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Home My WebLink About09-2885IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - a 88S Qiv-;t rer* Civil Action- ( ) Law ( ) Equity Teresa Putt 456 Hunters Road devville, PA 17241 • Anthony Watson and Mary Watson versus Plaintiff(s) & Address(es) Defendant(s) & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: f-lease issue writ of summons in the above captioned action. x Writ of Summons shall be issued and forwar g) Attomey ( )Sheriff Stephen J. Hogg, Ssauire `'??! ter,,, 19 S. Hanover Street, Ste. 101 Signature of A e Carlisle, PA 17013 (717) 24S-Y698 Supreme Court ID No. 36812 Names/Address/Telephone No. of Attorney Date: 05/07/09 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED ACTION AGAINST YOU. s Pro onotary n :ate: 5' 07 4009 by Depu ( ) Check here if reverse is issued for additional information PROTHON. -55 RLE)--OFFIGE OF T PROTHONOTARY IM MAY -7 PM 3: 53 CUlv1 r ?;.., GOUN7Y PENNSYLVANIA 4'72.60 PO AM at:* aaa9 Q,Tt aa,y 850 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERESA PUTT, Plaintiff CIVIL ACTION LAW NO.: 09-2885 V. ANTHONY WATSON AND MARY WATSON, JURY TRIAL DEMANDED Defendant . PRAECIPE TO ENTER DEFENDANT'S ADDRESS TO THE PROTHONOTARY: Please enter the following address for the above Defendant's: Anthony Watson and Mary Watson 1923 Boas Street Harrisburg, PA 17103 Thank you for your attention to this matter. LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 ms, quire Stephen J. Hlain Attorney for 19 S. Hanover Street, Ste. 101 Carlisle, PA 17013 (717) 245-2698 FILE OF THE FT-71 2009 AY 21 FN # - 3: r -.:l??, Sheriffs Office of Cumberland County R Thomas Kline ONN"Ir ct '?'umbr"I"A# nawaru i, aunurpp Sheriff Solicitor C" . Ronny R Anderson ' Jody S Smith Chief Deputy OFFICE OF THE SrIZRIFR Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/21/2009 R. Thomas Kline, Sheriff who being duly swom according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Anthony Watson, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Writ of Summons according to law. 05/21/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Mary Watson, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Writ of Summons according to law. 05/28/2009 Dauphin County Return: And now May 28, 2009 at 0929 hours I, Jack Lotwick, Sheriff of Dauphin County; Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Anthony Watson by making known unto himself personally, defendant at Front and Market Streets Harrisburg, PA 17101 its contents and at the same time handing to him personally the said true and correct copy of the same. 05/28/2009 Dauphin County Return: And now May 28, 2009 at 0929 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Mary Watson by making known unto herself personally, defendant at Front and Market Streets Harrisburg, PA 17101 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $53.44 May 29, 2009 2009-2885 Teresa Putt VS Anthony Watson SO ANSWERS, R THOMAS KLIN , SHERIFF ? 7 T 'Vy -: z TERESA PUTT, IN THE COURT OF COMMON Plaintiff :PLEAS CUMBERLAND COUNTY, PENNSYLVANIA, v• NO.: 09-2885 CIVIL ACTION LAW ~~ _~ ANTHONY WATSON and, - _ ~~; MARY WATSON, __ _ ' _ ` Defendants :JURY TRIAL DEMANDED ~:~ ~~, i _ - ~~ NOTICE TO DEFEND ~~' ::::j _ _ You have been sued in Court. If you wish to defend against theme ~~ 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE l 0 i CARLISLE, PA 17013 CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 S. Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 NOTICIA Le han demanado a usted en la corte. Si usted quiere defenderse de estes demandas expuestas en las paginas siguientes, usted tiene viente (20) digs de plazo al partir de la fecha de la demanda y la notilicacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en 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, la corte tomara medidas y puede entrar una Orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, SE ENCUENTRA ESCRI A ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 S. Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 TERESA PUTT, IN THE COURT Plaintiff OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA v. . CIVIL ACTION-LAW NO. 09-2885 ANTHONY WATSON and . MARY WATSON, Defendants :JURY TRIAL DEMANDED COMPLAINT AND NOW comes the Plaintiff Teresa Putt by her Attorney Stephen J. Hogg, Esquire representing the following: 1. Plaintiff is Teresa Putt, is an adult individual currently residing at 2. The Defendants Anthony Watson and Mary Watson, are adult individuals residing at 3. On or about May 10, 2007, prevailing time, the Plaintiff was driving a 2000 Subaru Outback owned by Plaintiff and her husband, Jed Putt and operated by Plaintiff, in a westerly direction on the exit ramp off of interstate 81 at the Plainfield Exit at approximately mile marker 44. LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 4. On the above date and time. the Plaintiff was stopped at the end of the exit ramp at a red traffic signal controlling traffic on Route 465. 5. On the above date and time, the Plaintiff observed the light controlling traffic coming off the Interstate 81 exit ramp to turn green and was preparing to make a right hand turn when she was struck from behind by an unknown make and model vehicle operated by Defendant Anthony Watson. 6. On the above date and time, Defendant Anthony Watson caused the Plaintiff's injuries and damages as follows: a. Operating his vehicle in a negligent, careless and reckless manner; b. Failing to exercise due care while operating a motor vehicle; c. Failing to maintain proper control of his vehicle; d. Failing to insure the rights and safety of others; e. Failing to operate his vehicle within the assured clear distance ahead; f. Operating his vehicle at an unsafe speed under the prevailing conditions; and g. Failing to obey a traffic signal. 7. As a direct and a proximate result of the negligence, LAW OFFICES OF STEPHEN J. HOGG carelessness and recklessness of Defendant Anthony 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 Watson, the Plaintiff suffered serious injuries to her spine, back and neck and other injuries to be enumerated at a later time. 8. As a direct and proximate result of the negligence, carelessness and recklessness of Defendant Anthony Watson, the Plaintiff has suffered and will in the future suffered economic damages, including but not limited to medical expenses and loss of wages in an amount to be proven at trial. 9. As a direct and proximate result of the negligence, carelessness and recklessness of the Defendant the Plaintiff has suffered and will in the future suffer non economic damages including, but not limited to, pain and suffering, mental anguish, permanent impairment and emotional distress. Wherefore, Plaintiff demands judgment against the Defendant in her favor and against Defendant as follows: 1. Past and future economic damages in such amount that will be proven at trial; 2. The sum of past and future non economic damages to be proven at trial; 3. Interest; LAW OFFICES OF STEPHEN J. HOGG 4. Costs; 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 5. Delay damages if applicable; and 6. Such other relief as the Court may deem just and proper. Respectfully Submitted, ~Gi// _.~ Stephen J. Hogg, s ire Attorney for Plaintiff 19 S. Hanover Street, Ste. 101 Carlisle, PA 17013 (717) 245-2698 Attorney I D# 36812 Date: 5~°7~ ~U LAW OFFICES OF STEPHEN J. NOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 VERIFICATION LAW OFFICES OF STEPHEN J. NOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 I verify that the statements made in this Complaint to the Court of Common Pleas of Cumberland County, Pennsylvania, are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904, relating to unsworn falsifications to authorities. Date: .~ 2~~ 2~ ~ o ~~ ~~ TERESA PUTT ,, CERTIFICATE OF SERVICE I, Stephen J. Hogg, Esquire, Attorney for the Plaintiff, hereby rtify that I did on this day serve one true and correct copy of the ached Complaint by United States Mail, postage pre-paid, addressed the following: Christopher M. Reeser, Esquire Marshall Dennehey Warner Coleman & Goggin 4200 Crums Mill Road, Ste. B Harrisburg, PA 17112 LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 Date: S Stephen J. Hogg, Esgsrfr~ Attorney for Plaintiff ~~ 19 S. Hanover Street, Ste. 101 Carlisle, PA 17013 (717) 245-2698 f::; `, - ' 11' '^r rr~ - - E ~ _ : t wt's n~ ' t~l~~~.'L'-~ r~x , . '' ' li 1 LiJ~ ~ i l) ~~~ r °; ~ ~ ,~~~ ,. MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID# 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 717-651-3509 Our File No. 12180-03495 Attorney for Defendants TERESA PUTT Plaintiff vs. ANTHONY WATSON and MARY WATSON Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY; PE I No. 09-2885 CIVIL ACTION -LAW ~~ JURY TRIAL DEMANDED VANIA 1. Denied. Plaintiffs Complaint does not list an address for plaintiff'Ireresa Putt. 2. Denied as stated. Plaintiffs Complaint does not list an address for defendants Anthony Watson and Mary Watson. Byway of further answer, def Watson and Mary Watson are adult individuals who reside at 1923 Boas Street, 17103. 3. Admitted. 4. Admitted. MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID# 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 717-651-3509 Our File No. 12180-03495 Attorney for Defendants TERESA PUTT Plaintiff vs. ANTHONY WATSON and MARY WATSON Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY; PE No. 09-2885 CIVIL ACTION -LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Stephen J. Hogg, Esquire 19 S. Hanover Street, Suite 101 Carlisle, PA 17013 VANIA You are hereby notified to plead to the enclosed Answer with New Mauer within twenty (20) days from service hereof or a default judgment maybe filed against you. Respectfully submitted, By: MARSHALL DENNEHEY WARNER COLEM GGIN '~ Christopher M. Reeser, Esquir Attorney for Defendants ID# 73672 I, 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 717-651-3509 Dated: July 7, 2010 5. Admitted in part and denied in part. It is admitted that plaintiff wad stopped at a red light. It is admitted that her vehicle was struck from behind by a vehicle Anthony Watson. The vehicle operated by defendant Watson was a Hyundai 6. The allegations of Paragraph 6 and subparagraphs 6(a)-6(g) are which no responsive pleading is required. To the extent that the allegations in subparagraphs 6(a}-6(g) are deemed to be factual, those allegations are denied Pa.R.C.P. 1029(e). 7. Denied pursuant to Pa.R.C.P. 1029(e). d by defendant nta Fe. conclusions to aragraph 6 and ursuant to WHEREFORE, Defendants request judgment be entered in their favo~ and demands a jury trial. NEW MATTER 8. Plaintiffs claims or any amendment to those claims maybe barred ~y the applicable statute of limitations. 9. In the event that Plaintiffs were insured under a policy of motor vehicle insurance which provided for the limited tort option, Plaintiffs are barred from recovering non-economic damages as Plaintiffs did not sustain "serious" injuries as defined in § 1702 of the Motor Vehicle Financial Responsibility Law. 10. Upon information and belief, some or all of Plaintiffs medical expenses have been paid or payable by collateral sources and are therefore, not recoverable from § 1722 of the Motor Vehicle Financial Responsibility Law. 11. Upon information and belief, some or all of Plaintiffs claims for loss of earnings capacity have been paid or are payable by collateral sources not recoverable from defendant under § 1722 of the Motor Vehicle Financial 'endant under wages and/or are therefore, ponsibility Law. 2 WHEREFORE, Defendants request judgment be entered in their favor and demands a jury trial. By: Dated: July 7, 2010 MARSHALL DENNEHEY W. COLEMA GGIN Christopher M. Reeser, Esquire Attorney for Defendant ID# 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 717-651-3509 3 VERIFICATION I, Anthony Watson, hereby state and aver that I have read the foregoing document which has been drafted by my counsel. The factual statements contained therein are rue and correct to the best of my knowledge, information and belief although the language is that of my counsel, and, to the extent that the content of the foregoing document is that of counsel, I have relied upon counsel in making this Verification. This statement is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Dated: 12180-03495/AWNM 4 MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN By: Christopher M. Reeser, Esquire ID# 73632 4200 Crums Mill Road, Suite B Hamsburg, PA 17112 717-651-3509 Our File No. 12180-03495 Attorney for Defendants TERESA PUTT COURT OF COMMON PLEAS CUMBERLAND COUNTY; PEP Plaintiff No. 09-2885 vs. : ANTHONY WATSON and CIVIL ACTION -LAW MARY WATSON : JURY TRIAL DEMANDED Defendants CERTIFICATE OF SERVICE I, Christopher M. Reeser, Esquire, of Marshall, Dennehey, Warner, Co do hereby certify that on July 7, 2010, I served a copy of Defendants' Answer plaintiffs Complaint via First Class United States mail, postage prepaid as Stephen J. Hogg, Esquire 19 S. Hanover Street, Suite 101 Carlisle, PA 17013 Attorney for Plaintiff ~~- ~,nnstopner ivi. xeeser VANIA & Goggin, New Matter to TERESA PUTT, Plaintiff v. ANTHONY WATSON and, MARY WATSON, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA, NO.: 09-2885 CIVIL ACTION LAW JURY TRIAL DEMANDED PLAINTIFF'S ANSWER TO NEW MATTER `Y, r ;,. .i M .~~' 4 ~ -,; .~ ~ ~~~ s ~ c~ Q ++ ~_~ ~ Plaintiff asserts that all allegations previously raised in the Complaint and responds to the new matter as follows: 8. This is a legal conclusion and no response is required. 9. This is a legal conclusion and no response is .required. To the extent that Defendant denies Plaintiff sustained serious injuries, Plaintiff asserts that her injuries were, in fact, serious. 10. It is agreed that if Plaintiffs medical expenses have been paid by other sources, they may not be recoverable from Defendant. 11. It is agreed that if any of Plaintiffs lost wages have been paid by collateral sources, they may not be recoverable from Defendant. Wherefore, Plaintiff again requests judgment in her favor and against Defendants. Su LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 Date: ~ G Stephen J. l~a~g, Esquire Attorney for aintiff 19 S. Hanover Street, Ste. 101 Carlisle, PA 17013 (717) 245-2698 VERIFICATION I verify that the statements made in this Complaint to the Court of Common Pleas of Cumberland County, Pennsylvania, are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904, relating to unsworn falsifications to authorities. Date: $ ~ ~~ ~"~ ~- ~~.~l~A ~ d TERESA PUTT LAW OFFICES OF STEPHEN J. NOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 CERTIFICATE OF SERVICE I, Stephen J. Hogg, Esquire, Attorney for the Plaintiff, hereby certify that I did on this day serve one true and correct copy of the attached Plaintiffs Answer to New Matter by United States Mail, postage pre-paid, addressed to the following: Christopher M. Reeser, Esquire Marshall Dennehey Warner Coleman 8~ Goggin 4200 Crums Mill Road, Ste. B Harrisburg, PA 17112 LAW OFFICES OF STEPHEN J. HOGG 19 S. HANOVER STREET SUITE 101 CARLISLE, PA 17013 Date: ~ ~ ~ ((/ Stephen J. Hoge, quire Attorney for Plainti 19 S. Hanover Street, Ste. 101 Carlisle, PA 17013 (717) 245-2698 y ' CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA NA L PURSUANT TO RULE 4009.22 IN THE MATTED. OF: TERESA F ANTHONT -VS- & MARY WATSON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 09-2885 requisite to service of a subpoena for documents and things u uaf? z" R81 , -: 4009.22 ? ? ::3 4"J MCS on behalf of CHRISTOPHER REESER, ESQ. C"') C W car certifies that > i 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, As a pr( to Rule (1 (2 A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3I) No objection to the subpoena has been received, and The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 03/16/2011 MCS on behalf of /S/ aridopl r eerier, 64. CHRISTOPHER REESER, ESQ. Attorney for DEFENDANT MCS # 49374-L05 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATT R OF: TERESA PUTT -VS- & MARY WATSON COURT OF COMMON PLEAS TERM, CASE NO: 09-2885 THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR BILLING ONLY CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY CARLISLE REGIONAL MEDICAL CTR. PATHOLOGY COMMIS ONER OF STATE POLICE INCIDENT RECORDS TO: STEPHEN HOGG, ESQ., PLAINTIFF COUNSEL MCS on behalf of CHRISTOPHER REESER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days f om 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: 02/22/2011 CC: CHRISTOPHER REESER, ESQ. STEPHEN HOGG, ESQ. L/O OF TEPHEN HOGG 19 S. OVER STREET STE. 10 CARLISL , PA 17013 - 12180-03495 MCS on behalf of CHRISTOPHER REESER, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 MCS # 49374-CO1 nrnl) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PUTT vs. & MARY WATSON File No. _ 09-2885 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: of Records for CARLISLE REGIONAL MEDICAL CNTR (Name of Person or Entity) Within twent?f (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 IVICS Gronn_ inc__ 1601 Market Street Snite Roo Philadelnhia PA 191 Al You may del er or mail legible copies of the documents or produce things requested by this subpoena, together with the certi lcate of compliance, to the party making this request at the address listed above. You have the right to seek, in ad ance, the reasonable cost of preparing the copies or producing the things sought. If you fail to roduce the documents or things required by this subpoena within twenty (20) days after its service, the party serv ng this subpoena may seek a court order compelling you to comply with it. THIS SUBP ENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER REESER, ESQ. ADDRESS: 4200 CR 1M MILL ROAD SUITE B HARRISBURG, PA 17112 TELEPHON : !2 1 51 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: 1*vTD_0 T&??LL Prothonotary/Clerk, Civil Division Deputy Date: eq ' I Seal of the Court 49374-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISL REGIONAL MEDICAL CNTR MEDICAL RECORDS 361 ALE ANDER SPRING CARLISLE, PA 17015 RE: MC # 49374-L05 TE SA PUTT 1 UNWOODY DRIVE CARLISLE, PA 17015 Social ecurity #: XXX-XX-6079 Date of Birth: 04-07-1962 Please rovide the entire hospital medical file, including but not limited to all records, intake or admission forms, correspondence to and from th consulting and treating physicians, and discharge forms. Include all files, emoranda, handwritten notes, history and physical reports. Supply all medication and prescription records, nurses' notes, doctor's comments, dietary and all patient consent or refusal of treatment. This should contain all records in your possession, including all archived records, records in storage. Includi g any and all items as may be stored in a computer database or otherwi e in electronic form. INCLUDING IN/OUT PATIENT RECS, PHYSICAL THERAPY & REHB RECS Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 49374-L05 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 I IN THE MATT R OF: COURT OF COMMON PLEAS TERESA PUTT TERM, CUMBERLAND -VS- CASE NO: 09-2885 ANTHON & MARY WATSON As a p erequisite to service of a subpoena for documents and things pursuant to Rul 4009.22 MCS on behalf of CHRISTOPHER REESER, ES certifies that (4 ( ) 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, {?) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (1) No objection to the subpoena has been received, and The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 03/16/2011 MCS on behalf of /S/ (? ,?ridop4er eerier. eia. CHRISTOPHER REESER, ESQ. Attorney for DEFENDANT MCS # 49374-LO6 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PUTT vs. & MARY WATSON File No. 09-2885 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Within twe documents at Tian of Records for CARLISLE REGIONAL MEDICAL CTR (Name of Person or Entity) (20) days after service of this subpoena, you are ordered by the court to produce the following kings: **** SEE ATTACHED RIDER **** You may delver 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 ad ance, 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 servng 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: CHRISTOPHER REESER. ESO. ADDRESS: 4200 CRUMS MILL ROAD SUITE B HARRISBURG. PA 17112 TELEPHON (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: -19V b -b3U£LL Prothonotary/Clerk, Civil Division a f ! Deputy Date: ' (I t Seal of the Court 49374-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISL REGIONAL MEDICAL CTR 361 ALE ANDER SPRING ROAD BILLING DEPARTMENT CARLISLE. PA 17015 RE : MC: TEI 11 CAI Social Date of > # 49374-L06 ZESA PUTT )UNWOODY DRIVE tLISLE, PA 17015 >ecurity #: XXX-XX-6079 Birth: 04-07-1962 Please provide any and all billing, insurance claims, and payments, outstanding and del nquent invoices. This should contain all records in your possess on, all archived records, or records in storage. Including any and all items a may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 49374-L06 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS TERESA PUTT TERM, CUMBERLAND -VS- CASE NO: 09-2885 ANTHON & MARY WATSON As a p erequisite to service of a subpoena for documents and things pursuant to Rul 4009.22 MCS on behalf of CHRISTOPHER REESER, ESQ. certifies that ( ) 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, (1) No objection to the subpoena has been received, and (?) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 16/2011 MCS on behalf of 4? /S/ (??//fhribtopher Keeler. 6a. CHRISTOPHER REESER, ESQ. Attorney for DEFENDANT MCS # 49374-LO7 DE11 1 A COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PUTT vs. & MARY WATSON File No. 09-2885 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: of Records for CARLISLE REGIONAL MEDICAL CTR. (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 Ithings: **** SEE ATTACHED RIDER **** at You may deli er 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 roduce the documents or things required by this subpoena within twenty (20) days after its service, the party serv ng this subpoena may seek a court order compelling you to comply with it. THIS SUBP ENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER REESER, ESQ. ADDRESS: 4200 CRUMS MILL ROAD SUITE B HARRISBURG- PA 17112 TELEPHON : (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: lam. iP1VT'D -1> ? Us LL Prothonotary/Clerk, Civil Division Deputy Date: Seal of the Court 49374-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISL REGIONAL MEDICAL CTR. 361 ALE ANDER SPRING RD RADIOLO Y DEPT CARLISL4, PA 17013 RE: 1 Social Date of # 49374-L07 ;ESA PUTT iUNWOODY DRIVE ;LISLE, PA 17015 ,ecurity #: XXX-XX-6079 Birth: 04-07-1962 Please rovide any and all x-ray films and reports. This should contain all x-ray films and reports in your possession, all archived x-ray films a rd reports, or x-ray films and reports in storage. Including any and all suc items as may be stored in a computer database or otherwise in electronic form. INCLUDING MRI'S & CT SCANS FILM INVENTORY Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 49374-L07 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTEIR OF: COURT OF COMMON PLEAS TERESA -vs- TERM, CUMBERLAND & MARY WATSON CASE NO: 09-2885 As a p erequisite to service of a subpoena for documents and things pursuant to Rul 4009.22 MCS on behalf of CHRISTOPHER REESER, ESQ. certifies that ( ) 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, (?) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (1) No objection to the subpoena has been received, and (4J) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 16/2011 MCS on behalf o /S/ arijtop4r eejer. 6a. CHRISTOPHER REESER, ESQ. Attorney for DEFENDANT MCS # 49374-L08 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PUTT vs. & MARY WATSON File No. 09-2885 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: of Records for CARLISLE REGIONAL MEDICAL CTR. (Name of Person or Entity) Within twent?(20) days after service of this subpoena, you are ordered by the court to produce the following documents or hings: * * * * SEE ATTACHED RIDER * * * * at You may deli er 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 ad ance, the reasonable cost of preparing the copies or producing the things sought. If you fail to the party ser THIS SUB NAME: ADDRESS: SUPREME C ATTORNEY iuce the documents or things required by this subpoena within twenty (20) days after its service, this subpoena may seek a court order compelling you to comply with it. A WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: CHRISTOPHER REESER, ESO. 4200 CRUMS MILL ROAD SUITE B HARRISBURG. PA 17112 15) 246-0900 ,URT ID #: Defendant BY THE COURT: Date: 'b 14USD -b RI) -5 LL Prothonotary/Clerk, Civil Division FE . Deputy - (t L- Seal of the Court 49374-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE REGIONAL MEDICAL CTR. 361 ALE NDER SPRING RD PATHOL Y DEPT CARLISLE, PA 17013 RE: 1 Social Date of # 49374-L08 ESA PUTT UNWOODY DRIVE LISLE, PA 17015 ecurity #: XXX-XX-6079 Birth: 04-07-1962 Please provide any and all pathology reports and records. This should contain all pathology records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consult tion, diagnosis care or treatment. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 49374-L08 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTEI Z OF: TERESA -VS- & MARY WATSON COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 09-2885 As a p erequisite to service of a subpoena for documents and things pursuant to Rul 4009.22 MCS on behalf of CHRISTOPHER REESER, ESQ. certifies that (] DATE: 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, (31) 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. 16/2011 MCS on behalf o /S/ aridopher ee-Jer, eia CHRISTOPHER REESER, ESQ. Attorney for DEFENDANT MCS # 49374-L09 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PUTT vs. & MARY WATSON File No. 09-2885 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custo ian of Records for COMMISIONER OF STATE POLICE (Name of Person or Entity) Within twent} (20) days after service of this subpoena, you are ordered by the court to produce the following documents or Ithings: **** SEE ATTACHED RIDER **** at You may deli er 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 ad ance, the reasonable cost of preparing the copies or producing the things sought. If you fail to ?roduce the documents or things required by this subpoena within twenty (20) days after its service, the party servng this subpoena may seek a court order compelling you to comply with it. THIS SUBP ENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: CHRISTOPHER REESER. ESO. ADDRESS: 4200 CRUMS MILL ROAD SUITE B HARRISBURG. PA 17112 TELEPHON : (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: JAN'C j -b ` U £ L L Prothonotary/Clerk, Civil Division Date: Deputy Seal of the Court 49374-09 . I EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMISI NER OF STATE POLICE 1800 EL MERTON AVE. HARRISB RG, PA 171129748 RE: MC # 49374-L09 TE ESA PUTT 1 NWOODY DRIVE C LISLE, PA 17015 Social ecurity #: XXX-XX-6079 Date of Birth: 04-07-1962 INCIDENT NO. H02-1696769, DATE AND TIME OF CRASH 09/08/2007 AT 9:39 Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 49374-L09 SU10 TERESA PUTT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 09-2885 CIVIL+ 3 ? ANTHONY WATSON and zrn MARY WATSON, cn?" Defendants CZ) N < A c-a -o s ORDER N AND NOW this /2 ~ day of July, 2012, the appointment of Carolyn McClatil, o Esquire, as a member of the Board of Arbitrators in the above-captioned case is VACATED. Elizabeth D. Snover, Esquire, is appointed in her place. BY THE COURT, 14 Kevin A/Hess, P. J. i/ Robert Bleecher, Esquire Chairman Court Administrator :rlm spy, /'d 7/ice/jam 0 m t? ,yz- & TERESA PUTT In the Court of Common Pleas of Cumb~ Plaintiff ANTHQNY WATSON and MARY WATSON County, Pennsylvania No. ~- 2885 Defendants Civil Action -Law. Oaih We do so y swear (or affirm) that we will support, obey and defend the Constitution of the Un and stitution of this Commonwealth andnthat we will discharge the duties of our office with ..vim,/ (~_. ` Si ignature Signa Rob Bleecher Name (Chairman) Pecht & Associates, PC Law Firm 1205 Manor Drive Suite 200 Address Linda A. Clotfelter Eliza Name Name Law Firm Law Firm 5021 E. Trindle Road Suite 100 301 Mai Address Address Mechanicsburg, PA 17055 Mechanicsburg, PA 17050 Lemoyne, PA 170 City, Zip City, Zip City, Zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the fc award: (Note: If damages for delay are awarded, they shall. be separately stated.) ~ P+~D ~ JZ.-~ c ACC- r~ a ft iv~t' Date of Hearing: ~ /j ~ Date of Award: ~~/j ~ ~.,.,~ L.~~n~(w ~. Cla~~~l ~'tr States Notice of Entry of Award Now, the ~ 7`~ day of ~_, 2012, at / ~ -~a lr /~ .M., the above award entered upon the docket and noticJ~f given b mail to the arties or their attorne s. Y P Y Arbitrators' compensation to be paid upon appeal: $ ~1~ . S~ l~a.t,~d D . Qc~e~~ Prothonotary ~: '~~~ ~~ ~~~ ~ T Y ~p%~ ,mod.. `t~•l ~~a ~/.~a ,, 4