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Home My WebLink About08-6922 ,/Andrew C. Spears, Esquire I.D.#87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax : (717) 233-3029 E-mail: Spears@HHRLaw.com Attorneys for Plaintiffs ANNETTE SAWYERS and KERRY SAWYERS, her husband, Plaintiffs v. LAUREN STEPHENSON, flk/a LAUREN BURKHART, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA NO. 08 - IA;,Q Ci I T?err? : CIVIL ACTION - LAW 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 filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 717-249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacibn de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reciamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 717-249-3166 Andrew C. Spears, Esquire I.D.#87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax : (717) 233-3029 E-mail: Spears@HHRLaw.com ANNETTE SAWYERS and KERRY SAWYERS, her husband, Plaintiffs V. LAUREN STEPHENSON, f/k/a LAUREN BURKHART, Defendant Attorneys for Plaintiffs : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA NO. G (? ? a C I U f ernes CIVIL ACTION - LAW COMPLAINT AND NOW, come the Plaintiffs, Annette Sawyers and Kerry Sawyers, by and through their attorney, HANDLER, HENNING & ROSENBERG, LLP, by Andrew C. Spears, Esquire, and make the within Complaint against the Defendant, Lauren Stephenson, f/k/a Lauren Burkhart, and aver as follows: 1. Plaintiff, Annette Sawyers, is an adult individual currently residing at 1507 Vernon Street, Harrisburg, Dauphin County, Pennsylvania 17104. 2. Plaintiff, Kerry Sawyers, is an adult individual currently residing at 1507 Vernon Street, Harrisburg, Dauphin County, Pennsylvania 17104. 3. Defendant, Lauren Stephenson, is an adult individual currently residing at 241 Walton Street, Lemoyne, Cumberland County, Pennsylvania 17043. At all times material hereto, Defendant went by the name Lauren Burkhart. 4. At all times material hereto, Plaintiff, Annette Sawyers, was the owner and operator of a 1999 Ford Explorer bearing Pennsylvania registration number DXP 0130. (hereinafter "Plaintiff's vehicle"). 5. At all times material hereto, Defendant, Lauren Stephenson, was the owner and operator of a 2006 Honda Accord bearing Pennsylvania registration DZS3938. (hereinafter "Defendant's vehicle"). 6. At all times material hereto, Plaintiff, Annette Sawyers, was insured under a Pennsylvania motor vehicle policy through Capital Insurance Company, with said policy providing for Full Tort status. 7. At all times material hereto, there were no adverse weather or road conditions. 8. On or about December 14, 2006, at about 4:45 p.m., Plaintiff, Annette Sawyers, was lawfully stopped at a stop sign, having just merged onto the Shiremenstown Exit, and was yielding to oncoming traffic awaiting a safe opportunity to turn onto Simpson Ferry in Camp Hill, Cumberland County, Pennsylvania. 9. At approximately the same time and place, Defendant, was traveling directly behind Plaintiff heading toward the stop sign off the Shiremenstown Exit at the intersection with Simpson Ferry Road, in Camp Hill, Cumberland County, Pennsylvania. 2 10. Suddenly and without warning, the vehicle being operated by Defendant failed to come to a safe stop behind Plaintiff's vehicle and violently impacted the rear of said vehicle, while Plaintiff's vehicle was lawfully stopped at the stop sign yielding to traffic on Simpson Ferry Road. 11. As a direct and proximate result of the negligence of the Defendant, Plaintiff, Annette Sawyers, sustained personal injuries, as set forth more specifically below: COUNT I - NEGLIGENCE Annette Sawyers v. Lauren Stephenson, f/k/a Lauren Burkhart 12. Plaintiff, Annette Sawyers, incorporates and makes part of this Count, paragraphs 1 through 11 above, as if the same were set forth fully below. 13. The occurrence of the aforementioned collision and the resultant injuries to Plaintiff, Annette Sawyers, are the direct and proximate result of the negligence, carelessness, and/or recklessness of Defendant, generally and more specifically as set forth below: (a) In failing to be reasonably vigilant to observe the road and traffic conditions then and there existing; (b) In failing to have due regard for the speed of the vehicles, the traffic upon the road and the condition of the highway, in violation of 75 Pa. C.S.A. § 3310(a); (c) In failing to operate her vehicle in such a manner that would allow her to apply the brakes and stop before striking the rear of the vehicle in front of her; 3 (d) In failing to operate her vehicle under proper and adequate control so that she could have avoided striking the rear of Plaintiff's vehicle in front of her; (e) In failing to properly regulate the speed of her vehicle so as to prevent a rear- end collision; (f) In failing to operate her vehicle at a speed and under such control so as to be able to stop within the assured clear distance, in violation of 75 Pa. C.S.A. § 3361; (g) In failing to operate her vehicle at a speed that was safe for existing conditions, in violation of 75 Pa. C.S.A. § 3361; (h) In following another vehicle more closely than is reasonable and prudent; (I) In failing to keep a proper lookout for vehicles lawfully stopped at the stop sign properly yielding to traffic traveling on Simpson Ferry Road, Camp Hill, Cumberland County, Pennsylvania; 0) In failing to exercise reasonable care in the operation and control of her vehicle, in violation of 75 Pa. C.S.A. § 3714; (k) In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have her vehicle under such control that injury to persons or property could be avoided; and (1) In otherwise driving her vehicle upon the roadway in a manner endangering persons and property and in a manner with careless 4 disregard to the rights and safety of others in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 14. As a direct and proximate result of the Defendant's negligence, Plaintiff, Annette Sawyers, sustained injuries, including, but not limited to pain in her neck, back and shoulder. 15. As a direct and proximate result of the Defendant's negligence, Plaintiff, Annette Sawyers, has suffered physical pain, discomfort, and mental anguish, and she will continue to endure the same for an indefinite period of time in the future, to her physical, emotional, and financial detriment and loss. 16. As a direct and proximate result of the negligence of the Defendant, the Plaintiff, Annette Sawyers, has suffered a loss of income and/or loss of earning capacity. 17. As a direct and proximate result of the Defendant's negligence, Plaintiff, Annette Sawyers, has been compelled, in order to effect a cure for the aforesaid injuries, to spend money for medicine and/or medical attention, and will be required to expend more for the same purposes into the future, to her detriment and loss. 18. As a direct and proximate result of the Defendant's negligence, Plaintiff, Annette Sawyers, has been, and probably will in the future be, hindered from attending to her daily duties, to her detriment, loss, humiliation, and embarrassment. 19. As a direct and proximate result of the Defendant's negligence, Plaintiff, Annette Sawyers, has suffered a loss of life's pleasures, and will continue to endure the same in the future, to her detriment and loss. 5 WHEREFORE, Plaintiff, Annette Sawyers, seeks damages from Defendant, Lauren Stephenson, f/k/a Lauren Burkhart, in an amount in excess of the compulsory arbitration limits of Cumberland County, exclusive of interest and costs. COUNT II - LOSS OF CONSORTIUM Kerry Sawyers v. Lauren Stephenson 20. Plaintiff, Kerry Sawyers incorporates and makes part of this Count paragraphs 1 through 19 above, as if the same were set forth fully below. 21. At all times material to this action, Plaintiffs, Kerry Sawyers and Annette Sawyers, were lawfully married as husband and wife. 22. As a direct and proximate result of Defendant's negligence, the Plaintiff, Kerry Sawyers, has suffered a loss of consortium, society, and comfort from his wife, Annette Sawyers, and he will continue to suffer a similar loss in the future. 23. As a direct and proximate result of Defendant's negligence, the Plaintiff, Kerry Sawyers, has been compelled, in order to effect a cure for his wife's injuries, to expend money for medicine and medical attention and will be required to expend more for the same purposes into the future, to his detriment and loss. 6 WHEREFORE, Plaintiff, Kerry Sawyers, seeks damages from the Defendant, Lauren Stephenson, f/k/a Lauren Burkhart, in an amount in excess of the compulsory arbitration limits of Cumberland County exclusive of interest and costs. Date: Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP By: - C'-? Andrew C. Spears, Esquire I.D. #87737 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorneys for Plaintiffs 7 VERIFICATION The undersigned hereby verifies that the statements in the foregoing document are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the document is 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 counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the document are that of counsel, I have relied upon my counsel in making this Verification. The undersigned also understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: / CJ VERIFICATION The undersigned hereby verifies that the statements in the foregoing document are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the document is 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 counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the document are that of counsel, I have relied upon my counsel in making this Verification. The undersigned also understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. -?2U Annette Sawyers Date: c7 *? C ? ? ems. 0 LAW OFFICES OF JAMES W. HARVEY BY: JAMES W. HARVEY, ESQUIRE Attorney for Defendants, Pa. I.D. No. 33462 LAUREN STEPHENSON, ROSSLYN COMMONS f/k/a LAUREN BURKHART 333 BALDWIN RD., 3`d FLOOR PITTSBURGH, PA 15205 (412) 429-5842 ANNETTE SAWYERS and KERRY SAWYERS, her husband, Plaintiffs v. LAUREN STEPHENSON, f/k/a LAUREN BURKHART, Defendant : COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW JURY TRIAL DEMANDED NO: 08-6922 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter my appearance on behalf of LAUREN STEPHENSON, f/k/a LAUREN BURKHART, Defendant in the above-captioned matter. LAW OFFICES OF JAMES W. HARVEY Date: PI-01-06 By: S W. HARVEY, QUIRE a!E? M Attorney for Defendant LAUREN STEPHENSON, f/k/a LAUREN BURKHART Rosslyn Commons 333 Baldwin Road, 3`d Floor Pittsburgh, PA 15205 (412) 429-5842 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing PRAECIPE TO ENTER APPEARANCE was served by U.S. First Class Mail, postage prepaid, this ),t- day of December 2008, upon the following counsel of record: Andrew C. Spears, Esq. Handier, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiffs AMES W. HARVEY, ESQUIRE "y ; ,.,. -, --? :_ t;: ?? ..?.. r; SHERIFF'S RETURN - REGULAR CASE NO: 2008-06922 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SAWYERS ANNETT ET AL VS STEPHENSON LAUREN FKA BURKHART RONALD E HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon STEPHENSON LAUREN F/K/A LAUREN BURKHART the DEFENDANT at 0020:32 HOURS, on the 24th day of November-, 2008 at 241 WALTON STREET LEMOYNE, PA 17043 by handing to CHRISTINE STEPHENSON ADULT IN CHARGE/MOTHER-IN-LAW a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 14.40 Affidavit 00 Surcharge 10.00 R. 11homas Kline Postage 42 !z?/?bF v 42.82 12/02/2008 HANDLER HENNING ROSEN13ERG Sworn and Subscibed to By: before me this day Deputy ?Taeriff of A.D. A ROLF E. KROLL, ESQUIRE Pa. Supreme Court I.D. No. 47243 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, Pennsylvania 17011 Telephone: [717] 975-8114 Direct Dial: (717) 760-7502 Attorneys for Defendant: Fax: [717] 975-8124 LAUREN STEPHENSON E-Mail: rkroll@margolisedelstein.com Vk1a LAUREN RURIOiART ANNETTE SAWYERS and : IN THE COURT OF COMMON PLEAS KERRY SAWYERS, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs, : CIVIL ACTION - LAW V. NO. 08-6922 CIVIL TERM LAUREN STEPHENSON f/k/a ; LAUREN BURKHART, Defendant. : JURY TRIAL DEMANDED PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA: Kindly enter my appearance on behalf of Defendant, LAUREN STEPHENSON f/k/a LAUREN BURKHART, in the above-captioned matter. Respectfully submitted, Date: ROLF. KROLL, ESQUIRE PA. ttorney I.D. No. 47243 Attorney for Defendant, LAUREN STEPHENSON f/k/a LAUREN BURKHART 3 510 Trindle Road Camp Dill, PA 17011 (717) 975-8114 I CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing PRAECIPE TO ENTER APPEARANCE on all counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first-class postage prepaid, on the Addayff (? , 2009, and addressed as follows: =;F Andrew C. Spears, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 JoAnn E. Nelson, ?t +?? t.' 1"T'i f ti ?' 1 _. :.? ??'. ??~ J Andrew C. Spears I.D.#87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax : (717) 233-3029 E-mail: Spears@HHRLaw.com ANNETTE SAWYERS, Plaintiff V. LAUREN BURKHART, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6922 CIVIL ACTION - LAW JURY TRIAL DEMANDED TO: Lauren Burkhart c/o James Harvey, Esquire Law Offices of James W. Harvey Rosslyn Commons Bldg, 3rd Floor 333 Baldwin Road Pittsburgh, PA 15205 (Defendant) DATE OF NOTICE: _January 8, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 717-249-3166 Andrew C. Spears, Esquire Atty. I.D. #87737 Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Andrew C. Spears, Esquire AVISO IMPORTANTE A: Lauren Burkhart c/o James Harvey, Esquire Law Offices of James W. Harvey Rosslyn Commons Bldg, 3rd Floor 333 Baldwin Road Pittsburgh, PA 15205 (Defendido) FECHA DEL AVISO: USTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARECENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA LISTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y LISTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOSIMPORTANTES. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 717-249-3166 Andrew C. Spears, Esquire Atty. I.D. #87737 Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Andrew t. SpXars, Esquire Ar Andrew C. Spears I.D.#87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax : (717) 233-3029 E-mail: Spears@HHRLaw.com ANNETTE SAWYERS, Plaintiff V. LAUREN BURKHART, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6922 : CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE On 1/8/09, 1 hereby certify that a true and correct copy of a Notice of Default was served upon the following by depositing same in the United States Mail, in Harrisburg, Pennsylvania: James Harvey, Esquire Law Offices of James W. Harvey Rosslyn Commons Bldg, 3rd Floor 333 Baldwin Road Pittsburgh, PA 15205 Dated: 1/8/09 HANDLER, HENNING & ROSENBERG, LLP Andrew r' Wears I.D. #87737 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiff n a ..'> y C? C ' ..rte' Andrew C. Spears I.D.#87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax : (717) 233-3029 E-mail: Spears@HHRLaw.com ANNETTE SAWYERS, Plaintiff V. LAUREN BURKHART, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-6922 CIVIL ACTION - LAW JURY TRIAL DEMANDED TO: Lauren Burkhart c/o Rolf Kroll, Esquire Margolis Edelstein 3510 Trindle Rd. Camp Hill, PA 17011 (Defendant) DATE OF NOTICE: -February 11, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 717-249-3166 Andrew C. Spears, Esquire Atty. I.D. #87737 Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Andrew C. Spears, Esquire AVISO IMPORTANTE A: Lauren Burkhart c/o Rolf Kroll, Esquire Margolis Edelstein 3510 Trindle Rd. Camp Hill, PA 17011 (Defendido) FECHA DEL AVISO: LISTED ESTA EN REBELDIA PORQUE HA FALLADO DE REGISTRAR COMPARECENCIA ESCRITA POR SI MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOS CARGOS QUE SE HAN PRESENTADO CONTRA USTED. A MENOS QUE LISTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SUYA SIN TENER DERECHOS A UNA VISTA Y LISTED PUEDE PERDER SU PROPIEDAD U OTROS DERECHOSIMPORTANTES. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESE S CIOS LEGALES S CARGO 0 BA JO COSTO A PERSONAS QUE CUAL F CAN. RO I CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 717-249-3166 Andrew C. Spears, Esquire Atty. I . D. #87737 Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 C -QC-- Andrew . Spears, Esquire C5 r. rt ) }? N ? ROLF E. KROLL, ESQUIRE Pa. Supreme Court I.D. No. 47243 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, Pennsylvania 17011 Telephone: [717] 975-8114 Direct Dial: (717) 760-7502 Attorneys for Defendant: Fax: [717] 975-8124 LAUREN STEPHENSON E-Mail: rkroll@margolisedelstein.com Wa LAUREN BURKHART ANNETTE SAWYERS and : IN THE COURT OF COMMON PLEAS KERRY SAWYERS, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs, : CIVIL ACTION - LAW V. NO. 08-6922 CIVIL TERM LAUREN STEPHENSON f/k/a ; LAUREN BURKHART, Defendant. : JURY TRIAL DEMANDED NOTICE TO PLEAD TO: ANNETTE SAWYERS and KERRY SAWYERS, her husband c/o Andrew C. Spears, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 YOU ARE HEREBY NOTIFIED to plead to the enclosed NEW MATTER within twenty (20) days of service hereof, or a default judgment may be entered against you. Respectfully submitted, Date: Z// Lo ? By 3510 Trindle Road Camp Hill, PA 17011 (717) 975-8114 Attorney for Defendant, LAUREN STEPHENSON f/k/a LAUREN BURKHART ROLF E. KROLL, ESQUIRE Pa. Supreme Court I.D. No. 47243 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, Pennsylvania 17011 Telephone: [717] 975-8114 Direct Dial: (717) 760-7502 Attorneys for Defendant: Fax: [717] 975-8124 LAUREN STEPHENSON E-Mail: rkroll@margolisedelstein.com VWa LAUREN BURKHART ANNETTE SAWYERS and : IN THE COURT OF COMMON PLEAS KERRY SAWYERS, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs, : CIVIL ACTION - LAW V. NO. 08-6922 CIVIL TERM LAUREN STEPHENSON f/k/a ; LAUREN BURKHART, Defendant. : JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANT, LAUREN STEPHENSON Vk/a LAUREN BURKHART, TO PLAINTIFFS' COMPLAINT AND NOW, comes Defendant, Lauren Stephenson ("Ms. Stephenson"), by and through her counsel, Margolis Edelstein, to answer the Complaint of Plaintiffs, Annette Sawyers and Kerry Sawyers ("Plaintiffs"), and in support thereof, avers the following: 1-2. Denied. After reasonable investigation, Ms. Stephenson is without knowledge or information sufficient to form a belief as to the truth of the averments in these paragraphs of Plaintiffs' Complaint and they are, therefore, denied. 3. Admitted. 4. Denied. After reasonable investigation, Ms. Stephenson is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs' Complaint and they are, therefore, denied. 5. Admitted. 6. Denied. After reasonable investigation, Ms. Stephenson is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs' Complaint and they are, therefore, denied. 7. Admitted. 8. Denied. This allegation of Plaintiffs' Complaint states a conclusion of law to which no responsive pleading is required and the same is, therefore, denied. By way of further answer, after reasonable investigation, Ms. Stephenson is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs' Complaint and they are, therefore, denied. 9-10. Denied as stated. At all times relevant hereto, Ms. Stephenson's vehicle was on the Shiremanstown exit. By way of further answer, it is admitted that the front of Ms. Stephenson's vehicle came into contact with the rear of Plaintiffs' vehicle. 11. Denied. This allegation of Plaintiffs' Complaint states a conclusion of law to which no responsive pleading is required and the same is, therefore, denied. By way of further answer, after reasonable investigation, Ms. Stephenson is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs' Complaint and they are, therefore, denied. COUNT I- NEGLIGENCE Annette Sawyers v. Lauren Stephenson, f/k/a Lauren Burkhart 12. Paragraphs 1 through 11 are incorporated herein by reference as if set forth in full. 13. (a-1). Denied. The allegations of this paragraph and its corresponding -2- subparagraphs are denied as conclusions of law which require no responsive pleading, and are therefore denied. 14-18. Denied. After reasonable investigation, Ms. Stephenson is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs' Complaint and they are, therefore, denied. 19. Denied. This allegation of Plaintiffs' Complaint states a conclusion of law to which no responsive pleading is required and the same is, therefore, denied. By way of further answer, after reasonable investigation, Ms. Stephenson is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs' Complaint and they are, therefore, denied. WHEREFORE, Defendant, Lauren Stephenson, f/k/a/ Lauren Burkhart, demands judgment in her favor and against Plaintiffs, with costs of suit assessed to Plaintiffs. COUNT II - LOSS OF CONSORTIUM Kerry Sawyers v. Lauren Stephenson 20. Paragraphs 1 through 19 are incorporated herein by reference as if set forth in full. 21. Denied. After reasonable investigation, Ms. Stephenson is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs' Complaint and they are, therefore, denied. 22. Denied. After reasonable investigation, Ms. Stephenson is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs' Complaint and they are, therefore, denied. -3- 23. Denied. This allegation of Plaintiffs' Complaint states a conclusion of law to which no responsive pleading is required and the same is, therefore, denied. By way of further answer, after reasonable investigation, Ms. Stephenson is without knowledge or information sufficient to form a belief as to the truth of the averments in this paragraph of Plaintiffs' Complaint and they are, therefore, denied. WHEREFORE, Defendant, Lauren Stephenson, f/k/a/ Lauren Burkhart, demands judgment in her favor and against Plaintiffs, with costs of suit assessed to Plaintiffs. NEW MATTER 24. The foregoing paragraphs are incorporated herein by reference as though set forth fully at length. 25. Plaintiffs' claims are barred in whole or in part by the limitations of the Pennsylvania Motor Vehicle Financial Responsibility Law. 26. Plaintiffs' claims are barred in whole or in part by the doctrines of contributory and comparative negligence. 27. Plaintiffs' claims are barred in whole or in part by failure to mitigate damages. 28. Plaintiffs have failed to state a claim upon which relief can be granted. 29. Plaintiffs' claims are barred in whole or in part by the Sudden Emergency Doctrine. 30. Plaintiffs' claims may be barred in whole or in part by the doctrines of waiver, accord and satisfaction or estoppel as discovery may reveal. -4- WHEREFORE, Defendant, Lauren Stephenson, f/k/a Lauren Burkhart, demands judgment in her favor and against Plaintiffs, with cost of suit assessed to Plaintiffs. Respectfully submitted, o.ta Z / 7 0 3510 Trindle Road Camp Hill, PA 17011 (717) 975-8114 -5- LAUREN STEPHENSON f/k/a LAUREN BURKHART VERIFICATION I, ROLF E. KROLL, ESQUIRE, individually and as counsel for LAUREN STEPHENSON f/k/a LAUREN BURKHART, have drafted and read the foregoing ANSWER WITH NEW MATTER OF DEFENDANT, LAUREN STEPHENSON f/k/a LAUREN BURKHART, TO PLAINTIFFS' COMPLAINT. The factual statements contained therein are known by me and are true and correct to the best of my knowledge, information and belief. This statement and verification is made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsifications to authorities, which provides that, if I knowingly make false averments, I may bg ?ect t? criminal penalties. Date: / OL , ESQUIRE CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing ANSWER WITH NEW MATTER on all counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first-class postage prepaid, on the ??day of uric , 2009, and addressed as follows: Andrew C. Spears, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 MARGOLIS EDELSTEIN I-TJ By: Kel i Ann Nelson, Paralegal r- CD M rsi. ROLF E. KROLL, ESQUIRE Pa. Supreme Court I.D. No. 47243 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, Pennsylvania 17011 Telephone: 17171975-8114 Direct Dial: (717) 760-7502 Attorneys] for Fax: [7171975-8124 LAUREN!ST] E-Mail: rkroll@margolisedelstein.com Wa LAUREN I ANNETTE SAWYERS and : IN THE COURT OF COMMON PLEAS KERRY SAWYERS, her husband, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs, : CIVIL ACTION - LAW V. : NO. 08-6922 CIVIL TERM LAUREN STEPHENSON f/k/a ; LAUREN BURKHART, Defendant. : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF ADAMS COUNTY: Kindly substitute the attached verification to the Answer with New Matter of Defendant, Lauren Stephenson, to the Complaint of Plaintiff, filed on or about February 17, 2009. Date: Respectfully submitted, MARGOLIS EDELSTEIN By: P4/Attovdifey I.D. No. 47243 Attorney for Defendant, LAUREN STEPHENSON f/k/a LAUREN BURKHART 3510 Trindle Road Camp Hill, PA 17011 (717) 975-8114 VERIFICATION I, LAUREN STEPHENSON, have read the foregoing ANSWER WITH NEW MATTER, which has been drafted by my counsel. The factual statements contained therein are known by me and are true and correct to the best of my knowledge, information and belief. This statement and verification is made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsifications to authorities, which provides that, it I knowingly make false averments, I may be subject to criminal penalties. Date: ?! I Le ) 0 9 ., .. CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing PRAECIPE TO SUBSTITUTE VERIFICATION on all counsel of record by placing the same in the United States mail at Camp Hill, Pennsylvania, first-class postage prepaid, rj on the dS day of 2dru , 2009, and addressed as follows: Andrew C. Spears, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 MARGOLIS EDELSTEIN By: c a C i_7'{ t: N T" Andrew C. Spears I.D.#87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax : (717) 233-3029 E-mail: Spears@HHRLaw.com ANNETTE SAWYERS and KERRY SAWYERS, her husband, Plaintiffs V. LAUREN STEPHENSON, Fk/a LAUREN BURKHART, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6922 CIVIL ACTION - LAW PLAINTIFFS' REPLY TO NEW MATTER AND NOW, come the Plaintiffs, Annette Sawyers and Kerry Sawyers, husband and wife, by and through their attorneys, Handler, Henning and Rosenberg, LLP., and file the within Reply to New Matter and aver as follows: 24. The averments of this paragraph constitute an incorporation paragraph to which no response is necessary. To the extent that a response is required, any and all allegations and insinuations of wrong doing on the part of plaintiffs are hereby denied. 25. The averments in this paragraph constitute a conclusion of law to which no response is required. To the extent a response is required, any and all allegations and insinuations of wrong doing on the part of plaintiffs are hereby denied. 26. The averments in this paragraph constitute a conclusion of law to which no response is required. To the extent a response is required, any and all allegations and insinuations of wrong doing on the part of plaintiffs are hereby denied. 27. The averments in this paragraph constitute a conclusion of law to which no response is required. To the extent a response is required, any and all allegations and insinuations of wrong doing on the part of plaintiffs are hereby denied. 28. The averments in this paragraph constitute a conclusion of law to which no response is required. To the extent a response is required, any and all allegations and insinuations of wrong doing on the part of plaintiffs are hereby denied. 29. The averments in this paragraph constitute a conclusion of law to which no response is required. To the extent a response is required, any and all allegations and insinuations of wrong doing on the part of plaintiffs are hereby denied. 30. The averments in this paragraph constitute a conclusion of law to which no response is required. To the extent a response is required, any and all allegations and insinuations of wrong doing on the part Of Plaintiffs are hereby denied. WHEREFORE, Plaintiffs, Annette Sawyers and Kerry Sawyers, respectfully request that this Honorable Court dismiss Defendant's New Matter and enter judgment in their favor and enter such other orders as are equitable and just. Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP Date: By: An C. Spears, Esquire 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorneys for Plaintiffs VERIFICATION THE UNDERSIGNED hereby verifies that the statements in the foregoing document are based on information that was gathered by counsel in preparation of this lawsuit. The language of the above-named document is of counsel and not my own. I have read the said document and, to the extent that it is based on information that I gave to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the contents of the said document is that of counsel, I have relied upon my counsel in preparing this Verification. THE UNDERSIGNED also understands that the statements therein are made subject to the penalties of 18 Pa.R.C.P. 2252(d) C.S. Section 4904, relating to unsworn falsification to authorities. Date f v q Annette Sawyers VERIFICATION THE UNDERSIGNED hereby verifies that the statements in the foregoing document are based on information that was gathered by counsel in preparation of this lawsuit. The language of the above-named document is of counsel and not my own. I have read the said document and, to the extent that it is based on information that I gave to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the contents of the said document is that of counsel, I have relied upon my counsel in preparing this Verification. THE UNDERSIGNED also understands that the statements therein are made subject to the penalties of 18 Pa.R.C.P. 2252(d) C.S. Section 4904, relating to unsworn falsification to authorities. Dater 4-o(? SaWPA? K rry awyers ANNETTE SAWYERS and KERRY SAWYERS, her husband, Plaintiffs V. LAUREN STEPHENSON, f/k/a LAUREN BURKHART, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6922 : CIVIL ACTION - LAW Defendant CERTIFICATE OF SERVICE AND NOW, this 4 , day of March, 2009, I hereby certify that I have served Plaintiffs' Reply to New Matter upon Counsel of Record by sending a true and correct copy of the same to them via First Class United States mail, postage prepaid, and addressed as follows: First Class U.S. Mail: Rolf E. Kroll, Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 HANDLER, HENNING & ROSENBERG, LLP By: Andrew . Spears, Esquire 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorneys for Plaintiffs n ? ?.? ?? ?; ? _ ? r ? '?? ? ' 1".?_ t ._ . __ _ yy ?? " w? V ?p . . v?'_ ? ?w ? ?S .. ' J 1 . , . j »S ? ?y t? ? L ?. . ? ?'.?..` ?: '"\ ANNETTE SAWYERS and KERRY SAWYERS, her husband, :COURT OF COMMON PLEAS, :CUMBERLAND COUNTY, :PENNSYLVANIA Plaintiffs V. LAUREN STEPHENSON f/k/a LAUREN BURKHART, :CIVIL ACTION LAW :NO. 08-6922 Defendant CERTIFICATE OF SERVICE AND NOW, this 6th day of April, 2009, 1 hereby certify that I have, on this date, served the within Plaintiffs' Response to Defendant's Request for Production of documents , by sending a true and correct copy of the same to the attorney of record via first class United States mail, postage prepaid and addressed as follows: Rolf E. Kroll, Esq. MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 (Attorney for Defendant) Date: 4/6/09 Respectfully submitted, HANDLER, HENNING & ROSENBERG, LLP By: Andrew . pears, Esq. I.D. No. 87737 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiffs OF THE FPo'? ?7APY 2009 APP -7 PIN i =12 0 ANNETTE SAWYERS and KERRY SAWYERS, her husband, :COURT OF COMMON PLEAS, :CUMBERLAND COUNTY, :PENNSYLVANIA Plaintiffs V. LAUREN STEPHENSON f/k/a LAUREN BURKHART, :CIVIL ACTION LAW :NO. 08-6922 Defendant CERTIFICATE OF SERVICE AND NOW, this 6th day of April, 2009, 1 hereby certify that I have, on this date, served the within Plaintiffs' Answers to the Interrogatories of Defendant, by sending a true and correct copy of the same to the attorney of record via first class United States mail, postage prepaid and addressed as follows: Rolf E. Kroll, Esq. MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 (Attorney for Defendant) Date: 4/6/09 Respectfully submitted, HAN=NBERG, LLP By: Andrew C`Spe-art, Esq. I.D. No. 87737 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiffs FlLE?i=???;L OF THE Pr.,, :"";'OTARY 2009 APP --7 FM 1: 30 0 U It v,,. CERTIFICATE 71,nv PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANNETTE SAWYERS AND KERRY SAWYERS TERM, CUMBERLAND -VS- CASE NO: 08-6922 LAUREN STEPHENSON F/K/A LAUREN BURKHART As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ROLF E. KROLL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/10/2009 R1.86S 133-H DE11-1010059 06780-LO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANNETTE SAWYERS AND KERRY SAWYERS -VS- LAUREN STEPHENSON F/K/A LAUREN BURKHART COURT OF COMMON PLEAS TERM, CASE NO: 08-6922 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: ANDREW C. SPEARS, ESQ., PLAINTIFF COUNSEL MCS on behalf of ROLF E. KROLL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/18/2009 CC: ROLF E. KROLL, ESQ. ANDREW C. SPEARS, ESQ. HANDLER, HENNING, ET AL 1300 LINGLESTOWN ROAD HARRISBURG, PA 17110 43500.4-00022 MCS on behalf of ROLF E. KROLL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.86S 133-H DE02-0587213 06780-COI >>> LOCATION LIST <<< NAME HARRISBURG HOSPITAL HARRISBURG HOSPITAL CAPITAL INSURANCE CEN'T'RAL PA. REHAB SERVICES SKOCIK CHIROPRACTIC UNIV. PHYSICIANS GROUP HERSHEY MEDICAL CENTER HERSHEY MEDICAL CENTER ARLINGTON ORTHOPEDIC GROUP NOVA CARE REHAB/JOYNER UNEMPLOYMENT COMPENSATION OFF RECORDS REQUESTED MEDICAL RECORDS X-RAY ONLY INSURANCE MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS EMPLOYMENT PAGE: 1 R1.86S 133-H DE02-0587213 06780-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNETTE SAWYERS AND KERRY SAWYERS File No. 08-6922 VS. LAUREN STEPHENSON F/K/A LAUREN BURKHART SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRTSB TR HOSPIT T. (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: ****SEE ATTACHED I ER * * * * at The MCS Groun. Inc.. 1601 Market Street, Suite 800, Philadelphia, PA 19103 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: ROLF E. KROLL. ES ADDRESS: _510 TRINDL.E ROAD _CAMP HIL,L., PA 17011 TELEPHONE: _ (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant DE/C 101009 _ Date: /// l L. I dpi Seal of the Court 06780-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: 'HARRISBURG HOSPITAL MEDICAL RECORDS Ill S. FRONT STREET HARRISBURG. PA 17101 RE: 6780 KERRY SAWYERS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING BUT NOT LIMITED TO EMERGENCY ROOM RECORDS AND TEST RESULTS. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes., doctor's comments, dietary restrictions, and,all patient consent or refusal of treatment,.procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care,, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: from: 01-01-2004 to 11-11-2009. Subject KERRY SAWYERS 1507 VERNON STREET, HARRISBURG,-PA 17104 Social security #: 162-48-1533 Date of Birth: 07-31-1960 Z1.86S 133-H SU10-0814038 06780-LO1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANNETTE SAWYERS AND KERRY SAWYERS TERM, CUMBERLAND -vs- LAUREN STEPHENSON F/K/A LAUREN BURKHART CASE NO: 08-6922 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ROLF E. KROLL, certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/10/2009 R1.86S 133-H DE11-1010062 06780-L02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNETTE SAWYERS AND KERRY SAWYERS File No. 08-6922 VS. LAUREN STEPHENSON F/K/A LAUREN BURKHART SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (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: **** SEE ATTACHED RIDER **** at The MCS Group, Inc., 1601 Market Street, Suite 800, Philadelphia, PA 19103 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: ROLF E. KROLL. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant I DEC 10 2009 Date: ?( t-09 Seal of the Court BY OURT: Trdthhonotary/Clerk, Civil Divis' eputy 06780-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL RADIOLOGY DEPT. .I11 S. FRONT STREET HARRISBURG, PA 17105 RE: -6780 KERRY SAWYERS Prior approval is required for fees is excess of $150.00 for hospitals, $100.00 for all other providers.. INCLUDING BUT NOT LIMITED TO SCANS OR OTHER STUDIES AND RADIOLOGY REPORTS. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 01-01-2004 to 11-11-2009. Subject c KERRY SAWYERS 1507 VERNON STREET; HARRISBURG, PA 17104 Social Security,#: 162-48-1533 Date of Birth: 07-31-1960 ? 1.86S 133-H SU10-0814040 06780-LO2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNETTE SAWYERS AND KERRY SAWYERS -vs- LAUREN STEPHENSON F/K/A LAUREN BURKHART COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 08-6922 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ROLF E. KROLL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/10/2009 R1.86S 133-H DEII-1010065 06780-L03 Attorney for DEFENDANT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNETTE SAWYERS AND KERRY SAWYERS File No. 08-6922 VS. LAUREN STEPHENSON F/K/A LAUREN BURKHART SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CAPITAL INS IR AN (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: **** SEE ATTACHFD RIDER **** at The M CS Group, Inc-, 1601 Market Street, Suite 800, Philadelphia, PA 19103 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: ROLF E. KROLL, ESO. ADDRESS: 3510 TR RO D CAMP HILL., PA 17011 TELEPHONE: 4215) Z46-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant EC 10 2009 Date: Seal of the Court 06780-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CAPITAL INSURANCE 1120 WELSH ROAD SUITE 220 NORTH WALES. PA 19454 RE: 6780 KERRY SAWYERS Prior approval ,is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. REGARDING YOUR INSURED PAST/OR PRESENT CLAIMS AGAINST HER CARRIER, OR CLAIMS THE INSURED MADE KNOWN TO HER CARRIER WHETER IT WAS DETERMINED SHE WAS AT FAULT OR NOT. INCLUDE ANY/ALL TRAFFIC VIOLATIONS, MOVING, NON-MOVING, INVOLVING.INJURY OR NOT. Date's Re..quested: -up to and including the present.. Subject s KERRY SAWYERS 1507 VERNON STREET, HARRISBURG, PA 17104 Social Security #: XXX-XX-1533 Date of Birth:-07-31-1960 '1.86S 133-H SU10-0814042 06780-LO3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNETTE SAWYERS AND KERRY SAWYERS -VS- LAUREN STEPHENSON F/K/A LAUREN BURKHART COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 08-6922 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ROLF E. KROLL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/10/2009 R1.86S 133-H DE11-1010068 06780-L04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNETTE SAWYERS AND KERRY SAWYERS File No. 08-6922 VS. LAUREN STEPHENSON F/K/A LAUREN BURKHART SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CENTRAL PA. REHAB SERVICES (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: **** SE F ATTA HED RIDER **** at The MCS Gm=, Inc., 1601 Market Street , Suite 800- Philadelphia, PA 19103 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: ROLF E. KROLL. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: (15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant DEC 10 200:91 Date: Ih p 142E Seal of the Court BY THE r1f; o honotary/Clerk, Civil Divis' Deputy 06780-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CENTRAL PA. REHAB SERVICES 805 SIR THOMAS COURT HARRISBURG, PA 17109 RE: 6780 KERRY SAWYERS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING INITIAL EVALUATIONS, TREATMENT RECORDS, CONSULTATION REPORTS OR EXAMINATIONS AND DISCHARGE SUMMARIES. Entire medical and x-ray file, including but not limited to any and all records, correspondence to and from the treating and consulting physicians, files, memoranda, handwritten notes, history and physical reports, x-ray films and reports, medication/prescription records, including any and all such items as may be stored in a .computer database or otherwise in electronic form, relating to any examination, consultation, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : KERRY SAWYERS 1507 VERNON STREET, HARRISBURG, PA 17104 Social security #: XXX-XX-1533 Date of Birth: 07-31-1960 .86S 133-H SU10-0814044 06780-L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANNETTE SAWYERS AND KERRY SAWYERS TERM, CUMBERLAND -vs- CASE NO: 08-6922 LAUREN STEPHENSON F/K/A LAUREN BURKHART As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ROLF E. KROLL, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/10/2009 MCS eh ROL E Att ev f R1.86S 133-H DE11-1010071 06780-L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNETTE SAWYERS AND KERRY SAWYERS VS. File No. - _08-6922 LAUREN STEPHENSON F/K/A LAUREN BURKHART SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SKOCIK CHIROPRACTIC (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: _ **** SEE ATTACHED RIDER **** at The MCS Gn - Inc", 1601 Market Street, Suite 800, P ilad ia, PA 1910' 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: ROLF E. KROLL. ESO ADDRESS: 3510 TRIND RO CAMP HIIL PA 17011 TELEPHONE: -(15) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant DEC 10 2009 Date: D Seal of the Court 06780-05 • EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SKOCIK CHIROPRACTIC 5431 OLD JONESTOWN RD. HARRISBURG. PA. 17112 RE: 6780 KERRY SAWYERS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING BUT NOT LIMITED TO EMERGENCY ROOM RECORDS, SCANS OR OTHER STUDIES, TEST RESULTS, RADIOLOGY REPORTS AND PHYSICAL THERAPY NOTES/ REPORTS. Entire medical and x-ray file, including but not limited to any and all records, correspondence to and from the treating and consulting physicians, files, ,memoranda, handwritten notes, hsto and reports, medication rY and physical reports, x-ray films /prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, care or treatment pertaining to: Dates Requested: up to and including the present. Subject :.KERRY SAWYERS 1507 VERNON STREET, HARRISBURG, PA 17104 Social Security #s XXX-XX-1533 Date of Birth: 07-31-1960 .86S 133-H SU10-0814046 06780-L05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANNETTE SAWYERS AND KERRY SAWYERS TERM, CUMBERLAND -VS- CASE NO: 08-6922 LAUREN STEPHENSON F/K/A LAUREN BURKHART As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ROLF E. KROLL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/10/2009 :1.865 133-H MCS `be /S/? ROL ., ESQ. Attorney r DEFENDANT DEII-1010074 06780-L06 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNETTE SAWYERS AND KERRY SAWYERS File No. _ 08-6922 VS. LAUREN STEPHENSON F/K/A LAUREN BURKHART SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for_ i 1NiV, pHY?I IANS C'RO 1P (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: **** SEE ATTA D RIDER **** at The MC. C?roun Ind 1601 M rk Str ?tSuite 800, Philad? hia, PA 1910 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: _ROLF E KROLL ESO ADDRESS: 3510 TRTNI?LE RO _CAIvIP H1T,T,PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant `DE 10 2009 Date: Seal of the Court 06780-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: UNIV. PHYSICIANS GROUP 1711 NORTH FRONT STREET HARRISBURG, PA 17102 RE: 6780 KERRY SAWYERS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other,providers. INCLUDING BUT NOT LIMITED TO PATIENT, EMERGENCY ROOM RECORDS, SCANS OR OTHER STUDIES, TEST, RADIOLOGY REPORTS, PHYSICAL THERAPY NOTES/REPORTS AND RECORDS OF DR. MILLER. Entire medical and x-ray file, including but not limited to any and all records, correspondence to and from the treating and consulting physicians, filep,, memoranda, handwritten notes, history and.physical reports, x-ray films and reports, medication./prescription records,, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, care or treatment pertaining to: Dates Requested: up to and including the present. Subject KERRY SAWYERS 1507 VERNON STREET, HARRISBURG, PA 17104 Social Security #: XXX-XX-1533 Date of Birth: 07-31-1960 1.865 133-H SU10-0814048 06780-LO6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANNETTE SAWYERS AND KERRY SAWYERS TERM, CUMBERLAND -VS- CASE NO: 08-6922 LAUREN STEPHENSON F/K/A LAUREN BURKHART As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ROLF E. KROLL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS DATE: 12/10/2009 ROLFiE. KROLX, ESQ. Attorney f DEFENDANT i 11.86S 133-H DE11-1010077 06780-LO7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNETTE SAWYERS AND KERRY SAWYERS File No. 08-6922 vs. LAUREN STEPHENSON F/K/A LAUREN BURKHART SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HERSHEY MEDICAL .. CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Group, Inc-, 1601 Market Street. Suite 800, P iladeln ia,PA 19103 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: ROLF E. KROLL, ESQ, ADDRESS: 3510 TRRMU ROAD CAMP HILL, PA 17011 TELEPHONE: (15) 246-0900 SUPREME COURT ID M ATTORNEY FOR: Defendant DIEC 10 2009' Date: Seal of the Court BY THE URT: .2 Prothonotary/Clerk,1 Divisi Deputy 06780-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER MEDICAL RECORDS 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: 6780 KERRY SAWYERS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING BUT NOT LIMITED TO EMERGENCY ROOM RECORDS, PATIENT, TEST RESULTS AND PHYSICAL THERAPY NOTES/REPORTS. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, ,handwritten notes, history and physical repots, medication/ prescription records, nurse's notes, doctor's comments,.dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : KERRY SAWYERS 1507 VERNON STREET, HARRISBURG, PA 17104 Social Security #: 162-48-1533 Date of Birth: 07-31-1960 R1-86S '133-H SU10-0814050 06780-LO7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANNETTE SAWYERS AND KERRY SAWYERS TERM, CUMBERLAND -VS- CASE NO: 08-6922 LAUREN STEPHENSON F/K/A LAUREN BURKHART As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ROLF E. KROLL, ESQ certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/10/2009 1.86S 133-H MCS /S/ ROL. Atb fOf" DEFENDANT DE11-1010080 06780-L08 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNETTE SAWYERS AND KERRY SAWYERS File No. 08-6922 VS. LAUREN STEPHENSON F/K/A LAUREN BURKHART SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group, Inc-, 1601 Market Street. Suite 800, Philadelphia, PA 19103 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: _ROLF E. KROLL. ESO. ADDRESS: 3510 TRINDLE ROAD CAMP EM L, PA 17011 TELEPHONE: -(215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant oEC l 0 2009 Date: , , /OF Seal of the Court BY OURT: P othonotary/Clerk, Civi n Deputy 06780-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER RADIOLOGY DEPT. 500 UNIVERSITY DRIVE HERSHEY. PA 17033 RE: 6780 KERRY SAWYERS Prior approval is required for fees in excess.of $150.00 for hospitals, $100.00 for all other providers. INCLUDING BUT NOT LIMITED TO SCANS OR OTHER STUDIES AND RADIOLOGY REPORTS Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertai4ng to Dates Requested: up to and including the present. Subject KERRY-SAWYERS 1507 VERNON STREET, HARRfSBURG, PA 17104 Social Security #: 162-48-1533 Date of.Birth: 07-31-1960- R1.86S 133-H SU10-0814052 06780-L08 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANNETTE SAWYERS AND KERRY SAWYERS -VS- LAUREN STEPHENSON F/K/A LAUREN BURKHART COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 08-6922 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ROLF E. KROLL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS DATE: 12/10/2009 /S/ / ROL E. I ESQ. M Att r ey or DEFENDANT I 21.865 133-H DE11-1010083 06780-L09 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNETTE SAWYERS AND KERRY SAWYERS File No. 08-6922 VS. LAUREN STEPHENSON F/K/A LAUREN BURKHART SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ARi.INGTON ORTHOP .DI RO IP (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: **** S ATTA D MME **** at The M CS Group, Inc 1601 Market tree , Suite 800, Philadelphia , PA 19103 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: ROLF E KROLL. ESO ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant DEC 101009 Date: Seal of the Court 06780-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ARLINGTON ORTHOPEDIC GROUP 805 SIR THOMAS COURT HARRISBURG, PA 17109 RE: 6780 KERRY SAWYERS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING BUT NOT LIMITED TO PATIENT, EMERGENCY ROOM RECORDS, SCANS OR OTHER STUDIES, TEST RESULTS, RADIOLOGY REPORTS, PHYSICAL THERAPY NOTES & REPORTS AND RECORDS OF DR. BERNARD ZELIGER. Entire medical and.x-ray file, including but not limited to any and all records, correspondence to and from the treating and consulting physicians, fiie.9, memoranda, handwritten notes, history and physical reports, x-ray films and reports, medication/prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to-any examination, consultation, care or treatment pertaining to: Dates Requested; up to and including the present. Subject KERRY SAWYERS 1507 VERNON STREET, HARRISBURG, PA 17104 Social security #: XXX-XX-1533 Date of Birth: 07-31-1960 '1.865 133-H SU10-0814054 06780-LO9 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANNETTE SAWYERS AND KERRY SAWYERS TERM, CUMBERLAND -VS- LAUREN STEPHENSON F/K/A LAUREN BURKHART CASE NO: 08-6922 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ROLF E. KROLL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent DATE: 12/10/2009 L.86S 133-H DE11-1010086 06780-L10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNETTE SAWYERS AND KERRY SAWYERS File No. 08-6922 VS. LAUREN STEPHENSON F/K/A LAUREN BURKHART SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for__ NOVA C RF. F AR/IO R (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:**** SFF. ATTACHED RIDER **** at The MCS C-A w, Inc., 1601 Market Street, Suite 800, Philadelphia, PA 19103 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: ROLF E KROLL ESO ADDRESS: _3510 TR ROAn CAMP HH .L, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: , 5 10 2009 Seal of the Court BY THE URT: r onotary/Clerk, Civil Divisio Deputy 06780-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NOVA CARE REHAB/JOYNER -4800 LINGLESTOWN ROAD STE 102 HARRISBURG, PA 17112 RE: 6780 KERRY SAWYERS Prior approval is required for fees in excess of $150.00 -for hospitals, $100.00 for all other providers. INCLUDING BUT NOT LIMITED TO PATIENT, EMERGENCY ROOM RECORDS, SCANS OR OTHER STUDIES, TEST RESULTS, RADIOLOGY REPORTS AND'PHYSICAL THERAPY NOTES/REPORTS. Entire medical and x-ray file, including but not limited to any and all records, correspondence to and from the treating and consulting physicians, files, memoranda, handwritten notes, history: and physical reports, x-ray films and reports medication/prescription records, including any and all such items as may be stored in a computer database or otherwise.in electronic form, relating to any examination, consultation, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : KERRY SAWYERS 1507 VERNON STREET, HARRISBURG, PA 17104 Social Security #: XXX-XX-1533 Date of Birth: 07-31-1960 ..86S 133-H SU10-0814056 06780-L10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS ANNETTE SAWYERS AND KERRY SAWYERS TERM, CUMBERLAND -VS- CASE NO: 08-6922 LAUREN STEPHENSON F/K/A LAUREN BURKHART As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of ROLF E. KROLL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and . (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the Suhnoena_ DATE: 12/10/2009 MCS for DEFENDANT I :1.865 133-H DE11-1010089 06780-Lll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANNETTE SAWYERS AND KERRY SAWYERS File No. 08-6922 VS. LAUREN STEPHENSON F/K/A LAUREN BURKHART SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for UNEMPLOYMENT COMPENSATION OFF, (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: * * * * SEE ATTACD RIDER * * * * at The M CS Group- Inc., 1601 M rk Street , Suite 800, P ilad l2ia, PA 19103 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: ROLF E. KROLL ESQ ADDRESS: 3510 TRINDLE ROAD CAMP HI L. PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE URT: o notary/Clerk, Civil Division D 10 2009 Deputy Date: Seal of the Court 06780-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: UNEMPLOYMENT COMPENSATION OFF. PA DEPT. OF LABOR OUBC 651 BOAS ST.: RM 501 HARRISBURG, PA 17120 RE: 6780 KERRY SAWYERS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. INCLUDING TIME WORKED, FULL/PART TIME OR INTERMITTENT STATUS, EVALUATIONS OF HER JOB PERFORMANCE AND SCHEDULED AND UNSCHEDULED TIME OFF WORK. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, ndl.uding any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: from: 01-01-2005 to 11-11-2009. Subject : KERRY SAWYERS 1507 VERNON STREET, HARRISBURG, PA 17104 .Social Security #: 162-48-1533 Date of Birth: 07-31-1960 ,1.86S 133-H SU10-0814058 06780-Lll \ZY Re: Filing Certificate Prerequisites for Philadelphia County To Our Valued Customers: Enclose please find a copy of the prerequisite for a Philadelphia County subpoena request that you placed with our office. As a result of the newly implemented order mandating that all legal papers be filled electronically, we are delivering these prerequisites to you to file with the court. At this time we are unable to electronically file prerequisites and as of January 5, 2009, the Philadelphia Court has instituted a paper filing fee of $1 per page. We apologize for the delay in the delivering these documents to you. Over the last month we have been in communication with the Philadelphia Prothonotary's Office to work out an arrangement where we would be able to electronically file on your behalf. However the utilization for electronic filing has still not been made available for third party vendors. If in the future the Philadelphia Court will allow us to electronically file, we will be happy to provide that service to you. S*re, Mon Data Entry Representative 1601 Market Street, suite 800/Philadelphia, Pa 19103-2399/ (215) 246-0900 Fax Number (215) 531-5037/ www.themcsgroup.com r r' ~~1~ ~~~ ~~ P~ ~~ ~!~ ~'E~~~S Yi~.~~'~ C~ I ~? Andrew C. S ars, Esquire I.D.#87737 HANDLER, H NNING & ROSENBERG, LLP 1300 Linglest wn Road Harrisburg, P 17110 Te{ephone: ' (717) 238-2000 Fax : (717) 233-3029 E-mail: spearsCcaHHRLaw.com Attorneys for Plaintiffs ANNETTE , AWYERS and KERRY SAl ERS, her husband, Plaintiffs v. LAUREN B EPHENSON, f/k/a LAUREN BI RKHART, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6922 CIVIL ACTION -LAW PRAECIPE TO THE ARY: :ket in the above captioned matter as Settled, Discontinued and Respectfully submitted, HANDLER, HENNING ~ ROSENBERG, LLP DA7 By: Andrew C. pears, Esquire Supreme Court I.D. # 87737 1300 Linglestown Road .Harrisburg, PA 17110 Spears~hhrlaw.com (71.7) 238-2000 Attorney for Plaintiff r ANNETTE AWYERS and KERRY S WYERS, her husband, ~ Plaintiffs v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6922 CIVIL ACTION -LAW LAUREN S EPHENSON, f/k/a LAUREN URKHART, Defendant Ont Plaintiffs' P' depositing ii .CERTIFICATE OF SERVICE e 19th day of October, 2010, I hereby certify that a true and correct copy of aecipe to Settle, Discontinue and Satisfy was served upon the following by ~ U.S. Mail: Rolf E. Kroll, Esq. Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Very truly yours, HANDLER, HENNING & ROSENBERG, LLP By: Andre C. pears ACSltgd 2