day of F%=1 _ 2008, I hereby certify that I have served a copy
of the foregoing Subpoena to Produce Documents and Things for Discovery Pursuant to Rule
4009.21 in the above captioned action on all counsel of record by forwarding a tnie and correct
copy of same by First Class United States Mail, postage prepaid, addressed to the following:
Zachary D. Campbell, Esquire
R.J. MARZELLA & ASSOCIATES, P.C.
3513 North Front Street
Harrisburg, PA 171 10
By: ( ?'l^
Caldwell & Kearns, P.C.
Jeffrey T. McGuire, Esquire
Attorney I.D. No. 73617
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
(717) 232-2766 (fax)
jmcguire@caldwellkeams.com
Attorneys for Defendant
COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND
CHRISTINE HARRIS AND KENNETH
HARRIS,
Plaintiffs,
FILE NO. 08-1096
CIVIL LAW
vs.
MICHAEL HILLEGAS, JR.,
Defendant.
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
AND NOW thia0day of ?, 2008, I hereby certify that I have served a copy
of the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 and
Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 in the above
captioned action on all counsel of record by forwarding a true and correct copy of same by First
Class United States Mail, postage prepaid, addressed to the following:
Zachary D. Campbell, Esquire
R.J. MARZELLA & ASSOCIATES, P.C.
3513 North Front Street
Harrisburg, PA 17110
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2010 .JAN -5 AM 11: k 5
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R. J. MARZELLA & ASSOCIATES, P.C. 9W
BY: Zachary D. Campbell, Esquire
Pennsylvania Supreme Court I.D. No. 93177
3513 North Front Street
Harrisburg, PA 17110
E-Mail: zcampbell@rjmarzella.com Attorneys for Plaintiffs
Telephone: (717) 234-7828 Christine Harris and Kenneth Harris
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CHRISTINE HARRIS and KENNETH HARRIS
Plaintiffs
Docket No.: 08-1096
Civil Law
V.
MICHAEL HILLEGAS, Jr.
Defendant
JURY TRIAL DEMANDED
PRAECIPE TO DISCONTINUE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please mark the above-referenced action settled and discontinued, with prejudice
as to all of the above named Defendants.
Dated: 2. LA[2-?oOr
Respectfully submitted,
R. J. MARZELLA & AssoclATEs, P.C.
BY:
ACH CAMPBELL, ESQUIRE
ID 177
3513 NORTH FRONT STREET
HARRISBURG, PA 17110-1438
(717) 234-7828
Docket:
CERTIFICATE OF SERVICE
I, Cynthia von Schlichten, hereby certify that a true and correct copy of the
foregoing document was served upon counsel of record this 29' day of
December, 2009, by depositing said copy in the United States Mail at Harrisburg,
Pennsylvania, postage prepaid, first class delivery, and addressed as follows:
Jeffrey T. McGuire, Esquire
Caldwell & Kerns
3631 North Front Street
Harrisburg, PA 17110
Counsel for Defendant
R. J. MARZELLA & AssoclATEs, P.C.
BY:
CYNT IA VON SCHLICHTEN, LAw CLERK TO
ZACHARY CAMPBELL, ESQUIRE