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HomeMy WebLinkAbout00-05036IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA KEVIN J. GUTSHALL 932 W. Trindle Road Mechanicsburg, PA 17055 Plaintiff(s) & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above-captioned action. Defendant(s) & Address(es) X Writ of Summons Shall be issued and forwarded to ( )Attorney (XX)Sheriff W. Scott Henning, Esquire 319 Market Street P.O. Box 1177 Harrisburg, PA 17108 (717) 238-2000 Name/Address/Telephone No. of Attorney Signature of Att Supreme Cour ID Data. 7/12/ WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. // r thonotary Date: ?Lc Cv /?f aOGO Eby ? ? DJputy No. OCS - k, l.lVr 4/LC'1. Civil Action - (XX) Law ( ) Equity JURY TRIAL DEMANDED RAENN BANKS 2024 State Road Camp Hill, PA 17011 ( ) Check here if reverse is used for additional information 1ROTHON.-55 - X) rr? V nQ?c I I 0 c: CJ (1J LL; y? . -f d, C7,. ZT -t ot-) SHERIFF'S RETURN - REGULAR CASE NO: 2000-05036 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GUTSHALL KEVIN J VS BANKS RAENN HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon BANKS the DEFENDANT at 0017:25 HOURS, on the 19th day of July 2000 at 2024 STATE ROAD CAMP HILL, PA 17011 by handing to RAENN BANKS a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.30 Affidavit .00 Surcharge 10.00 .00 37.30 Sworn and Subscribed to before me this day of o`lpyrv A.D. P othonotary So Answers: r R. Thomas Kline 07/20/2000 HANDLER, HENNING & By: Deputy Sheriff OOHB-00086 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 KEVIN J. GuTSHALL, PLAINTIFF VS. RAENN BANKS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-5036 CIVIL ACTION - LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above captioned matter on behalf of the Defendant, Raenn Banks. Date: August 16. 2000 Respectfully submitted, LAW OFFICES OF JACOBS & SABA By: 6131ff B. Ric s, Esquire Attorney for Defendant Identification No.58867 r i OOM-WO96 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attornevs for Defendant. Raenn Banks KEVIN J. GuTSHALL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. RAENN BANKS, DEFENDANT No. 00-5036 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of Entry of ANearance to be served by regular first class mail upon: W. Scott Henning, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Dated: August 16. 2000 u-? v v?- Giral E. Rickards, Esquire Attorney for Defendant OOHB-00086 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Raenn Banks KEv1N J. GUTsHALL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. RAENN BANKS, DEFENDANT No. 00-5036 CIvH. ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please enter a RULE upon Plaintiff to file a Complaint within twenty (20) days hereof or suffer the entry of a Judgment of Non Pros. Date: August 16. 2000 Girard E. Rickards Esquire Attorney for Defendant RULE TO FILE COMPLAINT AND NOW, this JILI-day of OuatL- , 2000 a RULE is hereby entered upon the Plaintiff to file a Complaint h rein within twenty (20) days after service hereof or suffer the entry of a Judgment of Non Pros. A/ da2iZL2 PROTHONOTARY i OOHB-00086 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Raenn Banks KEVIN J. GUTSHALL, PLAINTIFF VS. RAENN BANKS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-5036 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of Praecipe - Rule to File Complaint to be served by regular first class mail upon: W. Scott Henning, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Dated: August 16, 2000 Girard E. Rickards, Esquire Attorney for Defendant KEVIN J. GUTSHALL, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 00-5036 V. RAENN BANKS, CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone 717-249-3166 or 800-990-9108 HANDLER.-KENNING & ROSENBERG By W. S tt He mg, Esq. 1. D. 98 1300 Linglestow oad Harrisburg, P 17110 (717) 238- 00 Attorney fo Plaintiff I mgh/complaints/mva/gutshall KEVIN J. GUTSHALL, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 00-5036 V. RAENN BANKS, CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED COMPLAINT AND NOW, comes Plaintiff, Kevin J. Gutshall, by and through his attorneys HANDLER, HENNING & ROSENBERG, by W. Scott Henning, Esquire, and brings the within Complaint against the Defendant, Raenn Banks, and avers as follows: 1. Plaintiff, Kevin Gutshall, is an adult individual who currently resides at 932 West Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant, Raenn Banks, is an adult individual who currently resides at 2024 State Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. At all times material hereto, Plaintiff, Kevin J. Gutshall, was the owner and operator of a 1985 Mercury, bearing Pennsylvania Registration Number BLW- 9448. 4. At all times material hereto, Defendant, Raenn Banks, was the owner and operator of a 1978 Dodge, bearing Pennsylvania Registration Number BPZ-0860. 5. On or about August 17, 1998, at approximately 12:48 p.m., Plaintiff, Kevin J. Gutshall, was stopped at a red traffic signal, facing in the eastbound direction, at the intersection of York and Simpson Streets in Mechanicsburg, Cumberland County, Pennsylvania. 6. On or about August 17, 1998, at approximately 12:48 p.m., Defendant, Reann Banks, was traveling east on West Simpson Street in Mechanicsburg, Cumberland County, Pennsylvania, when suddenly and without warning, she failed to stop and violently collided into the rear of Plaintiff's vehicle. 7. Prior to the aforementioned collision, Plaintiff's parents, Jay and Janet Gutshall, had purchased a policy of motor vehicle insurance from Shelby Casualty Insurance Company in which Plaintiff was a named insured. Said policy was in full force and effect on August 17, 1998, the date of the incident. Pursuant to said policy, Plaintiff enjoyed the benefits of full-tort coverage. 8. The occurrence of the aforementioned collision and the resultant injuries to Plaintiff, Kevin J. Gutshall, were the direct and proximate result of the negligence of Defendant, Raenn Banks, generally and more specifically as set forth below: (a) In failing to operate her vehicle under proper and adequate control so that she could have avoided striking the rear of Plaintiff's vehicle; 2 (b) In failing to keep alert and maintain a proper lookout for the presence of other vehicles lawfully on the roadway; (c) In failing to operate her vehicle in such a manner so that she could apply her brakes so as to avoid a collision with the rear of Plaintiff's vehicle; (d) In failing to properly and adequately observe the traffic and road conditions then and there existing; (e) In failing to be reasonably vigilant to observe that Plaintiff's vehicle was stopped in front of her; (f) In speeding and/or driving too fast for existing road conditions; (g) In failing to operate said vehicle at a speed, and under such control, so as to be able to stop within the assured clear distance ahead, in violation of 75 Pa.C.S.A. § 3361; and, (h) In operating said vehicle in a careless manner, in violation of 75 Pa.C.S.A. § 3714. 9. As a direct and proximate result of the negligence of the Defendant, Raenn Banks, the Plaintiff, Kevin J. Gutshall, sustained serious injuries including, but not limited to, left knee and foot pain, neck pain, muscular and ligamentous injuries, lumbar sprain/strain and left spondyloloysis. 10. As a direct and proximate result of the negligence of the Defendant, Raenn Banks, the Plaintiff, Kevin J. Gutshall, sustained serious personal injuries 3 requiring emergency medical treatment and continuing medical treatment and physical therapy. 11. As a direct and proximate result of the negligence of the Defendant, Raenn Banks, the Plaintiff, Kevin J. Gutshall, has been, and may in the future be, hindered from attending to his usual daily activities and duties, to his great detriment, loss, humiliation and embarrassment. 12. As a direct and proximate result of the negligence of the Defendant, Raenn Banks, the Plaintiff, Kevin J. Gutshall, has suffered great physical pain, discomfort, humiliation and mental anguish, and will continue to endure the same for an indefinite period of time in the future, to his physical, emotional and financial detriment and loss. 13. As a direct and proximate result of the negligence of the Defendant, Raenn Banks, the Plaintiff, Kevin J. Gutshall, has been compelled, in order to effect a cure for the aforesaid injuries, to expend money for medical attention. Plaintiff continues to take medications and incur medical expenses for said injuries, and may continue to do so in the future, to his great detriment and loss. 14. As a direct and proximate result of the negligence of the Defendant, Raenn Banks, the Plaintiff, Kevin J. Gutshall, has suffered a loss of life's pleasure and he will continue to suffer the same in the future, to his great detriment and loss. 15. As a direct and proximate result of the negligence of the Defendant, Raenn Banks, the Plaintiff, Kevin J. Gutshall, sustained a loss of wages, and may continue to suffer the same in the future to his great detriment and loss. 4 16. Plaintiff, Kevin J. Gutshall, believes, and therefore avers, that his injuries are permanent in nature. WHEREFORE, Plaintiff, Kevin J. Gutshall, seeks damages from the Defendant, Raenn Banks, in an amount in excess of Twenty-Five Thousand ($25,000.00) Respectfully submitted, Date: 9-/5- '')O? W. 1300,Jdli glesto Ro< Harrisburg, P 17110 (717) 238-2 00 Attorney for Plaintiff 5 VERIFICATION I, KEVIN GUTSHALL, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. KEVIN J. GUTSHALL Date: ?) KEVIN J. GUTSHALL, Plaintiff V. RAENN BANKS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-5036 CIVIL : CIVIL ACTION -LAW : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE On this day of 2000, 1 hereby certify that a true and correct copy of Plaintiff's Complaint with Notice to Defend was served upon the following by depositing same in the United States Mail in Harrisburg, Pennsylvania: Girard E. Rickards, Esquire 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 HANDLER, HENNING & Date: 9 ?s -aOaa By W. Scott He ping, squ Attorney I.D. 98 1300 Linglestown ad Harrisburg, PA 17 10 (717) 238-2000 BERG ATTORNEY FOR PLAINTIFF OOHS-00086 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number. (717) 731-0988 Attorneys for Defendant, Raenn Banks KEVIN J. GUTSHALL, PLAINTIFF VS. RAENN BANKS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-5036 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Answer with New Matter of Defendant Raenn Banks to Plaintiff's 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 Answer with New Matter of Defendant Raenn Banks to Plaintiff's Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 I f OOBB-00086 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Raenn Banks KEVIN J. GUTSHALL, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. RAENN BANKS, DEFENDANT No. 00-5036 CIvIL ACTION - LAW JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANT RAENN BANKS TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Raenn Banks, by and through her attorney, Girard E. Rickards, Esquire, in support of Answer with New Matter of Defendant Raenn Banks to Plaintiff's Complaint hereby avers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted in part, denied in part. It is admitted that on or about August 17, 1998, at approximately 12:48 p.m., Defendant Raenn Banks was traveling east on West Simpson Street in Mechanicsburg, Cumberland County, Pennsylvania, when she was unable to stop and her vehicle impacted the rear of the Plaintiff s vehicle. The remaining averments of paragraph 6 are specifically denied and strict proof thereof is demanded at the time of trial. 7. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 7. Therefore, each and every averment of paragraph 7 is specifically denied and strict proof thereof is demanded at the time of trial. 8. The averments in paragraph 8 constitute a conclusion of law to which no response is required. To the extent that a response is deemed required, each and every averment of paragraph 8 is specifically denied and strict proof thereof is demanded at the time of trial. 9. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 9. Therefore, each and every averment of paragraph 9 is specifically denied and strict proof thereof is demanded at the time of trial. 10. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 10. Therefore, each and every averment of paragraph 10 is specifically denied and strict proof thereof is demanded at the time of trial. 11. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 11. Therefore, each and every averment of paragraph 11 is specifically denied and strict proof thereof is demanded at the time of trial. 12. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 12. Therefore, each and every averment of paragraph 12 is specifically denied and strict proof thereof is demanded at the time of trial. 13. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 13. Therefore, each and every averment of paragraph 13 is specifically denied and strict proof thereof is demanded at the time of trial. 14. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 14. Therefore, each and every averment of paragraph 14 is specifically denied and strict proof thereof is demanded at the time of trial. 15. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 15. Therefore, each and every averment of paragraph 15 is specifically denied and strict proof thereof is demanded at the time of trial. 16. After reasonable investigation, the Defendant is without sufficient knowledge to form a belief as to the truth of the averments of paragraph 16. Therefore, each and every averment of paragraph 16 is specifically denied and strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant Raenn Banks respectfully requests your Honorable Court to dismiss the Plaintiff's Complaint with prejudice. NEW MATTER 17. The Plaintiff's claims for medical expenses and wage loss are barred, or should be reduced in accordance with § 1722 of the Pennsylvania Motor Vehicle Financial Responsibility Act. 18. The Plaintiffs claims for non-pecuniary damages may be barred bythe limited tort option of the Pennsylvania Motor Vehicle Financial Responsibility Act. 19. The Plaintiff has been paid the sum of $233.10 on behalf of Defendant Raenn Banks for claims made in this lawsuit and set off in that amount is hereby claimed. WHEREFORE, Defendant Raenn Banks respectfully requests your Honorable Court to enter judgment in her favor and demands a set off in the amount of $233.10. Respectfully submitted, Date: November 20. 2000 By: Girard E. Rickards, Esquire Attorney for Defendant Identification No. 58867 LAW O CES OF 7 OBS & SABA 0003-00086 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 KEVIN J. GUTSHALL, PLAINTIFF VS. RAENN BANKS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5036 CIVIL ACTION - LAW JURY TRIAL DEMANDED VERIFICATION I, Raenn Banks, verify that the statements made in the foregoing Answer with New Matter of Defendant Raenn Banks to Plaintiff's Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of Pa.C.S.A. §4904, relating to unworn falsification to authorities. Dated: 7?? e ?= Raenn Banks, Defendant OOHB-00086 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 for Banks KEVIN J. GUTSHALL, PLAINTIFF VS. R.AENN BANKS, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 00-5036 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of Answer with New Matter of Defendant Raenn Banks to Plaintiff's Complaint to be served by regular first class mail upon: W. Scott Henning, Esquire Handler, Henning & Rosenberg 1300 Linglestown Road Harrisburg, PA 17110 Dated: November 20. 2000 2 card E. Rickards, Esquire Attorney for Defendant Y KEVIN J. GUTSHALL, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 00-5036 V. : CIVIL ACTION -LAW RAENN BANKS, Defendant : JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO NEW MATTER AND NOW, comes Plaintiff, Kevin J. Gutshall, by and through his attorneys, HANDLER, HENNING & ROSENBERG, by W. Scott Henning, who answers Defendant's New Matter as follows: 17. DENIED. The allegation set forth in Paragraph 17 is a conclusion of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, the Plaintiff acknowledges that his claim shall be reduced or limited by the Pennsylvania Motor Vehicle Financial Responsibility Act as may be properly determined by the Court. 18. DENIED. The allegation set forth in Paragraph 18 is a conclusion of law to which no responsive pleading is required, however, to the extent that the Honorable Court deems a response necessary, the Plaintiff elected the full tort option, and hence, the limited tort limitation on non-pecuniary damages is not applicable; and proof to the contrary is demanded at the trial in this matter. 19. ADMITTED. WHEREFORE, Plaintiff demands judgment against the Defendants for the relief set forth in his Complaint. HANDLER, HENNING & ROSENBERG { W. Sco m g, E uire Date: Suprem ID #A2298 P.O. Bo7 Harrisburg, PA 1 108 (717) 238-200 Attorneys for Plaintiff 1 VERIFICATION PURSUANT TO PA R.C.P. NO. 1024 (c) W. SCOTT HENNING, ESQUIRE, states that he is the attorney for the party filing the foregoing document; that he makes this affidavit as an attorney, because the party he represents lacks sufficient knowledge or information upon which to make a verification and/or because he has greater personal knowledge of the information and belief than that of the party for whom he makes this affidavit; and that he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa C.S. §4904 relating to unsworn falsification to authorities. Date: /':2,-C2 y KEVIN J. GUTSHALL, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 00-5036 V. RAENN BANKS, CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE On the day of ?, 2000, 1 hereby certify that a true and correct copy of Plaintiff's Answer to New Matter was served upon the following persons(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States mail, first-class postage prepaid as follows: Girard E. Rickards, Esquire JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 HANDLER, HENNING & ROSENBERG By: Date: /a-y'WO6 W. Scott H niM , Supreme/Coju,ErIAL) # P.O. Bo 77 Harrisburg, PA 171:11( (717) 238-200 Attorneys for Plaintiff oa ?C7 G , L? tV ?n n-l _;]Ll rl ID rn 7s CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN J. GUTSHALL - AUTO/BODILY INJURY TERM, -VS- CASE NO: 00-5036 REANN BANKS - BANKS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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. 4IRARD on b of DATE: 12/19/2000 E. RICKARDS. ESQUIRE Attorney for DEFENDANT DE11-225197 3 7 8 1 1- 1,0 4 C OMAQONWEAL TH OP PENNSYLVANIA COUNTY OH CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN J. GUTSHALL - AUTO/BODILY INJURY TERM, -VS- CASE NO: 00-5036 REANN BANKS - BANKS EVERETT C. HILLS, M.D. MEDICAL SHELBY INSURANCE CO. INSURANCE HB MCCLURE COMPANY, INC. EMPLOYMENT TO: W. SCOTT HENNING, ESQUIRE MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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 campleting the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/29/2000 CC: GIRARD E. RICKARDS, ESQUIRE - OOHB-00086 TOM $AEdE; - 5837DO05969 Any questions regarding this matter, contact MCS on behalf of GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET /800 PHILADELPHIA, PA 19103 - (215) 246-0900 DE02-138627 3783-3--C;02- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEVIN J. GUTSHALL -AUTO/BODILY INJURY VS File No. 00-5036 CIVIL REANN BANKS -BANKS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR:EVERETT C. HILLS, M.D. (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 at MCS GROUP INC.,1601 MARKET ST., #800, PHILA.,PA 1 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: GIRARD E. RICKARDS, ESQ. ADDRESS: 214 SENATE AVE.. SUITE 503 CAMP HILL, PA-17011 TELEPHONE: 215-246-0900 SUPREME COURT ID fh ATTORNEY FOR: DEFENDANT DATE: /?)O o a,? a eo n Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: EVERETT C. HILLS, M.D. 450 POWERS AVENUE HARRISBURG, PA 17109 RE: 37811 KEVIN J. GUTSHALL INCLUDE ANY AND ALL NOTES. Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : KEVIN J. GUTSHALL 932 WEST TRINDLE ROAD, MECHANICSBURG, PA 17055 Social Security 11: 210-58-9488 Date of Birth: 07-06-1978 SU10-279006 3 7 8 1 1- 1.0 4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: KEVIN J. GUTSHALL - AUTO/BODILY INJURY -V5- REANN BANKS - BANKS COURT OF COMMON PLEAS TERM, CASE NO: 00-5036 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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 on behalf of DATE: 12/19/2000 GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT DE11-225198 3781-1--1-05 V COMMONWEAL T H OF PENN S YLVAN 2A COUNTY 03F CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN J. GUTSHALL - AUTO/BODILY INJURY TERM, -VS- CASE NO: 00-5036 REANN BANKS - BANKS EVERETT C. HILLS, M.D. MEDICAL SHELBY INSURANCE CO. INSURANCE HB MCCLURE COMPANY, INC. EMPLOYMENT TO: W. SCOTT HENNING, ESQUIRE MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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: 11/2912000 CC: GIRABD B. RICKARDS, ESQUIRE - OOKE-00086 TOM BAKEW° - 5837D005969 Any questions regarding this matter, contact MCS on behalf of GIRARD B. RICKARDS, ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-138627 37S3---l---C:02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEVIN J. GUTSHALL -AUTO/BODILY INJURY VS REANN BANKS -BANKS File No. 00-5036 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: SHELBY INSURANCE COMPANY (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 at MCS GROUP INC.,1601 MARKET ST., 11800, PHILA.,PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: GIRARD E. RICKARDS, ESQ. ADDRESS: 214 SENATE AVE. SUITE 503 CAMP HILL, PA 17011 TELEPHONE: 215-246-0900 SUPREME COURT ID t1: ATTORNEY FOR: DEFENDANT DATE: , A )be) a ' Seal of the Court (Eff 7 97) EXPI.ANA17ION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SHELBY INSURANCE CO. 175 MANSFIELD AVENUE SHELBY, OH 44875 RE: 37811 KEVIN J. GUTSHALL FIRST PARTY FILE; POL/CLAIM NO.040-567118 R 0100931 27 LOSS DATE: 08/17/1998 Any and all claims files. Dates Requested: up to and including the present. Subject : KEVIN J. GUTSHALL 932 WEST TRINDLE ROAD, MECHANICSBURG, PA 17055 Social Security A 210-58-9488 Date of Birth: 07.06-1978 Date of Loss: 08/17/1998 SUIO-279008 3 7 8 1 1 - L 05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: KEVIN J. GUTSHALL - AUTO/BODILY INJURY -VS- COURT OF COMMON PLEAS TERM, CASE NO: 00-5036 REANN BANKS - BANKS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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 on behalf of DATE: 12/19/2000 GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT DE11-225199 3 7 8 1 1- 1-0 6 COMMONWEAL TH O V P E NN S YLVANTA COUNTY O Er CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN J. GUTSHALL - AUTO/BODILY INJURY TERM, -VS- CASE NO: 00-5036 REANN BANKS - BANKS TO SERVE A EVERETT C. HILLS, M.D. MEDICAL SHELBY INSURANCE CO. INSURANCE HB MCCLURE COMPANY, INC. EMPLOYMENT T0: V. SCOTT HENNING, ESQUIRE MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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: 11129/2000 CC: GIRARD E. RICKARDS, ESQUIRE - OOHB-00086 TOM BAKER - 5837DO05969 Any questions regarding this matter, contact MCS on behalf of GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-138627 3 7 8 1 1- 0 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEVIN J. GUTSHALL -AUTO/BODILY INJURY VS REANN BANKS -BANKS File No. 00-5036 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: HB MCCLURE COMPANY,INC. (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 at MCS GROUP INC.,1601 MARKET ST., 11800, PHILA.,PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its serv ice, 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: GIRARD E. RICKARDS, ESQ. ADDRESS: 214 SENATE AVE., SUITE 503 CAMP HILL, PA 17011 TELEPHONE: 215-246-0900 SUPREME COURT ID N: ATTORNEY FOR. DEFENDANT DATE: • / J co 07 C OUP Seal of the Court J'} EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HB MCCLURE COMPANY, INC. 600 SOUTH 17TH STREET HARRISBURG, PA 17105 RE: 37811 KEVIN J. GUTSHALL Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject : KEVIN J. GUTSHALL 932 WEST TRINDLE ROAD, MECHANICSBURG, PA 17055 Social Security #: 210-58-9488 Date of Birth: 07-06-1978 SU10-279010 3 7 8 3-3-- 1,0 6 r> _. c ?? . rj \ T y v r_- ?. ?: .. LC-- N -r', ?i v?,?; _ . C! -;C? ?: ?.._ L; i?? p` ?m ?t -G - 4 T CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN J. GUTSHALL - AUTO/BODILY INJURY TERM, -VS- CASE NO: 00-5036 CIVIL REANN BANKS - BANKS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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: 01/16/2001 CS on h/e? GIRA E. RICKARDS, ESQUIRE Attorney for DEFENDANT DE11-230442 :378-L3--I,07 COMMONWEALTH O V P E NN S YLVAN ZA COUNTY OP CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN J. GUTSHALL - AUTO/BODILY INJURY -VS- REANN BANKS - BANKS OF MINNESOTA MUTUAL INSURANCE TERM, CASE NO: 00-5036 CIVIL TO: U. SCOTT HENNING, ESQUIRE MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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: 12/27/2000 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT CC: GIRARD E. RICKARDS. ESQUIRE - 0088-00086 TOM BAKER - 5837D005969 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-141179 37 8 1 IL- C 0 2 I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEVIN J. GUTSHALL -AUTO/BODILY INJURY VS File No. 00-5036 CIVIL REANN BANKS -BANKS TO: CUSTODIAN OF RECORDS FOR: MINNESOTA MUTUAL INSURANCE COMPANY (Name of Person or Entity) Within twenty (20) days after service of this subpSEE I TOugCgDered by the court to produce the following documents or things: at MCS GROUP INC., 1601 MARKET ST., 0500, PHILA.,PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: GIRARD E. RICKARDS, ESQ. ADDRESS: 214 SENATE AVE.,#503 CAMP HILL, PA 17011 TELEPHONE: 215-246-0900 SUPREME COURT ID N: ATTORNEY FOR. DEFENDANT l)?!? DATE: ? .24. Seal of the Court (Eff. 7/97) r EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MINNESOTA MUTUAL GROUP DIVISON CLAIMS P.O. BOX 64114 ST PAUL, MN 55164 RE: 37811 KEVIN J. GUTSHALL COMPLETE DISABILITY CLAIM FILE, INCLUDING APPLICATION FOR BENEFITS AND AMOUNTS OF "PAYMENTS MADE FOR SUBJECT. CLAIM NO. H425582 Any and all claims files. Dates Requested: up to and including the present. Subject: KEVIN J. GUTSHALL 932 WEST TRINDLE ROAD, MECHANICSBURG, PA 17055 Social Security #: 210-58-9488 Date of Birth: 07-06-1978 Date of Loss: 08/17/1998 SU10-283212 3 7 8 1 1- L 0 7 ?..._ ? ;, o `,- ? ?,?.. ? .n ? ? G? ? i:? [: CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN J. GUTSHALL - AUTO/BODILY INJURY TERM, -VS- CASE NO: 00-5036 REANN BANKS - BANKS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE defendant 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 the 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: 09127/2000 GZRARD E. RICKARDS. ESQUIRE Attorney for DEFENDANT DEII-209146 3 7 8 1 1- L 0 1 COMMONWEALTH OF PENNSYL-?TANTA COUNT Y OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN J. GUTSHALL - AUTO/BODILY INJURY TERM, -VS- CASE NO: 00-5036 REANN BANKS - BANKS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS SHEPHERDSTOWN FAMILY PRACTICE MEDICAL BOWMANSDALE FAMILY PRACTICE MEDICAL SPANKEY'S AUTO SALES, INC. EMPLOYMENT TO: W. SCOTT HENNING, ESQUIRE MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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 no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. 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: 09107/2000 CC: GIRARD E. RICKARDS, ESQUIRE - OOHB-00086 TOM BARER - 5837DO05969 Any questions regarding this matter, contact MCS on behalf of GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-131617 3 7 8 1 1- C 0 2 COMMO\'4VEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEVIN J. GUTSHALL VS RAEANN BANKS File No. 00-5036 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: SHEPHERDSTOWN FAMILY PRACTICE (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 at MCS GROUP INC.,1601 MARKET ST., 11800, PHILA., PA 19103 (Address) You mac 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.'-he 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: GIRARD E. RICKARDS, ESQUIRE ADDRESS: 214 SENATE AVENUE, STE 503 CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPRENiE COURT ID ATTORNEY FOR. THE DEPENDENT DATE:7T?/V1r 1 'd Seal of the Court BY E OUMR-}T-: Prothonno???wy/Cler??kO Division Deputy (Eff. 7/ 9 i EXPLANATION OF REQUIRED RECORDS TO. CUSTODIAN OF RECORDS FOR: SHEPHERDSTOWN FAMILY PRACTICE 2140 FISHER ROAD MECHANICSBURG, PA 17055 RE: 37811 KEVIN J. GUTSHALL Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : KEVIN J. GUTSHALL 932 WEST TRINDLE ROAD, MECHANICSBURG, PA 17055 Social Security JI: 210-58-9488 Date of Birth: 07-06-1978 SII10-266100 37811-L01 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'F IN THE MATTER OF: COURT OF COMMON PLEAS KEVIN J. GUTSHALL - AUTO/BODILY INJURY TERM, -VS- CASE NO: 00-5036 REANN BANKS - BANKS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE defendant 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 the 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: 09/27/2000 GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT DE11-209147 3 7 8 1 1- L 02- C OMMO NWEAL T H O EP P E NN S YLVAN IA COUNTY O E7 C UMB E RLAND IN THE MATTER OF: KEVIN J. GUTSHALL - AUTO/BODILY INJURY -VS- REANN BANKS - BANKS COURT OF COMMON PLEAS TERM, CASE NO: 00-5036 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS SHEPHERDSTOWN FAMILY PRACTICE MEDICAL BOWMANSDALE FAMILY PRACTICE MEDICAL SPANKEY'S AUTO SALES, INC. EMPLOYMENT TO: W. SCOTT HENNING, ESQUIRE MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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 no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. 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: 09/07/2000 CC: GIRARD E. RICKARDS, ESQUIRE - OOHB-00086 TOM BARER - 5837D005969 Any questions regarding this matter, contact MCS on behalf of GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-131617 3 7 8 1 1- C 0 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEVIN S. GUTSHALL File No. 00-5036 VS RAEANN BANKS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUA:a`T TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: BOWMANSDALE FAMILY PRACTICE (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 ATTArvFn at MCS GROUP INC.,1601 MARKET ST., (1800, PHILA., PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If yon fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the pary 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 GIRARD E. RICKARDS, ESQUIRE ADDRESS: 214 SENATE AVENUE, STE 503 CAMP HILL, PA 17011 TELEPHONE: (215) 246-0900 SUPREME COURT ID ATTORNEY FOR: THE DEFENDENT BY THE COURT: nz? DATE s•. Prothon?o'/n Cle Civ' ivrsion D Deputy Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BOWMANSDALE FAMILY PRACTICE 1 KASEY COURT SUITE 101 MECHANICSBURG, PA 17055 RE: 37811 KEVIN J. GUTSHALL Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject : KEVIN J. GUTSHALL 932 WEST TRINDLE ROAD, MECHANICSBURG, PA 17055 Social Security A 210-58-9488 Date of Birth: 07-06-1978 SII10-266102 37811-L02 rr PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22'P IN THE MATTER OF: KEVIN J. GDTSHALL - AUTO/BODILY INJURY -VS- REANN BANKS - BANKS COURT OF COMMON PLEAS TERM, CASE NO: 00-5036 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE defendant 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 the 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: 09127/2000 GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT DEII-209148 3 7 8 1 1- Z.O 3 C0NII?40NWEAL1TH OF PENNSYLVAN=A COUNTY 0F CUMBERLAND IN THE MATTER OF: KEVIN J. GUTSHALL - AUTO/BODILY INJURY -VS- REANN BANKS - BANKS COURT OF COMMON PLEAS TERM, CASE NO: 00-5036 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS SHEPHERDSTOWN FAMILY PRACTICE MEDICAL BOWMANSDALE FAMILY PRACTICE MEDICAL SPANKEY'S AUTO SALES, INC. EMPLOYMENT TO: W. SCOTT HENNING, ESQUIRE MCS on behalf of GIRARD E. RICKARDS, ESQUIRE 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 no objection is made the subpoena may be served pursuant to the applicable Pennsylvania Rules of Civil Procedure 4009.24. 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: 09/07/2000 CC: GIRARD E. RICKARDS, ESQUIRE - OOHB-00086 TOM BAKER - 5837DO05969 MCS on behalf of GIRARD E. RICKARDS, ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-131617 37811--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND KEVIN J. GUTSHALL VS File No. 00-5036 RAEANN BANKS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: SPANLEY'S AUTO SALES. INC. (.Name of Person or Entity-) Within twenty (20) davs after service of this subpoena, you are ordered by the court to produce the following documents or things: CFF ATTA HFD at MCS GROUP INC.,1601 MARKET ST., 11800, PHILA., PA 19103 (Address) You may deliver or .ail 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 twe.nry (20) davs after its service, the party serving this subpoe:z may seek a court order compelling you to comply with it. THIS SUBPOE\A WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME GIRARD E. RICKARDS, ESQUIRE ADDRESS: 214 SENATE AVENUE, STE 503 CAMP HILL, PA 17011 TELEPHONE (215) 246-0900 SUPREME COURT ID I`:. ATTORNEY FOR THE DEFENDENT DATE 9ykMHU I nCU1lV Seal of the Court 13Y TITE COUR ? -url?to -- ?? PrvtiwTno /Cl Gvil Division Dep? ? (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SPANKEY'S AUTO SALES, INC. 701 EAST LOCUST STREET MECHANICSBURG, PA 17055 RE: 37811 KEVIN J. GUTSHALL Any and all employment records, files and memorandums, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee. Dates Requested: up to and including the present. Subject : KEVIN J. GUTSHALL 932 WEST TRINDLE ROAD, MECHANICSBURG, PA 17055 Social Security A 210-58-9488 Date of Birth: 07-06-1978 SU10-266104 37811-L03 -"= ? VM@ivvti4m.4#9.ei5ad.Y5irVwYtlNabSO?YU?A[sbiJS?tiew? r?erd;ra.?_ %"•.'.«. ?. "•..? ,. =....-.-may- ._: ... -.rte-. - 1) r 74 ? ? G ?_.... ,.!7 _ CJ? t" P) C'r 2 C Fri ' . C . -?C C73 KEVIN J. GIITSHALL, Plaintiff V RAENN BANKS, Defendant TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5036 : CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE Please mark the above action settled and discontinued. By: Respectfully Submitted, HANDLER, HENNING & ROSENBERG W. Scott l%nn. I.D. No. 3229 1300 Lingles o Harrisburg, P (717)238-2000 Dated: 9 - //® °a? Attorneys for Plaintiff CERTIFICATE OF SERVICE AND NOW, this 16th day of August, 2001, I hereby certify that I have, on this date, served the within document upon defendant's counsel and all counsel of record by sending a true and correct copy of same to them via first class, United States mail, postage prepaid, and addressed as follows: Girard E. Rickards, Esquire 214 Senate Avenue Suite 503 Camp Hill, PA 17011 HANDLER, HENNING & ROSENBERG By: W. Scott .R --) CD _<