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HomeMy WebLinkAbout08-4920IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION LESLIE LEWIS 73 Mountain Road Carlisle, PA 17015 PLAINTIFF V. JANE E. CLEPPER 13 Abbey Court Carlisle, PA 17015 DEFENDANT FILE NO.: CIVIL ACTION: PRAECIPE FOR SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue summons in the above captioned action, which arises from a motor vehicle accident on August 15, 2006. LIZ Writ of Summons shall be issued and Dater SUMMONS IN CIVIL ACTION TO: Jane E. Clepper 13 Abbey Court Carlisle, PA 17015 YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED AN ACTION AGAINST YOU. Prothon tart'/Clerk,' sio Date: ?S by: Deputy Dusan Bratice, Esq., I.D. # 19249 101 South US Route 15 Dillsburg, PA 17019 (717) 432-9706 Attorney for Plaintiff rv m ?-n a SHERIFF'S RETURN - REGULAR CASE NO: 2008-04920 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LEWIS LESLIE VS CLEPPER JANE E MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS CLEPPER JANE E was served upon the DEFENDANT , at 0019:00 HOURS, on the 27th day of August 2008 at 13 ABBEY COURT CARLISLE, PA 17015 by handing to JANE CLEPPER DEFENDANT 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 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 Postage .58 9Ib8]o8 33.58 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 08/28/2008 DUSAN BRATIC By. Deput Sheriff of A. D. WILLIAM J. FERREN & ASSOCIATES Francis R. Gartner, Esquire Atty ID # 49436 Attorney for Defendant 10 Sentry Parkway, Suite 301 Jane E. Clepper Blue Bell, PA 19422 (215) 274-1710 LESLIE LEWIS COURT OF COMMON PLE Plaintiff CUMBERLAND COUNTY, l? d V. a NO. 08-4920 Civil Term JANE E. CLEPPER _ Defendant CIO OF APPEARANCE & DEMAND FOR JURY TRIAL L0 TO THE PROTHONOTARY: Kindly enter my appearance as attorney for Defendant, Jane E. Clepper, in the above captioned matter. Defendant, Jane E. Clepper, by and through her undersigned counsel, hereby demands a trial by a jury of twelve. J. FERREN & ASSOCIATES 1? n1`_,-n Vic- rr7rar.?s'K. G ner, Esquire Attorney for Vef endant WILLIAM J. FERREN & ASSOCIATES Francis R. Gartner, Esquire Atty ID # 49436 10 Sentry Parkway, Suite 301 Blue Bell, PA 19422 (215) 274-1710 LESLIE LEWIS V. Plaintiff JANE E. CLEPPER Defendant Attorney for Defendant Jane E. Clepper COURT OF COMMON PL&@ CUMBERLAND COUNTY, a: NO. 08-4920 Civil Term 1 PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: N n n s.? Ul c CJl 9.D Please enter a Rule on plaintiff in the above-entitled matter to file a Complaint within twenty (20) days or suffer judgment of non pros. DATED: ')101!0 WILLIAM J. FERREN & ASSOCIATES By: F NC R. QARTNER, ESQUIRE Attorney for D endant RULE TO FILE COMPLAINT TO THE WITHIN PLAINTIFF: You are hereby ruled to file a Complaint within twenty (20) days after service hereof. a? (? d PROTHONOTARY T, ---I rir =::q c,_ ?i -C DATE __ ,?_? 10-2850T CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 G _ c' G. P-`Y! Q r?l I 1 ? M W C ) i In the Matter of: Court of Common PIeai---Cw -? LESLIE LEWIS Cumberland County 5;:? 0. N -VS c- JANE E. CLEPPER No. 08-4920 tD As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 CCLR on behalf of FRANCIS R. GARTNER, ESQUIRE Defendant certifies that (1) A notice of intent to serve the subpoena(s) with a copy of the subpoena(s) attached thereto was/were mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is/are sought to be served. (2) A copy of the notice of intent, including the proposed subpoena(s), is attached to the certificate. (3) No objection to the subpoena(s) has been received. (4) The subpoena(s) which will be served is/are identical to the subpoena(s) which is/are attached to the notice of intent to server the subpoena(s). DATE: 4/21/2010 I S E Counsel for Defendant ¦'il`• Center City Legal Reproductions, Inc. CCLR 123 South Broad Street, Suite 1920, Philadelphia, PA 19109 ¦ ¦ ¦ ¦ (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com LESLIE LEWIS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. JANE E. CLEPPER No. 08-4920 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS SUSAN BRATICK, ESQUIRE LAW OFFICE OF SUSAN BRATICK 101 OFFICE CENTER, SUITE A 101 S. US ROUTE15 DILLSBURG, PA 17019 Please take notice there has been a request by FRANCIS R. GARTNER, ESQUIRE, counsel for the Defendant in the above case for production and copying of records in the possession of (see enclosures). These records pertain to LESLIE LEWIS. Enclosed is(are) a copy (copies) of the subpoena(s) to be served on the custodian of such records and also a Counsel Return Page for you to fill out and return to us stating whether you would like to order a copy of the records and whether you have any objections to the production and copying of such records or manner thereof. The fee per location is enclosed on the Counsel Return Page. The subpoena will be sent to the records custodian twenty (20) days from the date of this notice requesting that the records be produced on or before ten (10) days thereafter unless we hear from you to the contrary on the Counsel Return Page. If you state an objection on the Counsel Return Page, we will proceed accordingly. If you require assistance, please contact our office. DATE: March 31, 2010 Enclosures : Copy (copies) of Subpoena(s) Counsel Return Page adhilk Center City Legal Reproductions, Inc. CCLR 123 South Broad Street, Suite 1920, Philadelphia, PA 19109 (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com LESLIE LEWIS CCLR File NO. 10-2850T vs. JANE E. CLEPPER COUNSEL RETURN PAGE I have received the Notice of Records Reproduction Request dated 3/31/2010 regarding records in the custody of (see attached subpoena(s)) and respond as follow: (1) COPIES yes / no I would like a copy of the records in question sent to me, and agree to pay the price noted in the Notice of Records Reproduction Request. (2) 1 would like copies of X-Rays sent to me. yes / no (3) OBJECTION In accordance to rules governing civil procedure a copy of date/time stamped filing needs to be sent to Center City Legal Reproductions on or prior to 4/21/2010. Failure to do so shall serve as an agreement that the records reproduction service should proceed with the records collection process. (4) 1 would like to look at the records at a Center City location before yes / no deciding whether to order a copy. 2010 Copy Fees/Per Location Administrative Fee $17.00 Pages 1-20 $.95 Pages 21-60 $.65 Pages 61-100 $.20 Date: Attorney for plaintiff(s) / defendant(s) SUSAN BRATICK, ESQUIRE LAW OFFICE OF SUSAN BRATICK 101 OFFICE CENTER, SUITE A 101 S. US ROUTE15 DILLSBURG, PA 17019 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LESLIE LEWIS VS JANE E. CLEPPER File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ALLSTATE INSURANCE COMPANY - CLAIMS DEPARTMENT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the follow' d?,?,? ANY :AND ALL RECORDS r REPORTS r MEMOS r DOCUMENTS, ANY WRITTEN INMOVATII7N°? or things: CONTAINED IN FILE REGARDING CLAIM#15532204172• iss lot at CENTER CITY LEGAL REPRODUCTI N (Address) 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'coatply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: FRANCIS R. GARTNER, ESQUIRE 4DDRESS: CL R. Inc. St. Ste 1920 rELEPHONE: __ per,, pA 19109 ?UPREME COURT ID# 2-1177 WrORNEY FOR: DEFENDA T BY THE COURT. ATE. Peary Clerk, Civil Disposition Seat of the Court Deputy (Eft 71" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LESLIE LEWIS VS JANE E. CLEPPER File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ALLSTATE INSURANCE COMPANY - CLAIMS DEPARTMENT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the followin documents or things: ANY AND ALL RECORDS, REPORTS, MEMOS, DOCUMENTS, ANY WRITTEN INFCMATICIN CONTAINED IN FILE REGARDING,CLAIM# 155434523901: DATE OF LOSS 3/22/2002. at CENTER CITY LEGAL REPRODUCTIONS, . (Address) 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 preparirig 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. PHIS. SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: FRANCIS R. GARTNER, ESQUIRE 4DDRESS: CCLR. Inc. ? Ion S.-Broad St., Ste 1920 [EI.EPHONE: PW ., PA 19109 :UPREME COURT ID# _ (2151732-1177 CTPORNEY FOR: DEFENDANT BY THE COURT: Prothonotary / Clerk, C.rvil Disposition ATE Seal of the cou" LESLIE LEWIS - VS - JANE E. CLEPPER - COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ALLSTATE INSURANCE COMPANY---- CLAIMS DEPARTMENT (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 RECORDS, REPORTS,' MEMOS, DOCUMENTS,. ANY WRITTEN INFORMATION CONTAINED IN FILE REGARDING CLAIM# 1553220417: DATE OF LOSS 10/4/1998. CENTER CITY LEGAL REPRODUCTIONS, . (Address) 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 preparitig the copies or producing the things sought. If you fail to produce the documents or things requited 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: 1IAME• FRANCIS R. GARTNER, ESQUIRE kDDRESS:_ .CC R.Ing. .103S-,_Ri'ad St., Ste 1920 - fELEPHONE: Phil, PA 19109 iUPREME COURT ID# l21 51732-1177 CITORNEY FOR: DEFENDANT BY THE COURT: ATE- Seat of the Court Prothonotary ! Ckd4 civil Disposition r (EfE 71". COMMONWEALTH OF PENNSYLVANIA = COUNTY OF CUMBERLAND LESLIE LEWIS VS JANE E. CLEPPER File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: AQUA TREATMENT SERVICE INC- PERSONNEL DEPARTMENT (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 EMPLOYMENT/PERSONNEL RECORDS INCLUDING WORKERS' COMP CLAIMS, DATES Of ATTENDANCE APPLICATIONS PERFORMANCE RECORDS REVIEWS, EVALUATI-ONS, EARNING S at CENTER CITY LEGAL REPRODUC MEDICAL REPORTS, ETC. PERTAINING TO (Address) LESLIE LEWIS. 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 prepadig the copies or producing the things sought- U 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 cant order compelling you to -comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: FRANCIS R. GARTNER, ESQUIRE kDDRESS: CCLB. Ines _'I *$ , Broad St., Ste 1,920 TELEPHONE: Phj?a} PA 1'9109 ?UPREME COURT IDS` ?2I 51-732-1177 CTPORNEY FOR. DEFENDA T BY THE COURT. Prothonotary / Clerk, Civil Disposition ?rTr): (EIL LESLIE LEWIS - VS JANE E. CLEPPER - COMMONWEALTH OF PENNSYLVAMA COUNTY OF CUMBERLAND File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: AVRAAM C. KARAS, M.D.- MEDICAL RECORDS DEPT (Name of Person or Entity) Within twenty (?A) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES CHARTS SUMMARIES TEST RESULTS, LAB TESTS,-EVALUATIONS,, at CENTER CITY LEGAL REPRODUCTIONS, ETC., PERTAINING TO LESLIE LEWIS. (Address) 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 preparitig 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:_ FRANCIS R. GARTNER, ESQUIRE kD RESS: CCLR. Inc. 103. S_ 13roadp/St., Ste 192Q TELEPHONE: Phila.. _PA 1910 :up"mE couRT m# 1517, 2-1177 W11ORNEY FOR: DEFENDANT ATE: Seal of the 'Coutt BY THE COURT Pw(hoeotary / Ckdr, Civil Disposition y (EIL 71" LESLIE LEWIS VS - JANE E. CLEPPER - COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CENTRAL PENN MEDICAL GROUP- MEDICAL 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 documents or things: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, at CENTER CITY LEGAL REPRODUCTIONS, ETC., PERTAINING TO LESLIE LEWI S. (Address) 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:. FRANCIS R. GARTNER, ESQUIRE kD RESS:_ CCLB.Inc. 193. Broad St., Ste 1920 fELEPHONE- Phila.} PA 19109 :UPREME COURT IIIN 2151 732-1177 ,TPORNEY FOR. DEFENDART ATE: Seal of the coats BY THE COURT. Prothonotary / Clerk, Civil Disposition. D*q (F.tl~ 7197): COMMONWEALTH OF PENNSYLVANIA = COUNTY OF CUMBERLAND LESLIE LEWIS VS JANE E. CLEPPER File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUMBERLAND ORTHOPEDIC & SPINE - M DT AT RFCoRnc 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 documents or things: ANY AND ALL MEDICAL RECORDS, REPORTS --OFFICE NnTFC_ PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, at CENTER CITY LEGAL REPRODUCTIONS, ETC., PERTAINING TO LESLIE LEWIS (Address) 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: . FRANCIS R. GARTNER, ESQUIRE 4DDRESS:_ CLLR. Inc. 2Q 132 S,. :Broad St., Ste is TELEPHONE PA 191,09 :UPREME COURT ID# 121?L732-1177 ?TTORNEY FOR. DEFENDART BY THE OOURT: ATE.- Prothonotary / Clerk, Civil DiVositioa seal of the Court y LESLIE LEWIS VS JANE E. CLEPPER - COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO' CURTIS GOLTZ, D.O.- MEDICAL 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 documents or things: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, CENTER CITY LEGAL REPRODUCTIONS, ETC., PERTAINING TO LESLIE LEWIS (Address) 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 preparisig the copies or pvoducing the things sought. V 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:. FRANCIS R. GARTNER, ESQUIRE k13DXESS. r-C R. Inc. ? 133S-._Broad St., Ste 1920 TELEPHONE: Pr11la.? PA 19109 MPREME COURT [D# 2151-732-1177 WWRNEY FOR: DEFENDA T BY THE COURT: Prothonotary / Cierk, Civil Disposition ATE: sat of the cow LESLIE LEWIS - VS - JANE E. CLEPPER - COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Be No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: DONALD KOVACS, M.D.- MEDICAL 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 documents or, things: ANY AND ALL MEDICAL RECORDS,-REPORTS,-OFFICE NOTES. PROGRESS RRPnRTc DOCTO T_gAT RESULTS, LAB TESTS EVALUATIONS ETC CENTER CITY LEGAL REPRODUCTIUNS, INC. PERTAINING TO LESLIE LEWIG at (Address) 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 parity 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 it court order compelling you to comply, with it. THIS. SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME:. FRANCIS R. GARTNER, ESQUIRE kDDRFSS: CCLR, Inc. *-,A S. Rroad St., Ste 1920 TELEPHONE: Phiiaa,rPA 19109 :UPREME COURT ID# J21FL732-11.77 ?TPORNEY FOR: DEFENDA T BY THE COURT: Prothonotary / Clerk, Civil DiVositim ATE., COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LESLIE LEWIS - VS JANE E. CLEPPER - File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ERIC D. KLINEDINST, D.C.- tAEDICAL 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 documents or, things: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROCRFSS RrPoR!rq., DOCTORS NOTES CHARTS SUMMARIES TEST RESULTS, C at CENTER CITY LEGAL REPRODUCT N PERTAINING TO L,ESr.TF. T.FWTC (Address) 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 s court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME _ FRANCIS R. GARTNER, ESQUIRE +1DDRESS:_ C LR, Inc. 101-1 ,S- :R ad St., Ste 192Q CELEPHONE Ph?l?, PA 19109 iUPREME COUR1. W# J21 51.732-11.77 CITORNEY FOR. DEFENDANT BY THE COURT. Prothonotary / Ckck, Ctvil Disposition ATE: Seal of the Coact Y (EM 71"7 COMMONWEALTH OF PENNSYL`IANIA = COUNTY OF CUMBERLAND LESLIE LEWIS VS JANE E. CLEPPER File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: LIBERTY MUTUAL INSURANCE COMPANY- CLAIMS 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 documents or things: ANY AND ALL RECORDS, REPORTS, MEMOS, DOCUMETES, ANY WRITTEN INFORMATION CONTAINED IN FILE REGARDING CLAIM #403100100001; DATE OF LOSS: 6/30/2007.. at CENTER CITY LEGAL REPRODUCTIONS, . (Address) 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. nilS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: YAME: FRANCIS R. GARTNER, ESQUIRE ADDRESS:_ CCLR, Inc. S_ road St., Ste 1920 IELEPHO[YE: Phila, PA 191.09 oUPREME COURT 113# _ (21SV-732-11.77 WMRNEY FOR: DEFENDANT BY THE COURT. Ptnthoaotacy / Clerk, Civil Dispaaitioa ATE: Sea! of the Court Deputy (Eit 7/97) COMMONWEALTH OF PENNSYLVANIA = COUNTY OF CUMBERLAND LESLIE LEWIS VS JANE E. CLEPPER - File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: MARK P. HOLENCIK, D.O.- MEDICAL RECORDS DEBT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC CENTER CITY LEGAL REPRODUCTIONS, PERTAINING TO LESLIE LEWIS. at (Address) 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 malting 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: .4AME:_ FRANCIS R. GARTNER, ESQUIRE 1DDRESS: CCLR, Inc. -?•g?3 S-- Broad St., Ste 1920 TELEPHONE: -Phila.. PA 19109 aJPREM£ COURT 1D# 2151-732-1177 WWRNEY FOR: DEFENDART BY THE COURT. Prothonotary / Clerk, Ova Disposition ATE- seal of the Court nay COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LESLIE LEWIS VS JANE E. CLEPPER File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PAUL C_ MCAFEE, M.D. - MEDICAL 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 documents or things: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC CENTER CITY LEGAL REPRODUCTIONS, INC. at PERTAINING TO LESLIE LEWIS. (Address) 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 pmpadrig 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: FRANCIS R. GARTNER, ESQUIRE 4DDRESS: CCLR, Inc. on S_ laroad St.. Ste 1920 TELEPHONE: Phil, PA 19109 ;UPREME COUI r ID# 1215) 732-1177 ?'IWRNEY FOR: DEFENDA T BY THE COURT: ATE:- seal of the Coact Prothonotary / Cleric, 04 DLVmtm (EA7197): COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LESLIE LEWIS VS JANE E. CLEPPER File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ROBERT J. BEAUDRY DMD- MEDICAL 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 documents or things: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS LAB TESTS' EVALUATIQNS, ETC at CENTER CITY LEGAL REPRODUCTIONS, PERTAINING TO LESLIE LEWIS. (Address) 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 prepariAg the copies or pFoducing 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: FRANCIS R. GARTNER, ESQUIRE HAME. ADDRESS: CCLR. Inc. 1 vn s.- :Broad St., Ste 1920 TELEPHONE: - Pheja s-pA 19109 :UPREME COURT W# 2151732-1177 W17ORNEY FOR: DEFENDA T BY THE COURT: ATE." Seal of tie Court Ptotionotaty / Clerk, Civil Disposition y COMMONWEALTH OF PENNSYLVANIA = COUNTY OF CUMBERLAND LESLIE LEWIS VS JANE E. CLEPPER - File No. 08-4920 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: RWC EMERGENCY PHYSICIANS- MEDICAL 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 documents or things: ANY AND ALL MEDICAL RECORDS, REPORTS, OFFICE NOTES, PROGRESS REPORTS, DOCTORS NOTES CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC at CENTER CITY LEGAL REPRODUCTIONS, PERTAINING TO LESLIE LEWIS. (Address) You may deliver or avail 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 prepari>ig 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: ,? FRANCIS R. GARTNER, ESQUIRE +1DDRESS: ?CLR, Inc. ? 9% SBroad St., Ste 1920 TELEPHONE: Phila. PA 19,109 .UPREME Cpulrr 2151732-1177 CTPORNEY FOR: DEFENDAT ATE: . Seal of the court BY THE COURT. Pro6motary / Clerk, avil Disposition o 71m Dusan Bratic, Esq. ID 19249 Bratic & Portko 101 South US Route 15, Suite A Dillsburg, PA 17019 (717) 432-9706 Attorney for Plaintiff 7: Zu`ni`, ? E3 ; Ito AEG lS ? n?' : SI C1.. - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P15NNSYLVANIA CIVIL DIVISION LESLIE LEWIS PLAINTIFF V. JANE E. CLEPPER DEFENDANT CIVIL ACTION: 08-4920 JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filings 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en law paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en ,persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, is corte tomam medidas y puede continuer is demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas law provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENT)E. SI NO TIENE ABOGADO O SI NO TIENE ELDINERO SUFICIENTE DE PAGAR'TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONNE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Dusan Bratic, Esq. ID 19249 Bratic & Portko 101 South US Route 15, Suite A Dillsburg, PA 17019 (717) 432-9706 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION LESLIE LEWIS PLAINTIFF V. JANE E. CLEPPER DEFENDANT CIVIL ACTION: 08-4920 JURY TRIAL DEMANDED COMPLAINT NOW COMES the Plaintiff, Leslie Lewis, by and through her counsel, Dusan Bratic, Esquire of Bratic & Portko and makes the within Complaint against the Defendant, Jane E. Clepper, as follows: 1. Plaintiff, Leslie Lewis, is an adult individual residing at 73 Mountain Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant, Jane E. Clepper, is an adult individual who at the time of the accident was residing at 13 Abbey Court, Carlisle, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or about August 15, 2006 at or about 6:45 p.m. at or about the intersection of Forge Road and Overfield Drive in South Middleton Township, Cumberland County, Pennsylvania 4. At the aforesaid time and place, Plaintiff, Leslie Lewis, was the driver of a 1999 Saturn Sedan. 5. At the aforesaid time and place Leslie Lewis was traveling in the lane of travel reserved for her vehicle, north bound on Forge Road in the direction of Overfield Drive, the Plaintiffs lane of travel had the right of way and did not have any traffic control devices or signs restricting movement for Forge Road at its intersection with Overfield Drive. 6. At the aforesaid time and place Defendant, Jane E. Tepper, was the operator of a 1994 Honda Prelude, which was traveling east on Overfield Drive in the direction of Forge Road. Overfield Road was controlled by a stop sign in the east bound direction prior to its intersection with Forge Road. 7. At the time and place, relevant to this complaint, the vehicle operated by Defendant, Jane E. Clepper, was caused or allowed to 'go out of control smashing into the vehicle operated by Leslie Lewis, which was then propelled into another vehicle, and thereby causing the Plaintiff to sustain the serious injuries set forth below. 8. Said collision and all of the herein mentioned injuries and damages sustained by Plaintiff are the direct result of the negligent, careless and reckless manner in which Defendant, Jane E. Clepper, operated her vehicle in causing the aforesaid collision, including but not limited to: (a) In failing to keep proper and adequate control over her vehicle; (b) In driving her vehicle in a reckless manner and with careless disregard for the rights and safety of others and in operating her vehicle upon the highway in a manner endangering persons and property in violation of 75 Pa.C.S.A. Section 3714; (c) In failing to apply her brakes in time to avoid striking the vehicle in which Plaintiff was an operator; (d) In being inattentive and failing to maintain a sharp lookout of the road and the surrounding traffic conditions in violation of 75 Pa.C.S.A. Section 3303; (e) In failing to stop her vehicle at a stop sign before entering the intersecting roadway of Forge Road and in failing to yield the right of way to the vehicle operated by the Plaintiff, which had the right of way, in violation of 75 Pa.C.S.A. §3323(a)(b); (f) Failing to operate her vehicle in accordance with existing traffic conditions and traffic controls and in violation of 75 Pa.C.S.A. Section 3303; (g) Failing to obey a traffic control device (stop sign) in violation of 75 Pa.C.S.A. Section 3111; (h) Otherwise operating her vehicle in a careless, reckless, and negligent manner and in a manner violating the Motor Vehicle Code of the Commonwealth of Pennsylvania. 9. As a result of the aforementioned accident, Plaintiff, Leslie Lewis, sustained painful and severe injuries and or aggravation of previous conditions, including but are not limited to: (a) Abrasions, contusions and injuries to her muscles and nerves; (b) Temporomandibular joint injuries; (c) Injuries to her head, neck and back, resulting in disc herniations and surgeries; (d) Thoracic outlet syndrome, resulting in bilateral surgeries; 10. By reason of the aforesaid injuries sustained by Plaintiff, Leslie Lewis, she was forced to incur liability for medical expense and treatment, medications, hospitalizations and similar miscellaneous expenses, including replacement services, in an effort to restore herself to health, and claim is made therefore. 11. Because of the nature of her injuries, Plaintiff, Leslie Lewis, has been advised, and therefore, avers the she may be forced to incur expenses for medical treatment in the future, and claim is made therefore. 12.. As a result of the aforesaid injuries, Plaintiff, Leslie Lewis, has undergone and in the future will undergo a great deal of physical and mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefore. 13. As a result of the aforesaid injuries, the Plaintiff, Leslie Lewis, has been and in the future will be subject to humiliation and embarrassment, and claim is made therefore. 14. As a result of the aforementioned injuries, Plaintiff, Leslie Lewis, has sustained work loss, loss of opportunity and a permanent diminution of her earning power and capacity, and claim is made therefore. 15. As a result of the aforesaid injuries, Plaintiff, Leslie Lewis, has sustained uncompensated work loss, and claim is made therefore. 16. Plaintiff, Leslie Lewis, continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefore. 17. As a result of the aforesaid accident, Plaintiff, Leslie Lewis, has sustained scarring and may sustain future scars, which has and will result in a permanent disfigurement, and claim is made therefore. r 18. Plaintiff, Leslie Lewis, has been plagued by persistent pain and limitation of body and, therefore, avers that she sustained serious impairment of body function and disfigurement and a claim is made therefore. WHEREFORE, Plaintiff, Leslie Lewis, demands judgment of the Defendant, Jane E. Clepper, in an amount in excess of Fifty Thousand and 00/100 ($50,000) Dollars and in excess of the amount requiring compulsory arbitration. Dated: 1?- 11-1 o Dusan Bratic ID # 19249 101 South U.S. Route 15 Dillsburg, PA 17019 (717) 432-9706 Attorney for Plaintiff VERIFICATION DUSAN BRATIC, ESQUIRE hereby states that he is attorney for the Plaintiff in this action, and is authorized to verify that the statements made in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. & PORTKO 0111 Dated : Du an Bratic, Esquire ID # 19249 101 South U.S. Route 15 Dillsburg, PA 17019 (717) 432-9706 Attorney for Plaintiffs Dusan Bratic, Esq. ID 19249 Bratic & Portko 101 South US Route 15, Suite A Dillsburg, PA 17019 (717) 432-9706 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION LESLIE LEWIS PLAINTIFF V. JANE E. CLEPPER DEFENDANT CIVIL ACTION: 08-4920 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE HEREBY CERTIFY that Plaintiff provided Defendant a copy of the Plaintiffs Complaint by U.S. Mail, first class, postage prepaid on the 11th day of August 2010, to: Francis R. Gartner, Esquire WILLIAM J. FERREN & ASSOCIATES 10 Sentry Parkway, Suite 301 Blue Bell, PA 19422 Attorney for Defendant BRA= & PORTKO Dated: g - l U Dusan Bratic, Esquire Attorney I.D. No. 19249 101 U.S. Route 15 South Dillsburg, PA 17019 (717) 432-9706 Attorney for Plaintiff WILLIAM J. FERREN & ASSOCIATES Francis R. Gartner, Esquire Atty ID # 49436 10 Sentry Parkway, Suite 301 Blue Bell, PA 19422 (215) 274-1710 LESLIE LEWIS Plaintiff V. JANE E. CLEPPER Defendant TO: PLAINTIFF YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR JUDGMENT MAY BE ENTERED AGAINST r, \,Franci Ga n , Esquire A orney for D ndant --» I Attorney for Defendar Jane E. Clepper S(z w COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-4920 Civil Term ANSWER AND NEW MATTER OF DEFENDANT JANE E. CLEPPER TO PLAINTIFF'S COMPLAINT Denied. After reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein since the means of proof are within the exclusive control of an adverse party and, thus, said allegations are denied with strict proof thereof being demanded at the time of trial. 2. Admitted. ,Admitted. 4. Denied. After reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein since the means of proof are within the exclusive control of an adverse party and, thus, said allegations are denied with strict proof thereof being demanded at the time of trial. 5. Denied. After reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein and. thus. said allegations are denied with strict proof thereof being demanded at the time of trial. 6. Admitted. 7. Admitted in part, denied in part. It is admitted only that defendant was involved in a collision with another vehicle. With regard to the remaining allegations, sfter reasonable investigation. defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein and, thus, said allegations are denied with strict proof thereof being demanded at the time of trial. 8. Denied. After reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein and, thus, said allegations are denied with strict proof thereof being demanded at the time of trial. Further, this averment contains allegations which are conclusions of law to which no response is required. 9. Denied. After reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein since the means of proof are within the exclusive control of an adverse party and, thus, said allegations are denied with strict proof thereof being demanded at the time of trial. Further. this averment contains allegations which are conclusions of law to which no response is required. 10. Denied. After reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein since the means of proof are within the exclusive control of an adverse party and, thus, said allegations are denied with strict proof thereof being demanded at the time of trial. 11. Denied. After reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein since the means of proof are within the exclusive control of an adverse party and, thus, said allegations are denied with strict proof thereof being demanded at the time of trial. 12. Denied. After reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein since the means of proof are within the exclusive control of an adverse party and. thus, said allegations are denied with strict proof thereof being demanded at the time of trial. l3. Denied. After reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein since the means of proof are within the exclusive control of an adverse party and, thus, said allegations are denied with strict proof thereof being demanded at the time of trial. 14. Denied. After reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein since the means of proof are within the exclusive control of an adverse party and, thus, said allegations are denied with strict proof thereof being demanded at the time of trial. 1-5. Denied. After reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein since the means of proof are within the exclusive control of an adverse party and, thus, said allegations are denied vvith strict proof thereof being demanded at the time of trial. 16. Denied. After reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein since the means of proof are within the exclusive control of an adverse party and, thus, said allegations are denied with strict proof thereof being demanded at the time of trial. 17. Denied. After reasonable investigation, defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein since the means of proof are within the exclusive control of an adverse party and. thus, said allegations are denied with strict proof thereof being demanded at the time of trial. 18. Denied. After reasonable investigation. defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations contained herein since the means of proof are within the exclusive control of an adverse party and, thus. said allegations are denied with strict proof thereof being demanded at the time of trial. WHEREFORE, Defendant demands that Plaintiffs Complaint be dismissed. NEW MATTER DIRECTED TO THE PLAINTIFF 19. Some or all of the damages claimed by Plaintiff are not recoverable under applicable law. 20. If Plaintiff suffered injuries or damages as alleged.. which averments are denied, then the sole and exclusive cause of any such alleged injuries or damages was the negligence and carelessness of others and not that of the Defendant. 21. The negligent acts and/or omissions of other individuals and/or entities may have constituted an intervening, superseding cause of the damages alleged to have been sustained by the Plaintiff. 22. Plaintiffs claims may be barred in whole or in part by the applicable Statute of Limitations. 23. Plaintiff s claims may be barred in whole or in part by the applicable doctrines of release and/or accord and satisfaction. 24. Plaintiff s claims may be barred in whole or in part by the applicable doctrines of res judicata and/or collateral estoppel. 25. Plaintiffs claims may be barred in whole or in part by the applicable provisions of the Pennsylvania Financial Responsibility Law. 26. At the time of the accident, Plaintiff failed to maintain financial responsibility on an owned motor vehicle and thus Plaintiffs claims for non-economic damages are barred by the applicable provisions of the Pennsylvania Financial Responsibility Law. 27. At the time of the accident, Plaintiff was the owner of an insured motor vehicle and selected the Limited tort option and thus Plaintiffs claims for non-economic damages are barred by the limited tort provisions of the Pennsylvania Financial Responsibility Law. 28. Plaintiffs' claims are barred in whole or in part by the Doctrine of Comparative Negligence. WHEREFORE, Defendant demands that Plaintiffs Complaint be dismissed. WILLIAM J.F//ERREN & ASSOCIATES B (Dras R. rtner. Esquire Attorney f Defendant VERIFICATION I, Jane E. Clepper, hereby depose and state that I have reviewed. the foregoing Answer to Plaintiffs' Complaint with New Matter and the facts contained therein are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of I8 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. r`f -? 6, C. e E. Clepper Dated{' WILLIAM J. FERREN & ASSOCIATES Francis R. Gartner, Esquire Atty ID # 49436 10 Sentry Parkway, Suite 301 Blue Bell, PA 19422 (215) 274-1710 Attorney for Defendant Jane E. Clepper LESLIE LEWIS Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. NO. 08-4920 Civil Term JANE E. CLEPPER Defendant CERTIFICATE OF SERVICE I, FRANCIS R. GARTNER, ESQUIRE, attorney for Defendant, Zaderine Brown, hereby certify that a true and correct copy of Defendant's Answer and New Matter to Plaintiffs Complaint was served upon the following, by way of regular first class mail and/or electronic mail, postage prepaid on August 24, 2010: Dusan Bratice, Esquire 101 South US Route 15 Dillsburg, PA 17019 WILLIAM J. FERREN & ASSOCIATES By 1krancii. Ga oer, Esquire At ornev for Defendant Dusan Bratic, Esq. ID 19249 Bratic & Portko 101 South US Route 15, Suite A Dillsburg, PA 17019 (717) 432-9706 Attorney for Plaintiff FILED-OFFICE OF THE PROTHONOTARY 2011 9: 46 CiUMBrEF'LG CO UNTY PENi1ilSYL" AMA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION LESLIE LEWIS PLAINTIFF V. JANE E. CLEPPER, DEFENDANT CIVIL ACTION - LAW NO.: 2008-4920 JURY TRIAL DEMANDED PRAECIPE TO SETTLE AND SATISFY TO THE PROTHONOTARY: Please mark the above captioned matter settled and satisfied. Dated:/ 7 2?1?eQ I Dusan Bratic, Esquire, ID 19429 101 South U.S. Route 15 Dillsburg, PA 17019 (717) 432-9706 Attorney for Plaintiff Dusan Bratic, Esq. ID 19249 Bratic & Portko 101 South US Route 15, Suite A Dillsburg, PA 17019 (717) 432-9706 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION LESLIE LEWIS PLAINTIFF V. JANE E. CLEPPER DEFENDANT CIVIL ACTION: 08-4920 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE HEREBY CERTIFY that Plaintiff provided Defendant a copy of the Plaintiffs Praecipe to Settle and Satisfy by U.S. Mail, first class, postage prepaid on the 7th day of January 2011, to: Francis R. Gartner, Esquire WILLIAM J. FERREN & ASSOCIATES 10 Sentry Parkway, Suite 301 Blue Bell, PA 19422 Attorney for Defendant BRIATIC & PORTKO Dated: Z? 'Dusan Bratic, Esquire Attorney I.D. No. 19249 101 U.S. Route 15 South Dillsburg, PA 17019 (717) 432-9706 Attorney for Plaintiff