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Home My WebLink About04-0879 II IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~~1in ~. :+lngftJe. N\o..r1~\JI'~el Pit 11653 No. c:P/ - ~7'l CaJ VS. Lee E. Minnick W ~ f{) LDV\dcvvJ..er<,"( U 166)( a.. D Hwr;s1~, PA Civil Action at Law \,IO? PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. a~ ~ure of Attorney ~ Mary A. Etter Dissinger Dissinger & Dissinger 28 North 32nd Street Camp Hill, PA 17011 Supreme Court ID No. 27736 Date: March 1, 2004 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE HEREBY NOTIFIED THAT THE ABOVE-NAMED AGAINST YOU WHICH YOU ARE REQUIRED TO DEFEND ENTERED AGAINST YOU. DATE: flfauA I. ...2CkJY by ';!?~AAP -P.~.k, 95' , l' 'I.... , , ' ......,.::"...,a f~l. \\A\" f io 4 -~. . , ~ ~, ~ ~ i0 "(\ ~, ",-, ' '^ \ ~ U\ 1.1 ~ J\ :\ \ \:) V\ \\ ,I:] ~ 0 ~ '\ '\. " '" l) , ~ ~ ~~~ r-_.) C.; I~ " , \1\) ',--/ f.....'} <:- ~) ..J.::- -n ........ "-' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-00879 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RINGLEY ROBIN R VS MINNICK LEE E R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MINNICK LEE E but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within WRIT OF SUMMONS On March 17th, 2004 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 30.50 .00 67.50 03/17/2004 DISSINGER & lS~~" ' /. -,//---~ S:~~~~_:~' R. Thomas Kline Sheriff of Cumberland County DISSINGER Sworn and subscribed to before me this /~ day of ~ .:/Arb'! A.D. Il {l >>;;117,.. ~ '-I"1"Prothonotary In The Court of Common Pleas of Cumberland County, Pennsylvania Robin R. Ringley VS. Lee E. Minnick SERVE: same No. 04-879 civil Now, March 2, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ./"'lJ ,/A' ~~...-. _do. .r" ".t~,:"::'/' ~ *,.?'.i.e;?~~..,.,~t;::~., ,/ i'/..J~~.~ ~ .. ~r ~4_G';~~ .~ SheriffofCumherlandCounty, PA Affidavit of Service Now, ,20_, at 0' clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDA VIT $ $ @ffb::e llf flp~ ~4~J:iff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania RINGLEY ROBIN R vs Connty of Dauphin MINNICK LEE E Sheriff's Return No. 1638-T - -2004 OTHER COUNTY NO. 04-879 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for MINNICK LEE E the DEFENDANT named in the within WRIT OF SUMMONS and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, March 10, 2004 NEED BETTER ADDRESS 11TH day l'{ MARCH, 2004 j \ Ii. "'\ , ~ i'?~'/,-1t,,(t) /'1 So Answers, Jf~ Sworn and subscribed to before me this Sheriff of Dauphin County, Pa. PROTHONOTARY By Deputy Sheriff Sheriff's Costs: $30.50 PD 03/09/2004 RCPT NO 189845 ~ ~~. " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY iRobin R. Ringley 414 Myrtle Avenue Marysville, PA 17053 No. 04-879 Civil vs. Lee E. Minnick 301 N. Progress Avenue Harrisburg, PA 17110 Civil Action at Law PRAECIPE TO REINST,ATE To The Prothonotary: Please reinstate the attached Writ of Summons. note that the Defendant's address has changed). ,) , ~~nature 0 torne Karen L. Koenigsberg Supreme Court ID #85556 Dissinger & Dissinger 28 N. 32nd Street Camp Hill, PA 17011 (717)975-2840 (Please Date: //7/6<-/ , , g ...., = ~ => z- .r- ;:R ti, C- ~ n t6 c= m:D '7 , ... Z~~: I ~~ ~::: -.I c::c; ~-, ~ z~' ~~ ~2 ~ s. Z :J~ ::;l Ul ~ ~ CD PLAINTIFF HAS COMMENCED AN ACTION OR A DEFAULT JUDGEMENT MAY BE ,<~o~ 1 by ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Robin R. Ringley 41'-/ M'{r-neJ AVeJ'UL (Y)Q/',c;v;lkJPA 1')65) vs. , ~ r--' c;::) C;,} -=- No. tfJl/ -~7f l~) ~ -- :..,-' ,- (,.\ Lee E. Minnick 1 D I IJ . p~f'{SS AvvlL(..<., \-tatri 5bw'1 3 PA t')ll 0 J PRAECIPE FOR WRIT OF SUMMONS r......, Civil Action at ~~\II .-- '::-::> ~-.-, -< TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. c---;7/( Signature of Attorney Mary A. Etter Dissinger Dissinger & Dissinger 28 North 320d Street Camp Hill, PA 17011 Supreme Court ID No. Date: March 1. 2004 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT: YOU ARE AGAINST ENTERED HEREBY NOTIFIED THAT THE ABOVE-NAMED YOU WHICH YOU ARE REQUIRED TO DEFEND AGAINST YOU, DATE: I11rvJ I. d(}~~' -..."" r;? l'O .s-- c") -n .-l :J: .,", \'11 r::O -'~Jr,,: .','t.lO i~~:~~.t !_'-\?':?1 ;~; ~:] .,,- 27736 '1/'" ,..,,~, '" " . \ , " '", >1: \>' Y',. . . " ~, ~ (") ~ ~ r; ~ ..,.. iR[:i'; <... ~::o trT'j [Q -;:.i._, r- ~F , ]j~ le: ~s', --.l 0 ~~~...' :t'. Y-ri ;;;:;,---., .. ~Ji ...-- 0_ Z', - -r;:C") ;;:;0 om ~~ 'to 3:~ ~ c:..., co -< '. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBIN RINGLEY, n/kla ROBIN SNYDER CIVIL DIVISION Plaintiff, No: 04-879 Civil vs. LEE E. MINNICK, Defendant. PRAECIPE FOR ENTRY OF APPEARANCE (substitution of counsel without leave of court pursuant to Rule 1012(b)(2)(ii) TO THE PROTHONOTARY: Please enter my appearance on behalf of Plaintiff, Robin Ringley, now known as Robin Snyder, in the above-captioned matter. I hereby certify that this change is not intended to, nor will it, delay this proceeding to the best of my knowledge, information and belief. Papers may be served at the address set forth below. Berger Law Firm, P.C, 2104 Market Street Camp Hill, PA 17011 (717) 920-8900 (Phone) (717) 920-8901 (Fax) Date: November 15,2004 0 r-.:> 0 = r::; c:,) -n .... ,: .....~ .--4 ..,:''.... :'C -r\ C ...c: p1 f"c, -nni -:.1C::t (J) ~~3, ~1) . -~. , 1 ~ ( ") ::,1 :'ii: ..:- ~ 0 -' - rn L CO ,~:) ~~ .. :~~ C- ) -' ::-.: " -.l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBIN RINGLEY, n/kla ROBIN SNYDER CIVIL DIVISION Plaintiff, No: 04-879 Civil vs. LEE E. MINNICK, Defendant. PRAECIPE TO REISSUE WRIT OF SUMMONS TO THE PROTHONOTARY: Please reissue the Writ of Summons upon Lee Minnick, 2515 S. 33rc1 St, Astoria, NY 11102 and provide the reissued writ to counselor counsel's representative for service. Service will be provided by certified mail with required receipt pursuant to Rules 403 and 404 of the Pennsylvania Rules of Civil Procedure. Date: November 15, 2004 i t2J(5\- ~ J Edmund J. Berger \ Attorney 1.0. #53407 Berger Law Firm, P.C. 2104 Market Street Camp Hill, PA 17011 (717) 920-8900 (Phone) (717) 920-8901 (Fax) 0 ,...", c) c:.~ c: = "Tj ~,' ... .-1 ,', -.' -r; ," ...i:!" ,.~ "'""l~~ , , C) (Ii fI1 Q} -:r.:: - -orr'; c?; ", "/J? --t;+ Ul f.:~~ ~>~) r~L , '- " , , }~ .. ::;::\"1 :\~} I -.,',.... 0 C ......... rn ....-... (' co ~. -,~ ....~ '., ~\:"' -') -~ O'l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBIN RINGLEY, n/kla ROBIN SNYDER CIVIL DIVISION Plaintiff, No: 04-879 Civil vs. LEE E. MINNICK, Defendant. MOTION FOR SERVICE BY PUBLICATION Pursuant to Rule 430 of the Pennsylvania Rules of Civil Procedure, Pa.R.C.P. 430, Plaintiff respectfully requests the Court issue an order that service of the defendant be permitted by publication. In support of this request, Plaintiff respectfully submits as follows: 1. Plaintiff originally filed a Praecipe for a Writ of Summons on March 1, 2004. The Sheriff of Dauphin County then attempted service at 4570 Londonderry Road, Harrisburg, PA 17109 and 301 N. Progress Avenue, Harrisburg, PA 17110 but was unable to locate the Defendant at these previous known addresses. 2. The Writ of Summons was then reinstated on July 7, 2004 and service was again attempted without success. A return of service was filed by the Sheriff on August 27,2004. The return of service indicated that Defendant had moved to North Carolina but no forwarding information was available for Defendant. 3. On November 17, 2004, counsel for Plaintiff (which had changed to current counsel on November 1, 2004) reinstated the Writ of Summons and sought to have the Sheriff serve the Defendant by certified mail at a possible current address that - 1 - had been obtained through a search service based on publicly available government information. This address was 2515 S. 33rd St, Astoria, NY 11102. Service was again unsuccessful and a return of service was provided on December 17, 2004. Prior to this attempt at service, counsel for Plaintiff contacted or attempted to contact numerous neighbors at this address but was unable to confirm Defendant's location. Plaintiff also attempted to contact family members of the Defendant to obtain information regarding his whereabouts but was unable to reach them and received no return phone calls. Counsel has also attempted to contact family members of Defendant by going to the address where they are believed to live but there was no response. 4. Counsel has notified Defendant's insurance company and they have been unable to provide any information on Defendant's whereabouts. WHEREFORE, Plaintiff respectfully requests that service be permitted by publication in the Harrisburg Patriot-News as the newspaper which serves the area of Defendant's most recent known residence and the residence, Plaintiff believes, of several family members. Date: February 4, 2005 Edmund J. Berge Attorney 1.0. #53407 Berger Law Firm, P.C. 2104 Market Street Camp Hill, PA 17011 (717) 920-8900 (Phone) (717) 920-8901 (Fax) -2- r~ ( s;~ SJ, ..., C:::.:> <:.:;',:) .....n r-~ ~il :~ -'1 I'T') OJ I ;;.- ~? _.t,.. .c- y '.~,," r 8 2'~'lC l __~) L) .........J r', j '} IN THE COURT OF COMMON PLEAS OF CUMBERLAN[1 COUNTY, PENNSYLVANIA ROBIN RINGLEY, nlkla ROBIN SNYDER CIVIL DIVISION Plaintiff, No: 04-879 Civil vs, LEE E. MINNICK, Defendant. OR~ AND NOW, this~ of ~05, the Court grants Plaintiff's Motion for Service by Publication. The Plaintiff shall provide service by publication in the Harrisburg Patriot-News as the location of the Defendant's last known address. BY THE, COURT / ~D0 ,\0 O~ I 7 .' 1 ! ~'~,' f"': "'~, . ll. U n::J ----------- SHERIFF'S RETURN - U.S. CERTIFIED MAIL CASE NO: 2004-00879 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RINGLEY ROBIN R VS. MINNICK LEE E R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,MINNICK LEE E by United States Certified Mail postage prepaid, on the 18th day of November ,2004 at 0000:00 HOURS, at 2515 S 33RD STREET ASTORIA, NY 11102 a true and attested copy of the attached WRIT OF SUMMONS Together with The returned receipt card was signed by on 00/00/0000 Additional Comments: ENVELOPE WAS RETURNED TO SHERIFF'S OFFICE STAMPED RETURNED TO SENDER - UNCLAIMED. Additional Comments Docketing Service Affidavit Surcharge 18.00 4.42 .00 10.00 .00 32,42 ~ ,,';:..:-c~ S,o, a annsweTI>.~",s.::,,// c/<::/--- ~'~->.-/./.- ---~ y~ /' .- R :-Thom~:Kl~ Sheriff of Cumberland County Sheriff's Costs: Paid by BERGER LAW FIRM on 12/17/2004 . Sworn and subscribed to before me this 1... II< day of l\f)n'4~ c4'V4 A.D. eli:' . Ofr.<jp,.) ~ P~t onotary , ..... ~.. ,.. () 1\1 .... ,.. , r.:: . - ::!:t ~~ ~....- c-.::::co o ~- C& "' "'~o ~ -\ u ;;.", , , 1'"'" {:.) ~ (') 0(') '" 0 ~......=c f/) _I Z ,on - 0 ID ::;! , ~~ 00 :J~..."'T1 "g-t(') ~"':rc <<DID;:: "'(/) CD 2..0 en m 0);:1":0 -&.""" CD I ""'J CD .. )> o -- Z W =0 -,J co co w ru ru IT" co co co co co '" -,J co -,J ru '" co '" .. o .. .. ,. .. .. ................,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBIN RINGLEY, n/kla ROBIN SNYDER CIVIL DIVISION Plaintiff, No: 04-879 Civil vs. LEE E. MINNICK, Defendant. PRAECIPE TO REISSUE WRIT OF SUMMONS TO THE PROTHONOTARY: Please reissue the Writ of Summons upon lee Minnick, 8325 Thunder Road, Hogan Creek, Lincoln, MT 59639 and provide the reissued writ to counselor counsel's representative for service. Service will be provided by certified mail with required receipt pursuant to Rules 403 and 404 of the Pennsylvania Rules of Civil Procedure. Date: February 28, 2005 Edmund J, Berger Attorney I. D. #5340 Berger law Firm, P.C. 2104 Market Street Camp Hill, PA 17011 (717) 920-8900 (Phone) (717) 920-8901 (Fax) !--) -; :t- ., c; 'iJ.. ...... fP ~ :>> -::z L-O " tv , , F\!'ILES\DA TAFlJ,E\Tra\elers3090\Cun-ent\822_p'J I\marn Oea\e<.l, (J{2Cli04 i)(lGPM Revised 3/3/05804AM 3090822 George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS & OTTO 1.D, No, 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant ROBIN R RINGLEY Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 04-879 CIVIL ACTION - LAW LEE E. MINNICK, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTS ON DEARDORFF WILLIAMS & OTTO on behalf of Defendant in the above matter. Defendant hereby demands a twelve juror jury trial in the above captioned action, MARTS ON DEARDORFF WILLIAMS & OTTO By Ge B, a ler, Jr., J.D, No, 49813 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant Dated: ~) 7.) c5 . CERTIFICATE OF SERVICE I, Melissa A. Mowery, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A. first class mail, postage prepaid, addressed as follows: Tad Berger, Esquire BERGER LAW FIRM, P,C 2104 Market Street Camp Hill, PA 17011 MARTSON DEARDORFF WILLIAMS & OTTO B/ ':\Z\C CC1DC\ C l(lln, (LtG' Melissa A Mowery Ten East High Street ' , Carlisle, P A 17013 (717) 243-3341 Dated: ~)\3) CD I" r-.....') ....~.::~ W'") ,r';:"" r,., (7:: c.) ------ F,IFILESIDA T AFILEI Tfavelers3090\C~lTent\822\pnt2\mam Creatoo: 9120104 0:06PM Revised: 8/29105 835AM 3090822 George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. No. 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant ROBIN R. RINGLEY Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-879 CNIL ACTION - LAW LEE E. MINNICK, Defendant. JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue a rule upon the Plaintiff to file a Complaint within twenty (20) days from service thereof or suffer judgment of non pros. Defendant hereby demands a twelve juror jury trial in the above captioned action. By: Dated: August 29, 2005 George B. Fal r, Jr" Esquire 1.0. No, 49813 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant RULE AND NOW, this -l~ay of {)f..t9usf- ,2005, a Rule is issued upon the Plaintiff to file a Complaint within twenty (20) days from service hereof. CERTIFICATE OF SERVICE I, Melissa A. Mowery, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Tad Berger, Esquire BERGER LAW FIRM, P.e. 2104 Market Street Camp Hill, P A 17011 MARTSON DEARDORFF WILLIAMS & OTTO By: (('{~,rln; Q. ~~'E() Melissa A Mowerv Ten East High Str~et Carlisle, PA 17013 (717) 243-3341 Dated: August 29, 2005 (} (co r-> "'" '8> -;r c: c;.) N <.P ,~,- 'l y~ So ~y ':2 ~ .... :t:-<' 0'e <-,,1; ~.f)~ i~?1~\ -,:"'" .."'I~ ....~ \")-t~ ;.:.:J-"> --, '8 :2; '-P. '-" J;:" uP' -IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY RINGLEY Vs. NO. 04879 MINNICK CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 GEORGE B FALLER JR, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s) . Date: 09/22/05 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-4907 File #: M324756 By: Patrice Laporte 'IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY RINGLEY Vs. MINNICK No. 04879 TO: TAD BERGER, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 09/01/05 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-4907 By: Patrice Laporte Enc(s): Copy of subpoena(s) Counsel return card File #: M324756 <XlMMJNWEM,TH OF PENNSYLVANIA 0JUN1'Y OF aJMBERIAND RINGLEY Vs. Fi Ie No. 04 8.?--2-..,___.____~ MINNICK SUBPOENA TO PRODUCE DCCI..M:NTS OR TH I NGS FOR 0 I SCOVERY PURSUANT TO RULE 4009. 22 NEW HAMPSHIRE INDEM/AIG, PO BOX 8220, CORAOPOLIS PA 15108 TO: __A.'tTN: LAURA WEBER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunent!'l or things: SEE ATTACllliD ADDENDUM at MEDICAL LEGAL REPRODUCTIONS{A~~SS~940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested h) this subpoena, together with the certificate of carp liance , to the party making thi, request at the address 1i sted above. You have the right to seek in advance the rea sonab 1 E cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within t~enty (20) days after its serv~ce, the party serving thin ~;ubpoena may seek a court orde.' c:arpelling you to carply with it. TH I S SUBPOENA WAS NAI"E: ADDRESS : ISSUED AT THE REQUEST OF THE FOLLONING PERSON: GEORGE B FALLER JR, ESQ 10 E nlaH ST CARL1~L~, ~A 17013 TELF.PH:lNE: SUPREI1: COJRT I D # ATTORNEY FOR: 215-335-3212 49813 DEFENDANT BY THE <XlURT: I Division M324756-02 DATE: .{r-=./.,. > 1.2.. 2Pa5___ S I of the Court , , . Deputy (Eff. 1/97) ADDENDUM TO SUBPOENA RINGLEY Vs. No. 04879 MINNICK CUSTODIAN OF RECORDS FOR: J LERUE HESS AGENCY COMPLETE AUTOMOBILE INSURANCE FILE PERTAINING TO ROBIN R RINGLEY, AIG POLICY #AIG 9926427. PERTAINING TO: NAME: ROBIN R RINGLEY ADDRESS: 414 MYRTLE AVE MARYSVILLE PA DATE OF BIRTH: 01/07/68 SSAN: 209460752 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS X-RAYS PATIENT BILLING RECORDS / XRAYS have been destroyed Date Authorized s1gnature for J LERUE HESS AGENCY CUMBERLAND M324756-01 *** SIGN AND RETURN THIS PAGE *** aJMMJNWV,LTH OF PENNSYLVANIA axJNTY OF aJMBEmAND RINGLEY VS. File No. 04879 MINNICK SUBPOENA TO PROOlX:E DOC\..t'ENTS OR TH I NGS FOR DISCOVERY PURSUANT TO RULE 4009. 22 TO: J LERUE HESS AGENCY, PO BOX 38, DUNCANNON PA 17020 II'P'T'N. (,T,II TMS DEPT (Nane of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following document~ or things: SEE ATTAClIED ADDKNDUM at MEDICAL LEGAL REPRODUCTIONS~A~~ss1940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested hi this subpoena, together with the certificate of carp liance , to the party making thi, request at the address listed above. You have the right to seek in advance the rea">onablE 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 serv~ce, the party serving thin ~;ubpoena may seek a court orde;' carpe 11 ing you to carply with it. TH I S SUBPOENA WAS NA/'E : ADDRESS: I SSUED AT THE REQUEST OF THE FOLLON I NG PERSON: GF.ORGE~ALLER JR, ESQ 1&-E- !IIOn OT CARLISLE, PA 17013 10 #_____~15-335-3212 TELEPH:lNE: SU'REI-E OOJRT ATTORNEY FOR: 49813 DEFENDANT M324756-01 OATE:__~~ r.J.. .2co,( ,__ Seal of the Court O'ivision Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA RINGLEY Vs. No. 04879 MINNICK CUSTODIAN OF RECORDS FOR: NEW HAMPSHIRE INDEM/AIG ENTIRE FIRST PARTY BENEFIT FILE AND ANY AND ALL INFORMATION PERTAINING TO ROBIN R RINGLEY, AIG POL #AIG 9926427, INCLUDING BUT NOT LIMITED TO THE INFORMATION ARISING FROM AN AUTOMOBILE ACCIDENT WHICH OCCURRED ON MARCH 2, 2002. PERTAINING TO: NAME: ROBIN R RINGLEY ADDRESS: 414 MYRTLE AVE MARYSVILLE PA DATE OF BIRTH: 01/07/68 SSAN: 209460752 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS X-RAYS PATIENT BILLING RECORDS 1 XRAYS have been destroyed Author1zed signature for NEW HAMPSHIRE INDEM/AIG Date CUMBERLAND M324756-02 *** SIGN AND RETURN THIS PAGE *** .'-, >, ~ ~: n c~ .-' ,.,::) ~;;) Gr1 t.,'2 l.-V (,) o ~i ~, ,"- ......,~ Q, --< -c.." h....;;;;;:. -(,'0:\ -c'L.... ;.,~(~ :-;? -.c_.... "iJ ',-< (~.:;j 0:; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBIN RINGLEY, n/kla ROBIN SNYDER CIVIL DIVISION Plaintiff, No: 04-879 Civil vs. LEE E. MINNICK, Defendant. COMPLAINT 1, Plaintiff, Robin Snyder (formerly known as Robin Ringley) is an individual residing at414 Myrtle Avenue, Marysville, PA 17053. 2. Defendant, Lee E. Minnick, is an individual residing at 8325 Thunder Road, Hogan Creek, Lincoln, MT 59639. 3. On or about March 3, 2002, at approximately 9:30a.m., Plaintiff Robin Snyder was stopped in her vehicle (a Red 1988 Chevy Corsica) at a red light in the southbound lane of Route 11 (North Enola Road) in Enola, PA near College Hill Road when she was struck in the rear by Defendant's vehicle. At the time of the accident, Plaintiff was wearing a seat belt. 4. At the time of the accident, Defendant Lee E. Minnick was traveling behind Plaintiff's vehicle in a 1994 Saturn and was putting down a cup of coffee when he realized too late that traffic had stopped. Defendant attempted to swerve out of the way toward the center lane of traffic but struck Plaintiffs vehicle on the rear driver's side, causing Plaintiff injuries and damages. 5, On the aforesaid date, Defendant was the operator of the 1994 Saturn automobile which was involved in the accident described herein and which was owned by B.E. Minnick. 6. At the time of the accident, Plaintiffs vehicle was lawfully stopped at the intersection because of a red light when it was struck in the rear by Defendant's vehicle. 7. The accident was directly and proximately caused by the negligence and carelessness of Defendant, which consisted, among other things, of the following: (a) operating his motor vehicle in a careless, reckless, and negligent manner; (b) operating his motor vehicle without due regard to the rights, safety, and position of the plaintiff; (c) failing to have his motor vehicle under the proper control so as to prevent his vehicle from striking the plaintiffs motor vehicle; (d) failing to keep a proper lookout; (e) failing to use due care under the circumstances; (f) failing to notice the motor vehicle of the plaintiff; (g) upon noticing the motor vehicle of the plaintiff, failing to yield the right-of-way to the plaintiffs vehicle; 2 (h) failing to take evasive action in order to avoid impacting with plaintiff's vehicle; (i) failing to apply his brakes in sufficient time to avoid striking plaintiff's vehicle; G) operating his motor vehicle in disregard of the rules of the road, the ordinances of East Pennsboro Township, and the laws of the Commonwealth of Pennsylvania, including but not limited to the Motor Vehicle Code, 75 Pa. Cons. Stat. Ann. 9 9 3361 and 3362. 8. At all times material hereto, Plaintiff acted with due care and was not contributorily negligent. 9, As a result of Defendant's negligence, Plaintiff, Robin Snyder, sustained the following injuries, some or all of which may be permanent: a, Strain and sprain to the muscles and soft tissues of the neck, spine, shoulders; b. strain and sprain to the muscles and soft tissues of the lower and mid-back; c. headaches, including migraine; 10. As a result of Defendant's negligence, Plaintiff has suffered great bodily pain and suffering, as well as mental anxiety and nervousness, to her great detriment and loss. The chronic nature of her pain has required Plaintiff to utilize medication on an ongoing basis to ameliorate her symptoms and has resulted in limitations to Plaintiff's activities and her sense of well-being and enjoyment of life. 3 11. As a result of Defendant's negligence, Plaintiff has sustained serious and permanent injury, for the treatment of which she has had to have physical therapy and chiropractic treatment and may require the same in the future. 12. As a result of Defendant's negligence, Plaintiff has suffered a loss of earnings and earning capacity. 13. As a result of Defendant's negligence, Plaintiff has suffered an interruption of her daily habits and pursuits to her great and permanent detriment and loss. WHEREFORE, Plaintiff, Robin Snyder, demands judgment against Defendant in an amount in excess of $35,000, exclusive of interest and costs. Edmund J. Berger Attorney I.D. #5340 Attorney for Plaintiff 2104 Market Street Camp Hill, PA 17011 Phone: 717-920-8900 Fax: 717-920-8901 E-Mail: tberaertmberaerlawfirm.net 4 VERIFICATION I, Robin Snyder, aflinn that I am the Plaintiff in this action and that the statements of fact made in the foregoing Complaint are true and correct to the best of my knowledge, Information and belief. The undersigned understands that the statements herein are made subject to the penalties of 1 B Pa. Cone. Stat. Ann. !i 4904 relating to unsworn falslllcation to authorities. Date: October 6, 2005 ~~duJ Robin Snyder CERTIFICATE OF SERVICE I hereby certify that I have this day filed the foregoing Complaint upon the following person and in the manner indicated. BY FIRST CLASS MAIL George B. Faller, Jr., Esq, Martson Deardorff Williams & Otto 10 East High Street Carlisle, PA 17013 Date: October 7,2005 0 r-> () ~::> c:: c_~) -n c.:.J" c.-'! ::;:l c) 6;"1~ -, I '-'1 ",.J _J ?:.~ m .<~:'~ l'> ~, C....n F\FILES\DA T AF1LEITr:lvders3()9G\Cunem\'822\3.nsl\nlm Created 9/20/04006PM RevLSed 10/27/05 lO.lOAM 3090.822 George B. Faller, Jr., Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. No. 49813 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Defendant ROBIN R. RINGLEY Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-879 CIVIL ACTION - LAW LEE E. MINNICK, Defendant JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT TO: ROBIN R. RINGLEY, Plaintiff, and her attorney, EDMUND J. BERGER, ESQUIRE YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOu. AND NOW comes Defendant, Lee E. Minnick, by and through his attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, and hereby responds to Plaintiffs Complaint as follows: L After reasonable investigation, answering Defendant without knowledge or information sufficient to form a belief as to the truth or falsity of the avernlents in this paragraph, 2, Admitted, 3, Defendant is not aware whether or not Plaintiff was wearing a seatbelt and, therefore, this averment is denied, The remaining averments of this paragraph are admitted, 4-8, Admitted. 9-13, Denied pursuant to Pa, R,C,P, 1029(e). WHEREFORE, Defendant demands judgment in his favor and dismissal of Plaintiffs Complaint with prejudice, NEW MATTER 14. Plaintiff's recovery is barred or reduced by the terms of the Pennsylvania Motor Vehicle Financial Responsibility Law. 15, Plaintiff's recovery is barred by the applicable statute of limitations, MARTS ON DEARDORFF WILLIAMS & OTTO ~1n~ " c~ tTi dz ' J By George B. Faller, Jr., Esquire J.D. Number 49813 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: October 27, 2005 Attorneys for Defendant VERIFICATION The foregoing Defendant's Answer with New Matter to Plaintiffs Complaint is based upon information wbich has been gathered by my counsel in the preparation ofthe lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification, This statement and verification are made subject to the penalties of 18 Pa, C.S. Section 4904 relating to unSWOn1 falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties, F IF! LES\DA T AFJ LEI T rave!el's3090\Curn;:l\t\f(221.al\S 1 ~ CERTIFICATE OF SERVICE I, Nichole L Myers, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Defendant's Answer with New Matter to Plaintiffs Complaint was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Edmund J. Berger, Esquire BERGER LAW FIRM, p.c 2104 Market Street Camp Hill, PA 17011 MARTSON DEARDORFF WILLIAMS & OTTO By . /0UifU vi 14;:b'-- Nichole L Myers Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: October 27,2005 --- -,., e,.: L - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY RINGLEY Vs. NO. 04879 MINNICK CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena{s) for documents and things pursuant to Rule 4009.22 GEORGE B FALLER JR, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena{s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena{s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena{s). ~~ GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT Date: 11/07/05 INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-4907 By: Patrice Laporte File #: M325836 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY RINGLEY Vs. MINNICK No. 04879 TO: EDMUND BERGER, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND TIIINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 10/17/05 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-4907 By: Patrice Laporte Enc(s): Copy of subpoena(s) Counsel return card File #: M325836 ~TH OF pmNSYLVANIA axJNl'Y OF aJMBmIAND RINGLEY Vs. File No. 04879 MINNICK SUBPOENA TO PROOlX:E lXXU1ENTS OR TH I NGS FOR 0 I SCX>VERY PURSUANT TO RULE 4009. 22 AIG INS CO, PO BOX 2006, CHADDS FORD FA 19317 TO: ATTN: DEBRA MILNES (NlI11e of Person or Ent ity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doa.ment... or things: SEE ATTACllliU AUUJ!.;NUUM at MEDICAL LEGAL REPRODUCTIONS<Ad~s'940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested h) this subpoena, together with the certificate of carpliance, to the party making thi, request at the address listed above. You have the right to seek in advance the reasonabJ~ cost of preparing the copies or producing the things sought. I f you fai I to produce the docunents or things required by this subpoena within twenty (20) days after its serv~ce, the party serving 'thi,-; mlbpoena may seek a court orde'- carpe 11 ing you to carp ly with it. THIS SUBPOENA WAS NAI'E: ADORESS: ISSUED AT THE REQUEST OF THE FOLlCfol/ING PERSON: GEORGE B FALLER JR, ESQ 10 E HIGH ST CARLl~L~, PA ~7013 TELEPI-KlNE : SUPREl'E COURT 10# ATTORNEY FOR: 215-335-3212 49813 DEFENDANT DATE: Clkt;.t, d..r:, J. (rt)s Sea I of the cOurt Prot Division BY THE CCURT: M325836-01 [)epUt Y (Eff. 7/97) ADDENDUM TO SUBPOENA RINGLEY Vs. No. 04879 MINNICK CUSTODIAN OF RECORDS FOR: AIG INS CO ENTIRE FIRST PARTY BENEFIT FILE AND ANY AND ALL INFORMATION PERTAINING TO ROBIN R RINGLEY, CLM #610AL025543, POL #AIG9926427, INCLUDING BUT NOT LIMITED TO THE INFORMATION ARISING FROM AN AUTOMOBILE ACCIDENT WHICH OCCURRED ON MARCH 2, 2002. PERTAINING TO: NAME: ROBIN R RINGLEY ADDRESS: 414 MYRTLE AVE MARYSVILLE PA DATE OF BIRTH: 01/07/68 SSAN: 209460752 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS X-RAYS PATIENT BILLING RECORDS / XRAYS have been destroyed Date Author~zed s~gnature for AIG INS CO CUMBERLAND M325836-01 *** SIGN AND RETURN THIS PAGE *** ~> ,:,.':;? CJ' ('-) ':"(1 :-;J ~? -~ ,r ,) G) ~,) (.;j ("\ J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBIN RINGLEY, n/kla ROBIN SNYDER CIVIL DIVISION Plaintiff, No: 04-879 Civil vs. LEE E. MINNICK, Defendant PLAINTIFF'S REPLY TO NEW MATTER AND NOW COMES PLAINTIFF, Robin Snyder, by and through her attorneys, Berger Law Firm, P.C., and submits the following Reply to New Matter in accordance with the Pennsylvania Rules of Civil Procedure. 14. This paragraph states a conclusion of law to which no response is required. To the extent that the indicated conclusion of law is related to any underlying facts not more specifically averred, such facts are specifically denied, 15, This paragraph states a conclusion of law to which no response is required. To the extent that the indicated conclusion of law is related to any underlying facts not more specifically averred, such facts are specifically denied. WHEREFORE, Plaintiff respectfully submits that Defendant's New Matter should be denied. Edmund J. Berger Attorney 1.0. #53407 Attorney for Plaintiff 2104 Market Street Camp Hill, PA 17011 Phone: 717-920-8900 Fax: 717-920-8901 E-Mail: tberaer@beraerlawfirm.net 2 ~ov, 15,2005 12:54PM HP LASE~JET ~330 Nov .La !;.'"'u..... ...... ._.IM ".::J NO, 0197 P 2 P ,4 VERIFICATION I, Robin Snyder;. affirm that I am the Plaintiff, in this action and that the slatement$ , , offact made Inthe foregolngR~ply to New Matter are true and correct to the best of my knowledge. information and belief. The undersigned underslands'thatthe statements herein are made subject to the penalties, of 18 Pa. Cons'. Stat. Ann. !i 4904 relating to unsworn falsification to authorities. Dala: November 15, 2005 ~J::b ~jrJ.>>J Robin Snyd r 1/, , , ,..'. , CERTIFICATE OF SERVICE I hereby certify that I have this day served Plaintiff's Reply to New Matter upon the following person and in the manner indicated. BY HAND DELIVERY George B, Faller, Jr., Esq, Martson Deardorff Williams & Otto 10 East High Street Carlisle, PA 17013 Date: November 16, 2005 --- I' <) c- '-i .-c: ." ,~ c:) "n ~ c> ...-r.;;: o -n ~-n nlp:.;:. ~.'l .....,.. Cl m :!:': CJ f'-' Cd " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY RINGLEY Vs. NO. 04879 MINNICK CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 GEORGE B FALLER JR, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 12/13/05 ~~ GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 717-243-3341 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-4907 File #: M326744 By: Patrice Laporte ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY RINGLEY Vs. MINNICK No. 04879 TO: EDMUND BERGER, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 11/17/05 GEORGE B FALLER JR, ESQUIRE 10 E HIGH ST CARLISLE, PA 17013 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-4907 By: Patrice Laporte Enc(s): Copy of subpoena(s) Counsel return card File #: M326744 .. mMMJNWEALTH OF PENNSYLVANIA OJUNTY OF aJMBrnIAND RINGLEY Vs. File No. 04879 MINNICK SUBPOENA TO PROCXX:E oo::::u-1ENTS OR TH I NGS FOR D I SCX>VERY PURSUANT TO RULE 4009. 22 REMILLARD CHIRO, 2459 WALNUT ST, HARRISBURG PA 17103 TO: (N!Ille of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunent'l orSmtlT'lACtlEU AIJDENDUM at MEDICAL LEGAL REPRODUCTIONS{A!~s1940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the docunents or produce things requested h, this subpoena, together with the certificate of carpliance, to the party making thic request at the address listed above. You have the right to seek in advance the rea,onablE cost of preoaring the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within t~enty (20) days after its serv~ce, the party serving thin subpoena may seek a court orde;' compelling you to carply with it. TH I S SUBPOENA WAS NAl'E : ADDRESS : ISSUED AT THE REQUEST OF THE FOLLClNING PERSON: GEORGE B FALLER JR, ESQ 10 E IHGH lOT CAKL~bL~, ~A ~7013 TELf'PHONE: SUPREI'E COURT I D # ATTORNEY FOR: 215-335-3212 49813 DEFENDANT DATE: 'J1t1-f), r:J1 ;200~ Seal of the Court BY THE OOJR!1,,~ ~. protl)6not~k:lvi 1 Division M326744-01 Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA RINGLEY Vs. No. 04879 MINNICK CUSTODIAN OF RECORDS FOR: REMILLARD CHIRO ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ROBIN R RINGLEY ADDRESS: 414 MYRTLE AVE MARYSVILLE PA DATE OF BIRTH: 01/07/68 SSAN: 209460752 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS X-RAYS PATIENT BILLING RECORDS / XRAYS have been destroyed Date Author~zed s~gnature for REMILLARD CHIRO CUMBERLAND M326744-01 *** SIGN AND RETURN THIS PAGE *** COMM)NWE!\LTH OF PENNSYLVANIA axJNl'Y OF CUMBERIAND RINGLEY VS. File No. 04A7Q MINNICK SUBPOENA TO PROCllX::E DOCU1ENTS OR TH I NGS FOR D I SCX>VERY PURSUANT TO RULE 4009. 22 HOLY SPIRIT HOSP, 503 N 21ST ST, CAMP HILL PA 17011 TO: ATTN: MRDICAL RECORDS DEPT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following document~ or things: SEE ATTACHED ADDENDlJM at MEDICAL LEGAL REPRODUCTIONS{A~s1940 DISSTON ST., PBILA., PA You may deliver or mail legible copies of the documents or produce things requested h, this subpoena, together with the certificate of carpliance, to the party making thj~ request at the address listed above. You have the right to seek in advance the reasonablE cost of preoaring the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within t~enty (20) days after its serv~ce, the party serving thi,-; ~;ubpoena may seek a court orde;' o::rrpelling you to carply with it. TH I S SUBPOENA WAS NAI'E : ADDRESS: ISSUED AT THE REQUEST OF THE FOLLOHING PERSON: GEORGE B F~R JR, ESQ 10 E 11I0l1 0'1' CARLISLE, PA 17013 215-335-3212 TELf'PHONE: SUPREl-E OOJRT 10# ATTORNEY FOR: 4QA11 DEFENDANT " - "'-"T' ~ ,~~,. of" Division M326744-02 DATE: '-7hv, ;2.1: ,;lCJ'::?) Seal of the Court Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA RINGLEY Vs. No. 04879 MINNICK CUSTODIAN OF RECORDS FOR : HOLY SPIRIT HOSP Any and all hospital records, including microfilm, microfiche emergency room reports, x-ray reports, out-patient records physical therapy records, and any other information pertaining to: NAME: ROBIN R RINGLEY ADDRESS: 414 MYRTLE AVE MARYSVILLE PA DATE OF BIRTH: 01/07/68 SSAN: 209460752 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. NO DOCUMENTS A VA/LABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS X-RAYS PATIENT BILLING RECORDS / XRAYS have been destroyed Date Author1zed s1gnature for HOLY SPIRIT HOSP CUMBERLAND M326744-02 * ** SIGN AND RETURN THIS PAGE ** * . - COMMJNWEI\LTH OF PENNSYLVANIA <XlUNrY OF aJMBERLAND RINGLEY VS. File No. 04879 MINNICK SUBPOENA TO PR<X:lLCE DC:CLM:NTS OR TH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 SHERMANS DALE FAMILY PRAC, 4570 VALLEY RD, SHERMANS DALE PA 17090 TO: (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunent!'; orS'EEg~TTf\CHED ADDENDl.LM at MEDICAL LEGAL R.l!ik'KUlJU<":!J,ONS, INC, 4940 llIS8T6N ST., FIIILA. ,-PA--,--- (Address) You may deliver or mail legible copies of the documents or produce things requeste~ h, this subpoena, together with the certificate of carpliance, to the party making thi, request at the address listed above. You have the right to seek in advance the reasonable cost of preoaring 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 thb ~;ubpoena may seek a court orde;- o::rrpelling you to carply with it. TH I S SUBPOENA WAS NAl'E: ADDRESS : I SSUED AT THE REQUEST OF THE FOLL()\II NG PERSON: GEORGE B FALLER JR, ESQ 10 E HIGH ST CA9LISL''',PlI 17013 TELF.PH:lNE: SUPREI"E OOJRT I D ** ATTORNEY FOR: :O.L~-.:S35-3212 49813 DEFENDANT DATE: '74.11/, 01!. -=<'4?S- Sea 1 of the Court , Civ Division M326744-03 Deputy (Eff. 7/97) .. ADDENDUM TO SUBPOENA RINGLEY Vs. No. 04879 MINNICK CUSTODIAN OF RECORDS FOR: SHERMANS DALE FAMILY PRAC ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: ROBIN R RINGLEY ADDRESS: 414 MYRTLE AVE MARYSVILLE PA DATE OF BIRTH: 01/07/68 SSAN: 209460752 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS X-RAYS PATIENT BILLING RECORDS / XRAYS have been destroyed Date Authorized s1gnature for SHERMANS DALE FAMILY PRAC CUMBERLAND M326744-03 *** SIGN AND RETURN THIS PAGE *** () "':; \'<:,., !:- i..,,-, h~ ;(1 ...~ r-> = = ,~j" ~ =r.'." r<1Fii T'C;; ?:,~ r.' _,:;J-"'f, \~:~, ~~ ~;--~ ~';:>, ~n '< Cl r' (J ~ -0 ::;r; N .- <.n o ROBIN R. RINGLEY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO.04-879 CNIL LEE E. MINNICK RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the fOllowing form: PETITION FOR APPOINTMENT OF ARBITRATORS TO mE HONORABLE. mE JUDGES OF SAID COURT: George B. Faller, Jr., Esquire ,counsel for the ~defendant in the above action (or actions), respectfully represents that: 1. The abov....captioned action (or actions) is (are) at issue. 2, The claim oHbe plaintiff in the action is $ less than $35,000, The counterclaim of the defenda.nt in the action is NIl, The following attorneys are interested in the ca5e(5) as counselor ace otherwise di~'l"alified to sit as llrbitraton;: B F ller Jr Esquire and Edmund J. Berger, Esqul e George . a , ., WHEREFORE. your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the c:ase shall be submitted. R~~~!~ I ~~~l~tlyrquire ORDER OF COURT AND NOW. , 19_, in consideratiotl of the Esq., . Esq., an: appointed arhitrators in the above captioned aclion (or foregoing petition. Esq.. and actions) as prayed for. By the Court, Pl, ,..., q. "'" = -'- a' ::;l ~>, '- J'P ~""Ti ~ ~ f11r: ~J -o'tn ~ v:> :py - '.,)0 , --- " :?--r. 'r, -1J :~~~ - ~ -'> ..., -t\ '$ 'y.' ~ 0'" '" "" "-' -.. ~ OJ, ':-^- c- "'" c-' W <::; 2, ROBIN R. RINGLEY v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.04-879 CNlL LEE E. MINNICK RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following fonn: PETITION FOR APPOINTMENT OF ARBITRATORS TO mE HONORABLE. mE JUDGES OF SAID COURT: George B. Faller, Jr., Esquire ,counsel for the I~defendant in the above action (or actions), respectfully "'presents that: I. The above-captioned action (or actions) is (are) at issue. 2, The claim ofthe plaintiff in the action is $less than $35,000. The counterclaim of the defendant in the action i. N l A The following attorneys are interested in the case(s) as counselor are otherwise di~~ualified to sit as arbitrators; George B. Faller, Jr., Esquire and Edmund J. Berger, Esqul e WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. R~cW~tcei(~ I ~!(;J~tkY~qUire ORDER OF COURT , ;106b AND NOW, ' '~ ~' Ul_,inconsideration of the foregoing~titioy, & ), , Esq,: \'1~/1r2~ (~'-1Jrt?1r^ actions) as prayed for, r 0(100, "",\,< I"~ " ~ L 0 C-,. Il.r ~"i ,~ if \(6.V\ '0___ o<.H} LJ 'C' U --- ~ -( ~;1r H f/1fV1" 0) v . ,r r--' 0 = c;:;J -n a' -I ~ '- ::c-., ~ 7> II'?" ~j Z -oi......... ~ v:> .":",G ;-;:\ ~~~, " Ie, -0 .--0 - .J:> :::,:: .~-~:~ <'.'~ -'\ Orn "" ,. ~ '" ., -'-\ " 35 " ~ r -.j 0) ::< r a 2/ i~0{/ ~ ') ~ 0;"->">;;~)' .' ,\ 1...) (' \c....... (",\"\',!.,) ~_.--_,_._."..__~M~"'""-~'---" -.----- ~(~ R. ~r~?le, PI . tiff Lee E. ;1.>1"";ek Defendant Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitu . of this Commonwealth and that we will discharge the duties of our office withfi 7O.r'r P. ;f-""~ Name (Chairman) ,iJJ,.~~ ., 'Jih"'~-r Law Firm 7'ii W. BU(~ sf Address ~r/(s/~ f,/ Ild~ City, ' Zip ... /I'){II In The Court of Common Pleas of Cumberland County, Pennsylvania No.6l( ?J77 Civil Action - Law. ~~ ;t(ark I!-.)h-krq , ~ Name .J; ~~ S' we (7-' ~r'A B. rieJ./ Name r Hat " &t1r:y, It Law Firm <f~~ dr//~ p.~ ~dreSS r+.Z ~(/';I 17lJ{ I City, ' Zip " II?'!,,). Law Firm Po BttK tZl J\ddress ( Sa-r /''''1 SPr...?T f,4. City, Zip 'r 7d1 ) Award We, the undersigned arbitrators, having been duly appointed and sworn (or affinned), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) ~1~~: f fo~~ ~1t,~ '';(:~::~.f-"~-F?~-::.1;1~~ Date of Hearing: Date of Award: ert name if applicable.) (Chairman) ~,". ,,:;1I;l~,' '. ~~&11 'Wi~"Ir.'j'j':~,.~- {<ij.;~~f~~~,t/..r,-j>,~&:< ."'I~'\!O;~;I~J"1!i ~",,~,~,:;""~..' Notice of Entry of Award Now, the 'llf day of ~ ' 20 D~ ,at /; <Jb , P.M., the above award was entered upon the docket and notice the of given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ .2 9b. () 0 othonotary By: Deputy ,.v... ~ 51 o,d () t. ic . :---,)ir--r~ ~ Il j~.g. S. C)r- g "'" = ~ = S <:r' ~t..T) ::3l: ~ -., rj, ,... ~'T' -< zt" ~i (fl)':'< I ~t, .0 ~, -v g~ -0 :::It ~c: - z .. ?5 =<! .. 0 < ROBIN RINGLEY, Plaintiff, --r '"'= ...,..,..." _ _.-..1 "'\';l....:t .....r=:"'~T , ,,..... Jl..,..'~u...r"~_,_ CE' '~C~!MC:~ ?T ~~.S ,....~.~r 'C":'lI~.s~rr "'r.l 'I"" .1 .....--_I_-J ..__._; __......1_. v. LEE E. MINNICK, Defendant. :;0. 04-879 :';OTI::E OF' APPEAL ?ROM AV~~ OF =C~~ CF _~~ _. .~CRS ':'Ol'_~ ?RC~CNCTP_"\Y: :-:ot"!.~e is giTrsn tl'1at Defendant Lee E. Minni k ~ppea1s f':=-Or.l tr~ aw~d O~ tr~ board of' arb1t~ators er.tered ~. this case on May 9, 2006 A jUI7 trial is c.emar-ded g. (~eak,k 'ce if a j,,::y trial is demar-ced. Ct::el":nse ju......,. -crial is ~.;a1 'led. ) ! :...ereOj ,~ertif7 that '" ) tee compensatior:. of "''''''' ,~oit!'a.tors .~ s :eer:. ;a1c, or \... <,,;...... , (2) -" ~ ~ - - :- :- ~ ~~ ...~:<ru :_u;:l!.r1s, ( Str:f.l.:e 01..:t tl:e l."Jap li::abh clause. ) / :TCTS : The, c:ema.nd for j ;:'rom compulsory by Rule 10C7.1 ( trial on ac-oeel ~b1trat1on is-~~rned , - I' (b) )~ a~fic:a7it or 'rer1:icaticn is ~CU' ed. (") "" ~ c~ = 0 r = r t~.: c:r< .." ::l': :r ::>- -< rl1 :!J .. -0 hi "- w ~ "- ~ :,,0 ....:. v-, -.(\ <)(l.} "'" ~ ~ "" :LJ..~, V', V''- i:7 ::1: {'~):o \.>> ,~O <;> ;::sm ,-1 c::> :':0 ~ -< ~ e ~ r "- PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO TIIE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: Ilf1 for JURY trial at the next tenn of civil court. o for trial without jl jury. -----..-.....-..--............--..-..........-.....-------..----..-..-..--..-----..-.....---....--..---..-----..-..........-----........-...-..-----..... CAPTION OF CASE (entire caption must be stated in full) ROBIN RINGLEY, n/k/a ROBIN SNYDER (check one) o Civil Action - Law e9 Appeal from arbitration o (other) (plaintiff) VB. LEE E. MINNICK, The trial llstwill be called on August 22, 2006 and Trials commence on September 18, 2006 (Defendant) PretrllllswllJbeheldon Auqust 30. 2006 (Brieft are due 5 days before pretrials vs. No. 04-879 .Civil Term Indicate the attorney who will try case for the party who files this praecipe: Edmund J. Berger Indicate trial cOWlsel for other parties if known: Geor e Faller Es. Date: (P('LI!b ~ Signed: Print Name: f-::d.m(.( ft Attorney for: -P fa In tcff, er This case is ready for trial. I CERTIFICATE OF SERVICE I hereby certify that I have this day served Praecipe for listing Case for Trial upon the following person and in the manner indicated. BY FIRST CLASS MAIL George B. Faller, Jr., Esq. Martson Deardorff Williams & Otto 10 East High Street Carlisle, PA 17013 Date: June 21, 2006 ,....... \ (j '" D C..:J ~'; ,.;;:,;;. " Q'" L;: :::1 fil f'.l "0 ~ c:::) (..-0 C-; ROBIN RINGLEY, n/k/a ROBIN SNYDER, plaintiff #10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-879 CIVIL TERM LEE E. MINNICK, Defendant CIVIL ACTION - LAW IN RE: PRETRIAL CONFERENCE A pretrial conference was held Wednesday, August 30, 2006, before the Honorable Edward E. Guido, Judge. Present for the Plaintiff was Edmund J. Berger, Esquire. Present for the Defendant was George B. Faller, Jr., Esquire. This is an uncomplicated vehicle accident in which the Defendant admits liability. The issue would be as to amount and causation of damages. There are no SCheduling conflicts. The case should take one and one half days to try. There is a possibility that the case will come off because of some additional medical treatment the Plaintiff is undergoing. The parties will keep the Court Administrator apprised of those developments. B~i),~~ourt) ~.'...~' ,l'~/r' Edward E. Guido, J. o ~ <, -r.7fZ 'J)r ~.. _::",. ej; ......, '= = "'^ ",. c-- c-:s w o -n -< ::J:'~ nl:::2 , :-om -~!]CJ :'~j(.J.) ~,~1j cSm ~ --< Edmund J. Berger, Esquire For the plaintiff r-':::( )'?; ~ ~ Court Admini~rat~ ~honotary-(,; co ::'4 .. -< (.....) C, George B. Faller, Jr., Esquire For the Defendant srs ROBIN RINGLEY n/kla ROBIN SNYDER, PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LEE E. MINNICK, DEFENDANT 04-0879 CIVIL TERM ORDER OF COURT AND NOW, this rrL day of September, 2006, by agreement of counsel, this case is continued from the September trial term. It may be relisted for trial by any party and then re-pretried. -~ /' B~CO ~. Edgar B. Bayley, " Edmund J. Berger, Esquire F or Plaintiff Court Administrator ~ ~~d1'0" '~ ~.:tu., George B. Faller, Jr., Esquire For Defendant :sal ~ \5 UJ-:,,,, Qc:, 1:tr~:: C)l': bel: wLL dLu u-l!" u- o :,j { \ to N i:i> "'0:- ;:;: l- I --- r-- '7 ':J<'t OJ ,"'--s~ "-1.'0 .-', ".!~, M Q (/) ..a <= <= iN :"/lJ ~JO_ -";' "') D o 10 Robin Ringley, n/kJa Robin Snyder IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Lee E. Minnick NO. 04-0879 CIVIL TERM ORDER OF COURT AND NOW, August 30,2006, by agreement of counsel, the above captioned case is continued from the September 18, 2006 trial term. Counsel are requested to relist the case for trial at such time as they deem appropriate. By the Court, Edgar B. Bayley, 1. vE8mund 1. Berger, Esquire F or the Plaintiff ~ vttartson, Deardorff, Williams & Otto For the Defendant Court Administrator kIn \11N\f^lASNN3d . AlNn08 cn.)'nY38Wno 20 :2 Wd 61 d3S gaOl AtN10NOHlOtld 3Hl dO 3~1:!:iO-t81f:l PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: ~ for JURY trial at the next term of civil court. o for trial without a jury, ..---------------------------------------------------------------------------------------------------------------...-.. - CAPTION OF CASE (entire caption must be stated in full) (check one) o Civil Action - Law jgI Appeal from arbitration o ROBIN RINGLEY, n/k/a ROBIN SNYDER (other) (plaintiff) Ys. The trial list will be called on January 9, 2007 and LEE E. MINNICK February 5, 2007 Trials commence on (Defendant) Pretrials will be held on January 17, 2007 (Briefs are due 5 days before pretrials 04-879 Civil No, Tenn Ys. Indicate the attorney who will try case for the party who files this praecipe: Edmund J. Berger Indicate trial counsel for other parties if known: George Faller, Esq. Si~M: ~~ Print Name: Edmund J. Berger This case is ready for trial. Date: November 1 , 2006 Attorney for: Plaintiff . 1 :~ ..,. .~ " ., ;... 'J'l" ." oil, .\ . ,t, ~ " 'JI. ., .", . ~ ! ..... ~ ., , , .... .1 . \ " ... . . . ~ ' '" .." . ./ '''I. , . " f'..j C-.l = C)" ~ (") -n :::! -'- "'T1 nlF~ ~~~ ~-;.: o Cl;;:_ I N v ::~ ;~r~ --i -j:.... ~.~ C,,) (:) ROBIN RINGLEY, a/k/a ROBIN SNYDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW LEE E. MINNICK, Defendant 04-879 CIVIL TERM IN RE: CASE STRICKEN FROM LIST ORDER OF COURT AND NOW, this 9th day of January, 2007, upon consideration of the call of the civil trial list, and the above-captioned case not having been called for trial, it is stricken from the trial list. By the Court, ~mund J. Berger, Esquire 204 Tall Oak Dr. New Cumberland, PA 17070-2347 For Plaintiff ~rtson, Deardorff, 10 East High Street Carlisle, PA 17013 For Defendant Williams & Ott~ Court Administrator :mae >- ss; I-~ r--- U..l:O,-:: ~€f-.; ~~~~ ~i' ~ 0..... ;:]ll1 w_j:E lL o ....... <:::::1 = ~ en o .. 9 < -''''i'':''' ....~.. c-:..::,o;: ~ " ''') o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBIN RINGLEY, nlkla ROBIN SNYDER CIVIL DIVISION Plaintiff, No: 04-879 Civil vs. LEE E. MINNICK, Defendant. PRAECIPE TO DISCONTINUE ACTION TO THE PROTHONOTARY: Please mark this action as settled, discontinued and dismissed, with prejudice. Attorney for Plaint' 2104 Market Stree Camp Hill, PA 17011 Phone: 717-920-8900 Fax: 717-920-8901 E-Mail: tberaer@beraerlawfirm.net Date: March 15, 2007 Edmund J. Berge Attorney I.D. #5 ~ ~ ~ ~ ::I: ~:n 'i%$ ~ i-~ it :i - ::0 ~.,:,. a" 0 ....C! ~~ is ""0 ::J: C - ~ ~ .. ~ N (J\