Loading...
HomeMy WebLinkAbout01-4744 v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 17 t.j 1 CIVIL TERM ANGELA DIANNE ZIMMERMAN, PLAINTTIFF, DONALD E. DONOVAN and JUDY K. DONOVAN, DEFENDANTS CIVIL ACTION . LAW PRAECIPE FOR A WRIT OF SUMMONS TO CURTIS R. LONG, PROTHONOTARY: Please enter my appearance on behalf of the Plaintiff and issue a Writ of Sununons against the defendants, Donald E. Donovan and Judy K. Donovan. Please direct the Sheriff to serve the defendants as follows: Mr. Donald E. Donovan Ms. Jndy K. Donovan 13 Deer Drive Newville, PA 17241 Respectfully submitted, IRWIN, McKNIGHT & HUG By: Date: August 10,2001 To: DONALD E. DONOVAN and JUDY K. DONOVAN You are hereby notified that Angela Dianne Zimmerman, the plaintiff, has commenced an action against you which you are required to defend or a default iUdGt may be ~tered a~ainst yo . tJ-O NO Y By: (irl1Ip (, ') ;] Lr/l"-i ~ ~ DEPUTY ~ Date/lt:J/J IT- / (J .2001 ~ LC. f:::: ,- I.i) t.V: --1 9:7 :Z ~ )L (;::I Q.. i6 In ::::r- ('"'J r- 7' 5........ S~ -\3 , >- : .' Cf) yz .c.z -'-JIU '-i~ n... ~ U c:.> c..::. <r '" ~ Ii ~~ (bl() - -\=}~ '&- '--> I"<'~ OH Z U)< ~:> ~h .-J>-;:>;: ;::.., tr.; p.:; Z,-" ZZf-I;s- C4:l < ~",,;:j"" o -::- J U~H ,;,U;Z ~.z <0 O~ H o .f-; =---U~U Slg-< g. ~:~ , ,.;~, ~ o:~ "'''-1ZoQ ~~' " ~, . : ,,<''', . . ~. J--~" ~ 9" -.r,:. -~- z ~ "" ~ H N "" " <0 II II jl ~ " "t -(---~ ,,~, '",~' ~~ N 0' ,'-j M ^ " tiJ a a: N I- 00 <: J..;. Z if ~ ~ ~ :> >- o " a. if t; :t ~ ui ~ o 00 IC :J a: <l "d "" UJ P<Z 00 :~ "-UJ H U~ WO ;:;if-< "'H & en w u it ~ o ~ ..J. " SHERIFF'S RETURN - REGULAR CASE NO: 2001-04744 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ZIMMERMAN ANGELA DIANNE VS DONOVAN DONALD E ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon DONOVAN DONALD E the DEFENDANT , at 1930:00 HOURS, on the 7th day of September, 2001 at 50 N HIGH ST #1 NEWVILLE, PA 17241 by handing to DONALD DONOVAN a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 7.80 .00 10.00 .00 35.80 So Answers: r~r/<:~ R. Thomas Kline 09/10/2001 IRWIN MCKNIGHT '\ Sworn and Subscribed to before By: me this 1..1, tt::- day of +-~~. .:un 1 A.D. ~ ()_ 7u,Ph" ~ Prothonotary . SHERIFF'S RETURN - REGULAR CASE NO: 2001-04744 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ZIMMERMAN ANGELA DIANNE VS DONOVAN DONALD E ET AL SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon DONOVAN JUDY K the DEFENDANT , at 1930:00 HOURS, on the 7th day of September, 2001 at 50 N. HIGH ST #1 NEWVILLE, PA 17241 by handing to DONALD DONOVAN HUSBAND a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: r~,-t:~ R. Thomas Kline 09/10/2001 IRWIN MCKNIGHT & HUGH S Sworn and Subscribed to before me this 1.2~ day of l,,;r,--...Lh~ ~I A.D. (J . fl~ ()A YH, I#"~~ '-t /Prothonotary By: " heriff OIHB-00132 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp HiD, PA 17011 Telephone Number: (717) 731-0988 Attome s for Defendants ANGELA DIANNE ZIMMERMAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2001-4744 DoNALD E. DoNOVAN AND JUDY K. DoNOVAN, DEFENDANTS CIVIL ACTION - LAw JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO mE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendants, Donald E. Donovan and Judy K. Donovan. Respectfully submitted, LAW OFFlC~rF JACOBS~ &S A ~. i' _ J if 1; L------- By: _/ Donald R. Dorer, Esquire Attorney for Defendants Identification No. 39126 Date: October 2. 2001 OIHB-00132 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants ANGELA DIANNE ZIMMERMAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CuMBERLAND COUNTY, PENNSYLVANIA VS. No. 2001-4744 DONALD E. DONOVAN AND JUDY K. DoNOVAN, DEFENDANTS CIVIL ACTION - LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Entrv of Aooearance to be served by regular first class mail upon: Date: October 2.2001 ~arcusA.~cKmgh~Irr Irwin, ~cKmght & Hughes 60 West Pomfret Street """'< PA 17013. . ... I I )10 /1* .. '. DJ;Ud R. Dorer, Esquire Attorney for Defendants o C 7' -nIT rnr";- Z:::c 2T (j);r~ -< " cO '- ~Q be,.J ,..<-'~ L =< Ci c, 'C-J ~ .....J , ,~' -" _.-. .....'," G) ::~ '~ 'oJ =< (,o) OIHB-00132 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attome s for Defendants ANGELA DIANNE ZIMMERMAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CuMBERLAND COUNTY, PENNSYLVANIA VS. No. 2001-4744 DONALD E. DoNOVAN AND JUDY K. DoNOVAN, DEFENDANTS CMLAcrION-LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTIlONOTARY: Please enter a RULE upon plaintiff to fIle a C P" . ']ithin, 20 daYS" ,if or suffer the entry of a Judgment of Non Pros. ',' / j j I7\-/ , d R. Dorer, Esqu1l'e Date: October 2.2001 Attorney for Defendants RULE TO FILE COMPLAINT AND NOW, this ~day of {'Y.-/.r..l '917 , 2001 a RULE is hereby entered upon the Plaintiff to fIle a Complaint herein within 20 days after service hereof or suffer the entry of a Judgment of Non Pros. PROTIlONOTARY ~ ""'~<'~'''Z.\r;./ ' OlHB-00132 ...'....,. LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants ANGELA DIANNE ZIMMERMAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2001-4744 DoNALD E. DoNOVAN AND JUDY K. DONOVAN, DEFENDANTS CIVll.. ACTION - LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Praecioe for Rule to File Complaint to be served by regular first class mail upon: Marcus A. McKnight, ill Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 j"., >iiP~<, I. JXG Ii/fl... . '. ~ '"" "::' .;" Date: October 2.2001 n '1; Donald R. Dorer, Esquire Attorney for Defendants rijl. ;' . . ~ ~ '~:(K /'I, 'I, ' ftr 1~~I(fo:: /1 , ! '~)/'1"''''' ...... .,~. , v " .~.""",", """".-,l""~.t .tn~, .?,',sl.i1l7 r,: t.'.,. . ("'-;!\i Lie:' }~l~' ...' I.:. " ~.. ";,!i.. " ".'"'7~f,:":~;~ ,,'." .. o C ?' -orE' nlf,'1 2:,r) 2C' en" ' -< r- -- );:c' 2.: ~< ,'-c- .Pc Z -=~ -< c? c:> n ._, I .r:...- CoJ , ::3 :0- ' :;: (,,:< ,._t ,--" ,II, l' ., ANGELA DIANNE ZIMMERMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2001-4744 CIVIL TERM DONALD E. DONOVAN and JUDY K. DONOVAN, Defendants JURY TRIAL DEMANDED NOTICE TO DEFEND 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, order 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 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, Pennsylvania 17013 (717) 249-3166 1-800-990-9108 Americans with Disabilities Act of 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 1 ANGELA DIANNE ZIMMERMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2001-4744 CIVIL TERM DONALD E. DONOVAN and JUDY K. DONOVAN, Defendants JURY TRIAL DEMANDED COMPLAINT AND NOW, this 29th day of October 2001 come the plaintiff, Angela Dianne Zimmerman, by and through her attorneys, Irwin, McKnight & Hughes, and makes the following Complaint against the defendants, Donald E. Donovan and Judy K. Donovan: I. The plaintiff is Angela Dianne Zimmerman who is an adult individual residing at 15 Etter Road, Newburg, Carlisle, Pennsylvania 17240. 2. The defendants, Donald E. Donovan and Judy K. Donovan, are adult individuals residing at 13 Deer Drive, Newville, Pennsylvania 17241. 3. On August 26, 1999, the Plaintiff was travelling north on Pa Route 233 at approximately 5:30 a.m. in Penn Township, Cumberland County, Pennsylvania. 4. The Plaintiff signaled a right hand turn into the parking area at the Penn Township Building. 2 5. The Defendant, Donald E. Donovan, was travelling directly behind the Plaintiff, driving a Chevrolet pickup truck. 6. Without warning, the Defendant struck the rear of the Plaintiff's 1990 Ford Probe automobile which caused the Plaintiffs vehicle to swerve. The Defendant's vehicle then struck the rear passenger door of the Plaintiffs vehicle. The Plaintiffs vehicle came to rest off the highway facing in a southerly direction. 7. The multiple impacts of the collision caused by the Defendant's vehicle severely damaged the Plaintiff's automobile and caused the Plaintiff to sustain multiple physical injuries. 8. The impact of the multiple collisions caused serious and permanent injuries to the Plaintiff, Angela Zimmerman. They included injuries to her neck, head, jaw, back, arms, and legs. 9. The defendant, Donald E. Donovan, was the proximate cause of the accident and injuries sustained by the plaintiff. 3 10. The accident and injuries sustained by plaintiff was caused by the negligent, careless and reckless actions of the defendant, Donald E. Donovan. II. The defendant, Donald E. Donovan, was acting as agent for the defendant, Judy K. Donovan, and he is therefore responsible for the damages sustained by the plaintiff. 12. Defendant's conduct was negligent, careless and reckless and with disregard and indifference to the rights and well being of others and the plaintiff in that she was: a. traveling too fast for conditions; b. was unable to control his vehicle while driving on a state highway; c. Failure to pay attention to the traffic in front of him and failure to pay attention to the plaintiffs vehicle which was turning right directly in front of him; d. Following too closely to the vehicle of the plaintiff and unable to avoid the collision; e. Failure to warn the plaintiff of the collision by sounding his horn; f. Operating his vehicle in a careless manner and with reckless indifference to the risk to the plaintiff; g. Failure to adequately control his vehicle; h. Failure to properly apply his brakes in order to avoid striking plaintiffs vehicle; and 1. Failure to bring his vehicle to a safe stop. 4 13. The negligent actions of the defendant, Donald E. Donovan, are the proximate cause of the injuries to the plaintiff, Angela Dianne Zimmerman. 14. The plaintiff, Angela Dianne Zimmerman, lost wages due to the injuries he sustained in the accident. 15. The plaintiff, Angela Dianne Zimmerman, seeks compensation for the pain and suffering, emotional distress, embarrassment and loss of life's pleasures since the date of the accident as well as compensation for future losses she will incur in these areas. 16. The plaintiff, Angela Dianne Zimmerman, seeks compensation for the medical expenses which he has occurred and may incur in the future to treat his injuries. 17. The plaintiff, Angela Dianne Zimmerman, seeks compensation for the permanent irUuries which he has sustained. 5 WHEREFORE, the plaintiff, Angela Dianne Zimmerman, requests compensation and damages from the defendants, Donald E. Donovan and Judy K. Donovan, in the amount in excess of Twenty-Five Thousand and no/I 00 ($25,000.00) Dollars with interest as permitted by law and the costs of this litigation. Respectfully submitted, IRWIN, MCKNIGHT & HUGHES By: Marcus A. McKn' t, III, Esquire 60 West Pomfret Stre Carlisle, Pennsylvania 17013 (717) 249-2353 Supreme Court LD. No. 25476 Attorney for plaintiff Date: 6 VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date:~ 2ro\ ANGELA DIANNE ZIMMERMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2001-4744 CIVIL TERM DONALD E. DONOVAN and JUDY K. DONOVAN, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Complaint was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Donald R. Dorer, Esq. JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 IRWIN, McKNIGHT & HUGHES By: Marcus A. Mc 60 West Pomfret Carlisle,PA 17013 (717) 249-2353 Supreme Court J.D. No. 25476 Date: October 29. 2001 >- q; ~::: (-., LU. . C);: 8::,i (...,) (- ~ C, 1,..1..1'__ --' l.L " () "",. r ~ z :~~~~ ._.-~ J , ~J ::-1 - ~ -..",~ -Cn (r~~~ .UUJ ~1J 0... ""::;;: 5 u (~ '-'-- a, N t-- (-~ G C> OIHfl.:o0132' . LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants ANGELA DIANNE ZIMMERMAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2001-4744 DONALD E. DONOVAN AND JUDY K. DONOVAN, DEFENDANTS CIVIL ACTION - LAw JURY TRIAL DEMANDED RULE TO SHOW CAUSE AND NOW, this day of .2002, upon consideration of the 'Within Petition of Defendants to Compel Answers to Interrogatories and Request for Production . of Documents Addressed to the Plaintiff, a Rule is hereby issued upon the Plaintiff to show cause, if any she may have, as to why the relief requested in said Petition should not be granted, with the Plaintiff being compelled to provide full and complete responses to the Interrogatories and Request for Production of Documents Addressed to the Plaintiff within thirty (30) days. Rule Returnable within twenty (20) days upon service hereof BY lHE COURT: J. Ol&B~0131> LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants ANGELA DIANNE ZIMMERMAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2001-4744 DONALD E. DONOVAN AND JUDY K. DONOVAN, DEFENDANTS CIVIL ACTION - LAw JURY TRIAL DEMANDED PETITION OF DEFENDANTS TO COMPEL ANSWERS TO INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS ADDRESSED TO THE PLAINTIFF AND NOW, comes the Defendants, Donald E. Donovan and Judy K. Donovan, who through their counsel Donald R. Dorer, Esquire, Jacobs & Saba, Camp Hill, Pennsylvania, respectfully state as follows: 1. The above referenced matter was commenced by the filing of a Writ of Summons on or about August 10, 2001, with a true and correct copy of same being attached hereto as Exhibit "A". 2. Thereafter, a Complaint was med on behalf of the Plaintiff on or about October 29, 2001, with a true and correct copy of same being attached hereto as Exhibit "B". The Defendants, Donald E. Donovan and Judy K. Donovan, med Answer with New Matter of Defendants, Donald E. Donovan and Judy K. Donovan, to Plaintiff's Complaint on or about November 14, 2001, with a true and correct copy of same being attached hereto as Exhibit "C". 3. The Defendants served Interrogatories and Request for Production of Documents Addressed to the Plaintiff under cover of a letter dated October 2, 2001 by counsel for the Defendants to counsel for the Plaintiff. A true and correct copy of the letter of October 2,2001, and the enclosed Interrogatories and Request for Production of Documents Addressed to the Plaintiff, are attached hereto as Exhibit oD". 4. By letter dated December 13, 2001, counsel for the Defendants inquired of counsel for the Plaintiff as to when responses to the Interrogatories and Request for Production of Documents served on or about October 2, 2001 may be expected, with a true and correct copy of the letter of December 13, 2001 being attached hereto as Exhibit "E". 5. By letter dated December 19, 2001, counsel for the Plaintiff indicated that he would be meeting with his client and "...1 believe she will be able to complete the Interrogatories in January 2002." A true and correct copy of the letter dated December 19, 2001 is attached hereto as Exhibit "P". 6. The Interrogatories and Request for Production of Documents served upon the Plaintiff, and previously attached as Exhibit "D", are routine and appropriate written discovery requests in a case involving a claim for personal injury allegedly arising out of a motor vehicle collision. 7. To date, the Plaintiff has failed to serve any responses to the Interrogatories and Request for Production of Documents Addressed to the Plaintiff, previously attached hereto as Exhibit "D", nor have any objections been lodged by the Plaintiff, or her counsel, with regard to the aforesaid discovery requests. 8. The failure of the Plaintiff to provide full and complete responses to the Interrogatories and Request for Production of Documents Addressed to the Plaintiff, previously attached hereto as Exhibit "0", is hindering and prejudicing the ability of the Defendants to evaluate the merits of the claim of the Plaintiff with regard to either settlement opportunities, or for expeditious trial preparation. WHEREFORE, this Honorable Court is respectfully requested to issue a Rule upon the Plaintiff to show cause, if any she may have, as to why the Plaintiff should not be ordered and compelled to provide full and complete responses to the Interrogatories and Request for Production of Documents, previously attached hereto as Exhibit "0", within thirty (30) days hereof, and to grant such other and further relief as may appear just to the Court under the circumstances. Respectfully submitted, LAW . F JACOBS 8rt By, . I/l! Donald R. Dorer, Esquire Attorney for Defendants Identification No. 39126 Date: March 18.2002 Exhibit A 14:50 71 75327151 .'\.NC':f.:t.." DIANNE ZIM:'\-lERMAN. l'LAIl"iTTlI'I', IN THJ;' rnlll'T nl' rnMMnN Pr..,A,~ o. CU!Y(DERLAND COUNTY, rENN3YL..,'A!'I1A v. NO. 2001 - ~1-I..JL/ CIVIL TERI\I nn('JAI n F.. nONOVAN and .JUD.... K. DOt'iO~'AJ"lt DEFENDANTS crVlL ACTION - LAW PRAECIPE FOR A WRIT OF SUM.MONS TO CURTIS R. LONG. PROTHONOTARY: Please enter my appe:1Iance on behalf of the Plaintiff and i~$ue a Writ of Summons agalIl~t tile defendants, Donald E. Donovan and Judy K. Donovan. Please direct the Shenffto serve the defendants as follows: Mr. Donald E, Donovan Ms, Judy K. Donovan 13 Deer Drive Newville, PA 17241 By: [S Date: August 10,2001 Marcu A. Mcl<.lrl1lht. III, ['q 60 Weat Porofr t Street, Carlisle, (717) 249.2353 - reme 17013 .D. No: 25d76 To: DONALD E. DONOVAN and JUDY K. DONOVAN You are hereby notified that Angela Dianne Zimmerman, the plaintiff, has commenced an action against you which you are required to defend or a default judgme may be entered against you. CJ1. , l..), PROTHO ,T^&y (}ml~A ~11A),O",,~ ~ DEPUTY By: Date!)11 fft1 D+ !l) 2001 --- Exhibit B ANGELA DIANNE ZIMMERMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. 2001-4744 CIVIL TERM - ~. ... DONALD E. DONOVAN and JUDY K. DONOVAN, Defendants JURY TRIAL DEMANDED NOTICE TO DEFEND 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, order 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 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 AFFO~ 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, Pennsylvania 17013 (717) 249-3166 1-800-990-9108 ". Americans with Disabilities Act of 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 'l.~~ ~\) TRUEOOPY FROM HE~ -- '-' TJ.~"'MnlOI, I !we UII'ilIllt my RanO .,J li'fIj f!!:...rM said Court It CaI1WI. Fe. '-- rn~ .~ot~,~ otttl)' I : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANGELA DIANNE ZIMMERMAN, Plaintiff v. 2001-4744 CIVIL TERM DONALD E. DONOVAN and JUDY K. DONOVAN, Defendants JURY TRIAL DEMANDED 'C. COMPLAI1\T AND NOW, this 29th day of October 2001 come the plaintiff, Angela Dianne Zimmerman, by and through her attorneys, Irwin, McKnight & Hughes, and makes the following Complaint against the defendants, Donald E. Donovan and Judy K. Donovan: I. The plaintiff is Angela Dianne Zimmerm~ who is an adult individual residing at 15 Etter Road, Newburg, Carlisle, Pennsylvania 17240. 2. The defendants, Donald E. Donovan and Judy K. Donovan, are adult individuals residing at 13 Deer Drive, Newville, Pennsylvania 17241. 3. On August 26, 1999, the Plaintiff was travelling north on Pa Route 233 at approximately 5:30 a.m. in Penn Township, Cumberland County, Pennsylvania. 4. --- The Plaintiff signaled a right hand turn into the parking area at the Penn Township Building. 2 5. The Defendant, Donald E. Donovan, was travelling directly behind the Plaintiff, driving a Chevrolet pickup truck. 6. Without warning, the Defendant struck the rear ofthe Plaintiff's 1990 Ford Probe automobile which caused the Plaintiffs vehicle to swerve. The Defendant's vehicle then struck the rear passenger door of the Plaintiffs vehicle. The Plaintiffs vehicle came to rest off the highway facing in a southerly direction. 7. The multiple impacts of the collision caused by the Defendant's vehicle severely damaged the Plaintiff's automobile and caused the Plaintiffto sustain multiple physical injuries. 8. The impact of the multiple collisions caused serious and permanent injuries to the Plaintiff, Angela Zimmerman. They included injuries to her neck, head, jaw, back, arms, and legs. -. 9. The defendant, Donald E. Donovan, was the proximate cause of the accident and injuries sustained by the plaintiff. .....--- 3 10. The accident and injuries sustained by plaintiff was caused by the negligent, careless and reckless actions of the defendant, Donald E. Donovan. 11. , The defendant, Donald E. Donovan, was acting as agent for the defendant, Judy K. Donovan, and he is therefore responsible for the damages sustained by the plaintiff. 12. Defendant's conduct was negligent, careless and reckless and with disregard and indifference to the rights and well being of others and the plaintiff in that she was: a. traveling too fast for conditions; b. was unable to control his vehicle while driving on a state highway; c. Failure to pay attention to the traffic in front of him and failure to pay attention to the plaintiffs vehicle which was turning right directly in front of him; d. Following too closely to the vehicle of the plaintiff and unable to avoid the collision; e. Failure to warn the plaintiff of the collision by sounding his horn; f. Operating his vehicle in a careless manner and with reckless indifference to the risk to the plaintiff; g. Failure to adequately control his vehicle; h. Failure to properly apply his brakes in order to avoid striking plaintiffs vehicle; and 1. Failure to bring his vehicle to a safe stop. ....~--- 4 13. The negligent actions of the defendant, Donald E, Donovan, are the proximate cause of the injuries to the plaintiff, Angela Dianne Zimmerman. 14. The plaintiff, Angela Dianne Zimmerman, lost wages due to the injuries he sustained in the accident. 15. The plaintiff, Angela Dianne Zimmerman, seeks compensation for the pain and suffering, emotional distress, embarrassment and loss of life's pleasures since the date of the accident as well as compensation for future losses she will incur in these areas. 16. The plaintiff, Angela Dianne Zimmerman, seeks compensation for the medical expenses which he has occurred and may incur in the future to treat his injuries. 17. The plaintiff, Angela Dianne Zimmerman, seeks compensation for the permanent injuries which he has sustained. -- 5 -. 'WHEREFORE, the plaintiff, Angela Dianne Zimmerman, requests compensation and damages from the defendants, Donald E. Donovan and Judy K. Donovan, in the amount in excess of Twenty-Five Thousand and no/l00 ($25,000.00) Dollars with interest as permitted by law and the costs of this litigation. - Respectfully submitted, By: Marcus 60 West omfret Carlisle, Pennsyl (717) 249-2353 Supreme Court J.D. No. 25476 Attorney for plaintiff IRWIN, MC Date: 0" I-v&.r .;If ~q() ( I ...-- 6 VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action. I have head the statements made in this _ do(;umen~ and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa, C.S.A. Section 4904, relating to unsworn falsification to authorities. Date:19 0~ 2ro\ --- : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANGELA DIANNE ZIMMERMAN, Plaintiff v. 2001-4744 CIVIL TERM DONALD E. DONOVAN and JUDY K. DONOVAN, Defendants JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Marcus A, McKnight, Ill, Esquire, hereby certify that a copy of attached Complaint was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Donald R. Dorer, Esq. JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 By: 1 ". . Date: October 29. 2001 ....,..- Exhibit C " OlHB..()() 132 LAW OFFICES OF JACOBS & SABA ___2H.cS$nate Avenue, Suite 503 ," Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne 5 for Defendants ANGELA DIANNE ZIMMERMAN, PI..AINTIFF IN THE Cciim.T OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . ~ - ....:'" VS. No. 2001-4744 DONALD E. DONOVAN AND JUDY K. DONOVAN, DEFENDANTS CIVIL AcrION - LAw JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANTS, DONALD E. DONOVAN AND JUDY K. DONOVAN, TO PLAINTIFF'S COMPLAINT 1. Admitted. 2. Admitted. 3. Admitted. 4.- 17. Denied. These paragraphs are generally denied pursuant to Fa.R.C.P. ~1029(e). WHEREFORE, the Defendants respectfully pray this Honorable Court to dismiss Plaintiff's Complaint, and to enter judgment against the Plaintiff and in favor of the . Defendants. NEW MAlTER .:iIS= ~. -.. 18. Paragraphs 1 through 17 are incorporated herein by reference, and made a part hereof as if set forth in full. 19. Plaintiff's claims are barred in whole or in part by the provisions of the Pennsylvania No-Fault Motor Vehicle Insurance Act and/or the Pennsylvania Motor Vehicle Financial Responsibility Law. .,,;1 ~.- ~ . :., WHEREFORE, the Defendants respectfully pray this Honorable Court to dismiss Plaintiff's Complaint, and to enter judgment against the Plaintiff and in favor of the Defendants. :;.- Respectfully submitted, /"1 /' LAW 0 By: : on d R. Dorer, uire Attorney for Defendants Identification No. 39126 Date: November 13. 2001 -:Pli= .- -,.- OlHB-00132 LAW OFFICES OF JACOBS & SABA _ ,_2t~ ~~ate Avenue, Suite 503 >, Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants ANGELA DIANNE ZIMMERMAN, PLAINTIFF IN 1HE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~ VS. No. 2001-4744 DONALD E. DONOVAN AND JUDY K. DONOVAN, DEFENDANTS CIVILACTlON-LAW JURY TRIAL DEMANDED VERIFICATION We, Donald E. Donovan and Judy K. Donovan, verify that the statements made in the foregoing Answer with New Matter of Defendants. Donald E. Donovan and Judy K. Donovan. to Plaintiff's Comolaint , which are within the personal knowledge of the undersigned, are true and correct, and as to the facts based on the information of others, the undersigned, after diligent inquiry, believe them to be true. And further, this Verification is signed on the recommendation of my attorneys, who advise me that the allegations and language in this document are required legally to raise issues for resolution at trial, by the Court, or by continuing investigation and preparation for trial. We understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete and we leave the detennination of these matters to my attorneys on their advice. -'. We understand that all statements herein are made subject to the penalties of 18 he.SA 14904, remting to u"'~ M~_. n."",;Joll-b-2OO( g1E ~ Donald E. Donovan 4" -..~ Dated: \\0\) G, J :J OD I ~.~ iUm,,,,,ci.. K. novan ~ NDV .. ~ zn~ OlHB..oo132 LAW OFFICES OF JACOBS & SABA _ ,_" 21Jt,S,enate Avenue, Suite 503 >, Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants ANGELA DIANNE ZIMMERMAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~ ,- VS. No. 2001-4744 DONALD E. DONOVAN AND JUDYK. DONOVAN, DEFENDANTS CIVIL AcrION - LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifie,s that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Answer with New Matter of Defendants. Donald E. Donovan and Judv K. Donovan. to Plaintiff s Comolaint to be served by regular first class mail upon: Marcus A. McKnight, III Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 Date: November 13. 2001 tt /" Donald R. Dorer, Esquire Attorney for Defendants ~ ~. ...,. .~- Exhibit D JACOBS & SABA ... (NOT'" PAIlTllERSmp) 214 SENATE AVENUE SurrE 503 CAMP HILL, P A 17011 (717)731-0988 FAX: (717)731-0987 TDD (800) 622-%421 -:-- DoN"ALD1t.DoRER GIR..i.Jm E. RlcKARDS* ATTORNEYS -CERTIFIED CML TRJALADVOCATE NATIONAL BOARD or TRIA.L ADVOCACY DENISE E. KAUFFMAN, LmCATION PAllALEGAL REFER To: 01HB-00132 October 2,2001 Marcus A. McKnight, ill Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 Re: Angela Dianne Zimmerman vs. Donald E. Donovan and Judy K. Donovan Cumberland County: No. 2001-4744 Dear Mr. McKnight, Please be advised that I will be representing the Defendants in the above referenced matter. I enclose a copy of my Entry of Appeaiance and Praecipe for Rule to File Complaint which I have med with the Court by mail this date. You may expect to receive the executed Rule to File Complaint by certified mail. Additionally, I enclose Interrogatories and Request for Production of Documents Addressed to the Plaintiff. Kindly provide responses to these discovery requests pursuant to the applicable Rules of Civil Procedure. If you so designate, you need not provide copies of documents previously supplied to Nationwide. -. Your attention to this matter is most a~)iated. S~irelY yo~rs, . ~----- ./ ;/ . Donald R. Dorer DRD:dek Enclosures _.oe__. -- .J~\. Employees ofNationwi~ Mutual Insurance Company Bethlehem' ~ Hill' Canonsburg' Doylestown. Oreeosburg' Media' Norristown. PIilladelphia' Wamnda1.' Wi1kos Bane OIHB..()() 132 LAW OFFICES OF JACOBS & SABA - 214 Senate Avenue, Suite 503 -. Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants ANGELA DIANNE ZIMMERMAN, PLA1NTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2001-4744 DONALD E. DONOVAN AND JUDY K. DONOVAN, DEFENDANTS CIVIL ACTION - LAw JURY TRIAL DEMANDED REQUEST FOR PRODUCTION OF DOCUMENTS UNDER Pa. R.C.P. 4009 ADDRESSED TO: Plaintiff, An2ela Dianne Zimmerman You are directed to produce the following documents pertaining to the incident, occurrence, or accident described in Plaintiff's Complaint for inspection and copying at the offices of Jacobs & Saba, 214 Senate Avenue, Suite 503, Camp Hill, PA, 17011, pursuant to Pennsylvania Rule of Civil Procedure 4009: _, 1. The entire contents of any and all claims and investigation mes prepared in this matter, however labeled, excluding references to mental impressions, conclusions or opinions representing the value or merit of the claim or defense, or respecting strategies or tactics in privileged communications from counsel. 2. All statements, memoranda, or writings, whether signed or unsigned, of any and all witnesses, including any and all statements, memoranda, and writings of Plaintiff. 3. All photographs, recordings, films, charts, sketches, graphs and diagrams taken and/or prepared. ..:if1Sr...:: 4. Reports of, or from, any and all experts who will testify at trial, or whom you expect will testify at trial. .-- ..;.:;;.. l' 5. All statements concerning this action or its subject matter previously made by any party or witness pursuant to Pa. R.C.P. 4003.4. 6. All bills, receipts, reports, diagnosis (including x-ray and like diagnostic reports) or prognosis and records of any and all medical, physical, psychiatric and! or psychological treatmei1(by any doctor, hospital, psychologist, and psychiatrist, pharmacy or medical facility for any injury, treatment or damage received by Plaintiff for any of the alleged incidents referred to in Plaintiff's Complaint. 7. All bills of any kind incurred by Plaintiff as a result of the alleged incident, occurrence, or accident. 8. All medical records, employer statements, IRS W-2 Forms, and Income Tax Retnrns (for the preceding five (5) years), lost wages and!or employment records and all other writings, including expert reports, establishing any claim Plaintiff may assert for lost earnings and lost earning capacity and for any other fmanciallosses. 9. All documents, exhibits, or other tangible physical objects, and/or reports, of any kind whatsoever that will be presented or introduced into evidence at time of trial. Respectfully submitted, LAwif: '; O','A7ft"'A Iir. / f I n d R. Dorer, Esquire' Attorney for Defendants Identification No. 39126 Date: October 2. 2001 ~ ",,' --~ OIHB..()()132 LAW OFFICES OF JACOBS & SABA - 214 Senate Avenue, Suite 503 . Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attome s for Defendants ANGELA DIANNE ZIMMERMAN, PLA1NTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2001-4744 DONALD E. DONOVAN AND JUDY K. DONOVAN, DEFENDANTS CIVIL ACTION - LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R Dorer, Esquire, hereby certifie,s that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Request for Production of Documents of Defendants Addressed to the Plaintiff to be served by regular first class mail upon: Date: October 2. 200 I Marcus A. McKnight, ill Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 1/ / [' .1/) .. , tV \. L/ /:~._- I ,/\. /-- I ' - :.:Donald R Dorer, Esquire Attorney for Defendants .:;tsr-= oIHfl~OI32, LAW OFFICES OF JACOBS & SABA -::: 214.Senate Avenue, Suite 503 Camp HilI, PA 17011 Telephone Number: (717) 731-0988 Attome s for Defendants ANGELA DIANNE ZIMMERMAN, PLA1NTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2001-4744 DONALD E. DONOVAN AND JUDY K. DONOVAN, DEFENDANTS CIVIL ACTION - LAw JURY TRIAL DEMANDED INTERROGATORIES ADDRESSED TO: Plaintiff, An2ela Dianne Zimmerman The Defendants propound the following Interrogatories to be answered under oath pursuant to Pa. R.C.P. 4005, 4006 by the Plaintiff within thirty (30) days after service. The foregoing Interrogatories are to be regarded as continuing and you are requested to provide, by way of supplementary answers thereto, such additional information as may hereafter be obtained by you, or any person on your behalf, which will augment or otherwise modify any answers now given to the foregoing Interrogatories pursuant to Pa. RC.P. 4007.4. Such supplemental responses are to be served upon the Defendants seasoDllbly after receipt of ~- ... --~ such information. 1. PERSONAL INFORMATION: PLEASE PROVIDE THE FOLLOWING INFORMATION FOR EACH PLAINTIFF INVOLVED IN - 1WS 4-CTION: (A) FuLL NAME AND ANY PRIOR NAMES USED FROM THE TIME OF THE INCIDENT FOR WHICH THIS ACTION IS BROUGHT. ." (B) CURRENT ADDRESS AND ANY PRIOR ADDRESSES USED FROM THE TIME OF THE INCIDENT FOR WHICH THIS ACTION IS BROUGHT. (c) DATEOFBIRm. -. (D) SOCIAL SECURITY NUMBER. ~ 2. CURRENT EMPLOYMENT: FOR EACH PLAINTIFF PLEASE STATE: ~--.., ~.. (A) CURRENT PLACE OF EMPLOYMENT, POSITION AND LENGTH OF CURRENT EMPLOYMENT; AND (B) THE PLACE OF EMPLOYMENT AND POSITION AT THE TIME OF THE INCIDENT, IF DIFFERENT. 3. INJURIEs: DESCRIBE SEPARATELY EACH INJURY EACH PLAINTIFF SUSTAINED IN THE INCIDENT AND THE APPROXIMATE DATE ON WHICH EACH PLAINIlFF RECOVERED FROM EACH SUCH INJURY. ~. - -~- 4. HEALTH CARE PROVIDERS: IDENTIFY EACH BEAL'IH CARE PROVIDER WHO HAS EXAMINED, TREATED OR RENDERED _ ~VJ;CES TO EACH PLAINTIFF BECAUSE OF THIS INCIDENT, INCLUDING THE DATES OF SUCH '. SERVICES AND THE CHARGES FOR SAME. - 5. MEDICAL EXPENSES AND INSURANCE PAYMENTS: STATE THE TOTAL AMOUNT OF MEDICAL EXPENSES INCURRED BY EACH PLAINTIFF THAT RELATES TO THIS INCIDENT, 1HE AMOUNT COMPENSATED BY FIRsT PARTY BENEFITS, 1HE AMOUNT, IF ANY, SUBJECT TO A LIEN OF ANY SORT, THE IDEN'IITY (INCLUDING 1HE NAME, ADDRESS, AND POllCY NUMBER) OF ANY LlENHOLDER, AND THE AMOUNT CLAIMED TO BE RECOVERABLE AT TRIAL. ~. ... -~- 6. TERMlNATION OF MEDICAL SERVICES: WHEN AND BY WHOM WAS EACH PLAINfIFF LAST EXAMINED OR GIVEN MEDICAL . ~ ATIENllON FOR THE INJURIES RECEIVED IN THIS INCIDENT? ..-. - 7. CONTINUATION OF MEDICAL SERVICES: IF THE PLAINTIFF IS STILL BEING TREATED FOR THE INJURIES RECEIVED IN THIS INCIDENT, IDENTIFY BY WHOM AND STATE HOW FREQUENTLY SUCH TREATMENTS ARE BEING GIVEN NOW, THE NATURE OF THE TREATMENT BEING ADMINISTERED, AND]HE EXTENT TO WHICH TREATMENT WILL BE REQUIRED IN]HE FUTURE. " ~- 8. PRIOR CONDITIONS: ExPLAIN ALL PRIOR BEALm PROBLEMS OR INJURIES AND IDENTIFY THE BEALm CARE . - PROVJDERS WHO TREATED EACH PLA1NTIFF FOR mOSE INJURIES IN THE LAST SIX (6) YEARS. ". . 9. FAMILY PHYSICIAN: PLEASE STATE THE NAME AND ADDRESS OF YOUR FAMILY PHYSICIAN FOR THE LAST FIVE (5) YEARS. ~. 10. PRIOR OR SUBSEQUENT ACCIDENTS: IF BEFORE OR AFTER. THE INCIDENT WHICH IS THE SUBJECT OF THIS LAWSUIT, ANY . _ ~ WAS INVOLVED IN ANY OTHER INCIDENT INVOLVING INJURIES TO ANY PART OF THE - BODY, PLEASE STATE THE TYPE OF INCIDENT INVOLVED AND THE HEALTH CARE PROVIDERS WHO RENDERED TREATMENT FOR moSE INJURIES. 11. DISABILITY: DOES ANY I'LAINTIFF CONTEND THAT HE OR SHE HAS BEEN PERMANEN'ILY INJURED AS A RESULT OF THIS INCIDENT? IF SO, PLEASE DESCRIBE THE EXACT NA1URE OF THE ALLEGED INJURY AND THE IDENTITY OF ANY REALm CARE PROVIDER WHO HAS INFORMED ANY PLAINTIFF THAT THE INJURY IS PERMANENT. ~ 12. Loss OF EARNINGS: Is ANY PLAINTIFF MAKING A CLAIM FOR LOSS OF EARNINGS OR IMPAIRMENT OF _ E~G CAPACITY BECAUSE OF THIS INCIDENT? IF SO, THEN PLEASE PROVIDE THE . FOLLOWING INFORMATION OF EACH: . (A) EACH EMPLOYER, JOB TITLE AND DESCRIPTION OF Du.rms AS WELL AS MONTHLY OR WEEKLY RATE OF PAY AT THE TIME OF THIS INCIDENT; (B) THE INCLUSIVE DATES DURING WHICH ANY PLAINTIFF ALLEGES HE OR SHE WAS UNABLE TO WORK AS A RESULT OF THIS INCIDENT AND THE TOTAL AMOUNT OF EARNINGS AND PLAINTIFF LOST BECAUSE OF THIS ABSENCE; (C) THE SOURCE AND AMOUNT OF ANY WAGES OR SALARY RECEIVED SINCE THIS INCIDENT; AND (D) THE DATE ON WHICH ANY PLAINTIFF FIRST REI1JRNED TO WORK FOLLOWING THE INCIDENT AND EACH EMPLOYER FOR WHOM ANY PLAINTIFF HAS WORKED SINCE THE INCIDENT WITH INCLUSIVE DATES OF EMPLOYMENT, EACH JOB TIlLE ANY PLAINTIFF HAS HELD AND EACH MONTHLY OR WEEKLY RATE OF PAY WHICH ANY PLAINTIFF HAS RECEIVED FROM THE DATE OF STARTING WORK AGAIN AFTER THIS INCIDENT UNTIL THE PRESENT TIME. ~ 13. IMPAIRED EARNING CAPACITY: Is ANY PLAINTIFF MAKING A CLAIM FOR IMPAIRED EARNING CAPACITY BECAUSE OF _ 'fI!IS INCIDENT? IF YES, PLEASE STATE THE AC'lUAL VALUE OF ANY l'LAINTIFF's IMPAIRED . -.... ... EARNING CAPACITY, SETI1NG OUT THE MANNER IN WHICH SAm VALUE WAS CALCULATED, AND BY WHOM. , 14. STATEMENTS: HAS ANY PLAINTIFF OR ANYONE ACTING ON ANY PLAINTIFF's BEHALF OBTAINED ANY STATEMENTS, REPORTS, MEMORANDUM OR TESTIMONY IN ANY FORM FROM ANY PERSON RELATING TO THIS INCIDENT. IF SO, PLEASE IDENTIFY FROM WHOM THE STATEMENT WAS TAKEN, THE DATE OF THE STATEMENT AND PROVIDE A COPY IN ANSWER TO THIS INTERROGATORY. -, ~. - ~.- 15. WITNESSES: IDENTIFY ANY WITNESS WHO HAS ANY KNOWLEDGE OF OR INFORMATION AS TO THE _ FACIS PERTAINING TO nus INCIDENT. ALso PROVIDE A SUMMARY OF THE INFORMATION . ~- ,- '< , WHICH EACH WITNESS HAS CONCERNING TIiIs INCIDENT. ." 16. EXPERT WITNESSES: IDENTIFY ALL EXPERTS WHO ANY PLAINTIFF EXPECTS TO CALL AT THE TRIAL OF nus CASE, AND PURSUANT TO PA R.C.P. 4003.S(A)(1)(B), STATE THE SUBSTANCE OF THE FACTS AND OPINIONS TO WHICH ANY PLAINTIFF'S EXPERT WILL TESTIFY AND THE SUMMARY OF THE GROUNDS FOR EACH OPINION. THE FACIS, OPINIONS AND GROUNDS OF THE EXPERT MAY BE CONTAINED IN AN EXPERT REPORT WHICH MAY BE A'ITACHED. SUCH REPORT OR ANSWER TO nus INTERROGATORY SHOULD BE SIGNED BY ANY PLAINTIFF'S EXPERT. . . ~ - -..- 17. PHOTOGRAPHS, DOCUMENTS AND THINGs: IF ANY l'LAINTIFF, OR ANYONE ACI'ING ON ANY PLAINTIFF'S BEHALF, HAS OR KNOWS .--:- OF,AN,Y PHOTOGRAPHS, DIAGRAMS, ME~, SURVEYS OR OTHER DESCRIPTIONS - REGARDING OR RELATING IN ANY WAY TO THIS INCIDENT, PLEASE IDENTIFY THOSE ITEMS. IN LIEU OF ANSWERING THE FOREGOING INTERROGATORY, COPIES OF ANY SUCH ITEMS l\IA Y BE PROVIDED AS ATTACHMENT TO THESE ANSWERS. 18. RELATED LAWSUITS: PLEASE IDENTIFY BY CAPTION, DOCKET NUMBER AND COURT ANY OTHER LAWSUITS ARISING FROM THIS INCIDENT OR RELATING TO 1HE INJURIES CLAIMED BY THE PLAINTIFF IN THIS SUIT, OR IN WHICH ANY PLAINTIFF HAS BEEN INVOLVED. 19. PLEASE IDENTIFY ANY OTHER CLAIMS FILED OR DEMANDS MADE BY ANY PLAINTIFF AGAINSt ANYONE OTHER THAN DEFENDANTS IN 1IDS ACTION FOR ANY DAMAGES OR INJURIES ARISING OUT OF OR RELATED TO THIS INCIDENT. ~- 20. PRIOR CONVICTIONS: HAVE YOU BEEN CONVIC'IED OR PLED GUILTY TO ANY CRIME WITHIN THE PAST TEN _ (10)u:ARS. IF SO, PLEASE STATE FOR EAqI CONVICIlON OR PLEA, THE OFFENSE CHARGED, ". THE COURT CAPTION AND DOCKET, AND THE DISPOSTIlON AND SENTENCE. 21. LIENS: WOULD ANY SEITLEMENT OR VERDICT SECURED BY YOU IN THIS MATI'ER BE SUBJECT TO ANY FEDERAL LIEN, STATE LIEN, FELA LIEN, WORKMEN'S COMPENSATION LIEN, OR ANY SIMILAR OR OTHER LIEN? IF SO, IDENTIFY THE HOLDER OF THE LIEN, THE AMOUNT OF THE LIEN, THE COSTS OF EXPENSES COVERED BY THE LIEN, AND THE CIRCUMSTANCE UNDER WHICH YOU ARE OR MIGHT BE OBLIGATED TO SATISFY THE LIEN. Respectfully submitted, LAW ~1'ftF ITi& iT, By, iN< (I) DOriald R. Dorer, Esquire Attorney for Defendants Identification No. 39126 -, -~ Date: October 2. 2001 OIHB..()()137; LAW OFFICES OF JACOBS & SABA . -::-:- 214 S-enate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attome s for Defendants ANGELA DIANNE ZIMMERMAN, PLA1NTIFF IN THE COURT OF COMMON PLEAS CUMBERLANDCOUNTY,PENNSYLVANlA VS. No. 2001-4744 DONALD E. DONOVAN AND JUDYK. DONOVAN, DEFENDANTS CIVIL ACTION - LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Interro2atories of Defendants Addressed to the Plaintiff to be served by regular first class mail upon: Date: October 2.2001 Marcus A McKnight, ill Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 J}I~ /1. A? . i llL/ :I I~I /\.;/ Donald R. Dorer, Esquire Attorney for Defendants ~. ~ - ,- Exhibit E ........-. JACOBS & SABA (NOT A PARTNERSHIP) 214 SENATE AVENUE SUITE 503 CAMP HILL, P A 17011 (717) 731-0988 FAX: (717)731-0987 TDD (800) 622-2421 4 _.- DolULD-R. DoRER . ':... GIiA.RD i..'RICKARDS- ArroR..'iEYS -CERTIFIED CIvIL TRIAL ADVOCATt: NATIONAL BOARD OF TRIAL ADVOCACY DENISE Eo KAUFFMA.'i. LmGATION PARALEGAL REFER To: 0IHB-00132 , December 13, 2001 Marcus A. McKnight, ill, Esquire Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 Re: Angela Dianne Zimmerman vs, Donald E. Donovan and Judy K. Donovan Cumberland County: No. 2001-4744 Dear Mr, McKnight, .'. I served Interrogatories and Request for Production of Documents directed to Plaintiffs under cover of my letter of October 2,2001. To date, I have received neither responses, nor objections, concerning these reasonable and appropriate discovery requests. Kindly advise as to when I may expect responses to our discovery requests in this matter so that we may move forward with the completion of this litigation. If I do not receive these responses by the end of January, 2002, I have been-instructed to me an appropriate Motion to Compel with the Court. Thank you for your attention and anticipated courtesies. ,~ DRD:dek Employees ofNationwi~ Mutual Insurance Company Bethlehem' ~ Hill- Caoonsburg' DoyIestown . Qrecmburg' Media' Nonistown. PIilladelphia' Wanondal. - Wilkes Barre Exhibit F . LAW OFFICES . IRWIN McKNIGHT & HUGHES ROGER B. IRWIN MARCUS A. McKNIGHT. J/[ JAMES D. HUGHES REBECCA R. HUGHES MXRxD.SCHWARTZ DOUGLAS G. MILLER WEST POMFRET PROFESSIONAL BUILDING 60 WEST POMFRET STREET CARLISLE, PENNSYL VANIA 17013-3222 17171 249,2353 FAX 1717) 249-6354 ~MAft:IMHLAW@SUPERNET.COM HAROLD S. IRWIN (/925./977) HAROLDS./RW1N,JR. (1954./986) IRWIN, IRWIN &: IRWIN (/956-1986) IRWIN. IRWIN & McKNIGHT (/986-/994) IRWIN. McKNIGHT &: HUGHES (/994- ) December 19, 2001 Donald R. Dorer, Esquire Jacobs & Saba 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Re: Angela Dianne Zimmerman v. Donald E. Donovan and Judy K. Donovan 2001-4744 Dear Mr. Dorer: Thank you for your letter dated December 13, 2001. I met with my client and I believe she will be able to complete the Interrogatories in January 2002. I will forward them to you as soon as I have them completed. Very truly yours, MAMfmln cc: Ms. Angela Dianne Zimmerman '1..\\\\\ \)t.\' C2, \\ ...r--- OIHB;OOI32. . . LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorne s for Defendants ANGELA DIANNE ZIMMERMAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2001-4744 DONALDE.DoNOVANAND JUDY K. DONOVAN, DEFENDANTS CIVIL ACTION - LAw JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Donald R Dorer, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Petition of Defendants to ComDel Answers to Interrogatories and Reauest for Production of Documents Addressed to the Plaintiff to be served by regular first class mail upon: Marcus A McKnight, ill Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 Date: March 18. 2002 D R. Dorer, Esquire Attorney for Defendants Un' , (- (' r~ >- Q:- L_ e) -=:. is C""; ( ~>~ c; 1 Cj . . OIHl3.;Q0132' Ift~~ 2 0 2002 )> , . > LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attome s for Defendants ANGELA DIANNE ZIMMERMAN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 2001-4744 DONALD E. DONOVAN AND JUDY K. DONOVAN, DEFENDANTS CIVIL ACTION - LAW JURY TRIAL DEMANDED RULE TO SHOW CAUSE AND NOW, this z'2? J day of Vvt.v c.t . 2002, upon consideration of the within Petition of Defendants to Compel Answers to Interrogatories and Request for Production of Documents Addressed to the Plaintiff, a Rule is hereby issued upon the Plaintiff to show cause, if any she may have, as to why the relief requested in said Petition should not be granted". ..itl. the PlaimHfbeiflg eeRljlelled te pr~'ide hIli and eORljllete reSflQIIEIlS te tftt InteHagateries aaQ~ R.quest fer Pradl:letiofi efDeet:lnteftts Addh...."d tu the Plaintiff vv;thin tl';.ty (30) days,. Rule Returnable within twenty (20) days upon service hereof , ~ ~::ofl~5 -to " ,.,WI. .boreR ~MeK(\\~\j[ BY TIlE COURT: J. . , . J . . , . \ ..,.. . '. ifli~Vfi1)\SNN3d ,UNnC<) ncV'i'.j;;]\"l(iCJ '1'1 :[ Hd <;2 U~W 2:0 ::10 CERrrFlCA1'E PREREQUISI1'E TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANGELA DIANNE ZIMMERMAN COURT OF COMMON PLEAS TERM, -VS- DONALD E. DONOVAN AND JUDY K. DONOVAN CASE NO: 2001-4744 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, 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: 10/23/2002 ttf~ep>>~ DONALD R. DORER, ESQ. Attorney for DEFENDANT DEll-368293 07355 -L 0 1 COMMONWEALTH OF PENNSYLVANZA COUNTY OF CUMBERLAND IN THE HATTER OF: ANGELA DIANNE ZIMMERMAN COURT OF COMMON PLEAS -VS- TERM, DONALD E. DONOVAN AND JUDY K. DONOVAN CASE NO: 2001-4744 NOTICE OP IN'l'EN'l' TO SERVE A StmPOENA TO PRODUCE ~S AIm 1'JfINGS POR DISCOVERY PURStJAIrii TO RULE 4009.21 HlDICAL RECORDS HlDICAL RECORDS HlDICAL RECORDS HlDICAL RECORDS HlDICAL RECORDS HOLY SPIRIT HOSPITAL GIWIAH HlDICAL CLINIC PElftPS WOOD PHYSICAL THERAPY CURRu , BECHT ORAL APPALACHIAN OR'l'BOPEDIC CENTER TO: MARCUS A. MCNIGHT. III. ESQ. MCS on behalf of DONALD R. DORER. 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 UDdersigned 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. C~lete copies of any reproduced records may be ordered at your expense by c~leting the attached cOUDsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/03/2002 KeS on behalf of CC: DONALD R. DORER. ESQ. ANGELA ALOISE DONALD R. DORER. ESQ. Attorney for DEFENDANT - 01HB-00132 Any questions regarding this matter. contact TIlE MCS GROOP INC. 1601 MARKET STREET #800 PHILADELPHIA. PA 19103 (215) 246-0900 DE02-202083 0 7355 - C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ANGELA DIANNE ZIMMERMAN VS DONALD E.CONOVAN & JUDy K.DONOVAN File No. 2001-4744 TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL (Name of Penon or Entity) SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the folloWing doc:uments or things: SEE ATTACHED ~ MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Adctre..) at You may deliver or mail legible copies of the doc:uments 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. I( YO' f~' .. prod~'" d~....................... by .hI..._....... _ (20) ..... -". _. ... ...., 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: nONAT.n R. DORER. ESO. ADDRESS: 214 SENATE AVE., STE 503 CAMP HILL,PA 17011 TELEPHONE: 71 ~-?L.I> OQOO SUPREME COURT lD ,: ATTORNEY FOR: nFFFNnAN'T' DATE: .QtiT ':J :l ;:) /""v} ~ . ... Prothonotuy/Clerk. Qv ~-,# P '~D?~'L r- Oe ty '-- Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 N. 21ST STREET CAMP HILL, P A 17011 RE: 7355 ANGELA DIANNE ZIMMERMAN Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject: ANGELA DIANNE ZIMMERMAN 29 EITERS ROAD, NEWBURG, PA 17240 Social Security #: 197-66-7655 Date of Birth: 03-25-1974 SUIO-401570 07355-LOl --~-._.._....~,. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANGELA DIANNE ZIMMERMAN COURT OF COMMON PLEAS TERM, -VS- DONALD E. DONOVAN AND JUDY K. DONOVAN CASE NO: 2001-4744 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, 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 on behalf of DATE: 10/23/2002 DONALD R. DORER, ESQ. Attorney for DEFENDANT DEll-368294 07355-LOZ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: ANGELA DIANNE ZIMMERMAN COURT OF COMMON PLEAS TERM. -VS- DONALD E. DONOVAN AND JUDy K. DONOVAN CASE NO: 2001-4744 NOTICE OF IN'l'ENT TO SERVE A SUBPOENA TO PRODUCE ~S AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 HOLY SPIRIT HOSPITAL GIAHAH MEDICAL CLINIC PENN'S WOOD PHYSICAL THERAPY CURRIE II HECHT ORAL APPALACHIAN ORTHOPEDIC cum HEDlCAL RECORDS MEDICAL RECORDS HEDlCAL RECORDS HEDICAL RECORDS HEDlCAL RECORDS TO: MARCUS A. MCNIGHT, III, ESQ. MCS on behalf of DONALD R. DORER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days fram 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. CClIIIplete copies of any reproduced records may be ordered at your expense by cOlllpleting the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 10/03/2002 MCS on behalf of CC: DONALD R. DORER, ESQ. ANGELA ALOISE DONALD R. DORER, ESQ. Attorney for DEFElmAiT - 01UB-00132 Any questions regarding this matter, contact l'HE MCS GROUP IRC. 1601 MARlET STREET #800 PHILADELPHIA, PA 19103 (21S) 246-0900 DE02-202083 07355 - C 0 2. ~--'-"""'-"-""'..'"'~"""--- COMMOl'lWEAL TH OF PENNSYL VANIA COUNTY OF CUMBERLAND ANGELA DIANNE ZIMMERMAN VS DONALD E.CONOVAN & JUDY K.DONOVAN File No. 2001-4744 TO: CUSTODIAN OF RECORDS FOR: GRAHAM MEDICAL CLINIC, P.C. (Name of Penon or Entity) SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Within twenty (20) days after service of this subjJoena, 'you are ordered by the court to produce the folloWing documents or things: SEE ATTACHED MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Addrn.) f . ~ at 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: nONAt.D R. DORER. ESO. ADDRESS: 214 SENATE AVE., STE 503 CAMP HILL.PA 17011 TELEPHONE: '1 'i-?L.';_OQOO SUPREME COURT ID ,: ATTORNEY FOR: nFFFl\TTUI\l'l' '-- D4IE: ~p:1 02.~ ~ ~~:l-. . Seal of the Court (Eff.7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GRAHAM MEDICAL CLINIC 100 SOUTH HIGH STREET NEWVILLE, P A 17241 RE: 7355 ANGELA DIANNE ZIMMERMAN 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: ANGELA DIANNE ZIMMERMAN 29 ETTERS ROAD, NEWBURG, PA 17240 Social Security #: 197-66-7655 Date of Birth: 03-25-1974 SUIO-401572 07355 -L02 CER1'IFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANGELA DIANNE ZIMMERMAN COURT OF COMMON PLEAS TERM, -VS- DONALD E. DONOVAN AND JUDY K. DONOVAN CASE NO: 2001-4744 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, 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: 10/23/2002 MCS on behalf of DONALD R. DORER, ESQ. Attorney for DEFENDANT DEll-368295 07355 - L 0 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER OF: COURT OF COHMON PLEAS ANGELA DIANNE ZIMMERMAN TERM, DONALD E. DONOVAN AND JUDY K. DONOVAN -VS- CASE NO: 2001-4744 NOTICE OF IN'l'EN'l' TO SERVE A SUBPOENA TO PRODUCE DOCtnmN'l'S AHD THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPIrAL GlWIAK MEDICAL CLIIfIC PElDf'S WOOD PHYSICAL THERAPY CUllRIE , HECHT ORAL APPALACHIAN OR1'80PIDIC CEIITER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: HARGUS A. MClfIGHT, III, ESQ. KeS on behalf of DONALD R. DORER., 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 KeS or by contacting our local KeS office. DATE: 10/03/2002 KeS on behalf of CC: DONALD R. DORER., ESQ. ANGELA ALOISE DONALD R. DORER., ESQ. Attorney for DEP'EImANT - 01HB-00132 Any questions regarding this matter, contact THE KeS GROUP INO. 1601 HARKET STREET #800 PHILADELPHIA, PA 19103 (21S) 246-0900 DE02-202083 0 7355 - C02 COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND ANGELA DIANNE ZIMMERMAN VS DONALD E.CONDVAN & JUDY K.DONOVAN FiJe No. 2001-4744 TO: CUSTODIAN OF RECORDS FOR: PENN'S WOOD PHYSICAL THERAPY (Nam.. o( P.......n or Entity) SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Within twenty (20) days after service of this subpoena. 'you are ordered by the Court to produce the folloWing doc:uments or things: SEE ATTACHED MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Addreu) f 4 ~ at You may deliver or mail legible copies of the doc:uments 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 doc:uments 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 TIlE REQUEST OF TIlE FOLLOWING PERSON: NAME: DONALD R. DORER. ESO. ADDRESS: 214 SENATE AVE., STE 503 CAMP HILL.PA 17011 TELEPHONE: ? 1" ?L..I>_OQ()() SUPREME COURT ID I: AlTORNEY FOR: nFFFNnAN'T' DATE: S2jLt ~~ ~^",~ , , Prothonotary/a~ Ovil 0" ~n-a.o 0 ~r.o/7'/"'J I '-- Seal of the Court (Eff, 7/97) EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PENN'S WOOD PHYSICAL THERAPY 425 STONEHEDGE DRIVE CARLISLE, P A 17013 RE: 7355 ANGELA DIANNE ZIMMERMAN 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: ANGELA DIANNE ZIMMERMAN 29 ETIERS ROAD, NEWBURG, PA 17240 Social Security #: 197-66-7655 Date of Birth: 03.25.1974 SUIO-401574 073SS-L03 _._,-."~.".......-.- CERTIFlCArE PREREQUISlrE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANGELA DIANNE ZIMMERMAN COURT OF COMMON PLEAS TERM, -VS- DONALD E. DONOVAN AND JUDY K. DONOVAN CASE NO: 2001-4744 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, 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 r~eived, 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: 10/23/2002 DONALD R. DORER, ESQ. Attorney for DEFENDANT DEll-368296 a 7355 -La 4 COMM:ONWEAL'rH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COHMON PLEAS ANGELA DIANNE ZIMMERMAN' TERM, -VS- CASE NO: 2001-4744 DONALD E. DONOVAN AND JUDy K. DONOVAN NO'1'ICE OF IH'l'EH'l' TO SERVE A SUBPOENA TO PRODUCE DOCOJIEH'l'S AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL GRAIWf MEDICAL CLIIfIC PENH'S WOOD PHYSICAL THERAPy CUIRIE r. BECHT ORAL APPALACHIAN ORTHOPEDIC CElft'ER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: HARCUS A. KCRIGHT, III, ESQ. KCS on behalf of DONALD R. DOUR, 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 ezpense by completing the attached counsel card and returning same to KCS or by contacting our local KCS office. DATE: 10/03/2002 KCS on behalf of CC: DONALD R. DOUR, ESQ. ANGELA ALOISE DONALD R. DOUR, ESQ. Attorney for DEFENDANT - OlHB-OOI32 Any questions regarding this matter, contact THE KCS GROuP IRC. 1601 MARlET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-202083 07355-C02 COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND ANGELA DIANNE ZIMMERMAN VS DONALD E.CONOVAN & JUDY K.DONOVAN FiJe No. 2001-4744 TO: CUSTODIAN OF RECORDS FOR: CURRIE & HECHT Y~ILLOFACIAL SURGEONS, P.C. (Name of Penon Dr Entity) SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Within twenty (20) days after service of this subpoena. J'ou are ordered by the court to produce the folloWing documents or things: SEE ATTACHED MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Ad.u....) f . ~ at 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: DONALD R. DORER. ESO. ADDRESS: 214 SENATE AVE., STE 503 CAMP HILL.PA 17011 TELEPHONE: ? 1 ~-?L..I>_()Q()() SUPREME COURT ID II: AlTORNEY FOR: nFFFlIlT1A N'T' QATE: np:i- :li ,.J ''''M ~ , , Protltonot.uy/Clerk. a,,' ion ~n,:; D {:) ?:1-f A"Y, r- Depu ~ c......... Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CURRIE & HECHT ORAL AND MAXILLOFACIAL SURGEON 338 ALEXANDER SPRING CARLILSLE, PA 17013 RE: 7355 ANGELA DIANNE ZIMMERMAN 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: ANGELA DIANNE ZIMMERMAN 29 EITERS ROAD, NEWBURG, PA 17240 Social Security #: 197.66.7655 Date of Birth: 03-25-1974 SUIO-401576 073SS-L04 -~----._--,--_..,......~ CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: ANGELA DIANNE ZIMMERMAN COURT OF COMMON PLEAS TERM, -VS- DONALD E. DONOVAN AND JUDY K. DONOVAN CASE NO: 2001-4744 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of DONALD R. DORER, 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 on behalf of DATE: 10/23/2002 DONALD R. DORER, ESQ. Attorney for DEFENDANT DEll-368297 07355-L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS ANGELA DIANNE ZIMMERMAN TERM, DONALD E. DONOVAN AND JUDY K. DONOVAN -VS- CASE NO: 2001-4744 NOTICE OF IN'l'ENT TO SERVE A SUBPOENA TO PRODUCE DOCUJlENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HOLY SPIRIT HOSPITAL GRAHAM MEDICAL CLINIC PENN'S WOOD PHYSICAL THERAPy CURRIE IE HECHT ORAL APPALACHIAN ORTHOPEDIC CENTER MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS MEDICAL RECORDS TO: MARCUS A. KeNIGHT. III. ESQ. KeS on behalf of DONALD R. DORER. 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 KeS or by contacting our local KeS office. DATE: 10/03/2002 KeS on behalf of CC: DONALD R. DORER, ESQ. ANGELA ALOISE DONALD R. DORER, ESQ. Attorney for DEFENDANT - 01HB-00132 Any questions regarding this matter, contact THE KeS GROUP INC. 1601 HARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-202083 0 73 .s .s - C 0 2. COMMONWEALTH OF PENNSn VANIA COUNTY OF CUMBERLAND ANGELA DIANNE ZIMMERMAN VS DONALD E.CONOVAN & JUDY K.DONOVAN File No. 2001-4744 TO: CUSTODIAN OF RECORDS FOR: SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Within twenty (20) days after service of this subpoena. 'you are ordered by the court to produce the following documents or things: SEE ATTACHED f. ~ PALACHIAN ORTHOPAEDIC CENTER , LTD. (Name of Person Dr Entity) at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Addreso) 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: DONALD R. DORER. ESO. ADDRESS: 214 SENATE AVE., STE 503 CAMP HILL.PA 17011 TELEPHONE: ? 1 ~-?L.h ()Q()() SUPREME COURT ID I: ATTORNEY FOR: nFFFNnANT '-- DATE: 5kfL1 :<2 ..J~:l. I Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: APPALACHIAN ORTHOPEDIC CENTER 1 DUNWOODY DR. CARLISLE, P A 17013 RE: 7355 ANGELA DIANNE ZIMMERMAN 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: ANGElA DIANNE ZIMMERMAN 29 ETTERS ROAD, NEWBURG, PA 17240 Social Security #: 197-66-7655 Date of Birth: 03-25-1974 SUIO-401578 07355-L05 -,,: r'-:,l Z :. j .,' o c: " -< , , -) -.; '.~."l ~. ", ".) ():) -< File No.: QIHB-00132 PRAECIPE FOR LISTING CASE ]4'OR TRIAL (Must be typewritten and submitted in dlllplicate.) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case (check one): ( x) for JURY trial at the next term of civil court. ( ) for trial without a jury . CAPTION OF CASE: (Entire Caption Must Be Stated In Full) (Check One) ( ) Assumpsit Angela Dianne Zimmerman, ( ) Trespass Plaintiff ( x) Trespass (Motor Vehicle) vs. ( ) (Other) Donald E. Donovan and Judy K. Donovan, Defendants The trial list will be called on June 10. 2003 Trials commence on Julv 7. 2003 Pre-trials will be held on June 18. 2003 (Briefs are due 5 days before pre-trials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel. pursuant to local Rule 214-1.) No. 2001-4744 Civil 20 QL Indicate the attorney who will try case for the party who files this praecipe: Donald R. Dorer. Esquire. Attorney for Defendants; Jacobs & Saba. 214 Senate Avenue. Suite 503. Camp Hill. Pennsylvania. 17011: (717) 731-0988. Indicate trial counsel for other parties if known: Marcus A. McKnight., III. Esquire. Attornev for Plaintiff; Irwin McKni ht & Hu 8, 0 West Porn e Street Carlisle Penns lvania 17109; (717) 249-2353 This case is ready fQ t l. / / ,/ / / Signed: Print Name: Donald R. Dorer. Esquire Attorney for: Defendants Date: March 18. 2003 01HB-00132 LAW OFFICES OF JACOBS & SABA 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Angela Dianne Zimmerman, ase No.: 2001..4744 Plaintiff Y TRIAL DEMANDED vs. Donald E. Donovan and Judy K. Donovan, Defendants CERTIFICATE OF SERVICl~ Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Praecipe for Listing Case for Trial to be served by regular first class mail upon: Marcus A. McKnight, III Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 Date: March 18, 2003 /l l' onald R. Dorer, Esquire Attorney for Defendants o c <~ -r ~ t.~~ rflrr. 2: ::- -:;.;- ," v)> ~ ~(,~, c- (, PC: 2..:- =< r: .) ~,Ci -'"r '"') ,) (n 5. Angela Dianne Zimmerman : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V Donald E, Donovan and Judy K. Donovan : NO, 01.4744 CIVIL TERM ORDER OF COURT AND NOW, June 10, 2003, the above-captioned matter is continued by agreement of counsel, from the July 7, 2003 trial term, at the plaintiff s request. Counsel is directed to relist the case when ready, By the Court, Lcus A. McKnight, III, Esquire For the Plaintiff ~onald R. Dorer, Esquire For the Defendant Court Administrator . L~ ) I'l~ Ol. - J ~..a:3 :ld . ,1 VINV^1\S!\JN3d I 'Nln~~. n .r,) '-"'"pn" 1\1./ i 1".),1 .", :"-:1:''],,\ V " '1'" I . .,J,' . ",-I AI:!VW;"" :r~~ JI +: :"': _...,...d..I..'\., . , ....If ~rl I fiI lo,. ,,; ::JD File No.: OI~B-00132 PRAECIPE FOR RE-LISTING CASE FOR TRIAL (Must be typewritten and submitted ill duplicate.) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case (check one): ( x) for JURY trial at the next term of civil court. ( ) for trial without a jury, CAPTION OF CASE: (Entire Caption Must Be Stated In Full) (Check One) ( ) Asswnpsit Angela Dianne Zimmerman, ( ) Trespass Plaintiff ( x) Trespass (Motor Vehicle) vs. ( ) (Other) Donald E. Donovan and Judy K. Donovan, Defendants The trial list will be called on August 12. 2003 Trials commence on Seotember 8. 2003 Pre-trials will be held on AUl!Ust 20. 2003 (Briefs are due S days before pre-trials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214-1.) No. 2001-4744 Civil 20 QL Indicate the attorney who will try case for the party who files this praecipe: Donald R. Dorer. Esquire. Attomev for Defendants: Jacobs & Associates. 214 Senate Avenue. Suite 503. Camp Hill. Pennsvlvania. 17011; (717) 731- 0988, Indicate trial counsel for other parties if ow: Marcus A. McKnil!ht. III. Esquire. Attomev for Plaintiff' Irwin McKni ht & hes 60 est 0 et Street Carlisle Pennsvlvania 17109; (717) 249-2353 This case is ready for tri Signed: Print Name: Donald R. Dorer. Esquire Attorney for: Defendants Date: June 16. 2003 01HB-00132 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMP HILL, P A 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Angela Dianne Zimmerman, Plaintiff Y TRIAL DEMANDED vs, Donald E, Donovan and Judy K, Donovan, Defendants CERTIFICATE OF SERVIC]~ Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Praecipe for Re- Listing Case for Trial to be served by regular first class mail upon: Marcus A. McKnight, III Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, P A 17013 Date: June 16,2003 t(" Donald R.lDorer, Esquire Attorney for Defendants o ~ \:}!'.!-' !JJi:., ~i:l C~ r:'l < ~(-< 5-:; ~~~ ~ . () oil C~) ,...:,-, :n tv ~j] -< PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in dupllicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: (Check one) x for JURY trial at the next term of Givil court. for trial without a jury. --..---.-.---....--...---.------.-------------------..-~-_.--_.----_..------_._.-...--_.._-------_.....--_....--....---....--....---.....--....---....---..---..... CAPTION OF CASE (entire caption must be stated in full) (check one) Assumpsit ANGELA DIANNE ZIMMERMAN, Trespass (X) Trespass (Motor Vehicle) ) (other) (Plaintiff) vs, DONALD E. DONOVAN and JUDY K. DONOVAN, The trial list will be called on Ortobpr 7. 2003 and Trials comme:nce on November 3. 2003 (Defendant) Pretrials will be held on October 15. 2003 (Briefs are due 5 days before pretrials,) vs. (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214-1.) No, Civlil 2001-4744 19__ Indicate the attorney who will try case for the party who files this praecipe: M~rrl1R A. McKnight, Ill, Esq., 60 West Pomfret Strept" Carlisle, PA 17013 Indicate trial counsel for other parties if known: Donald R. Dorer, Esquire, 214 C::&>n~h:. Avp-nue. Camp Hill, PA 17011 This case is ready for trial. Signed: Print Name: ~ Dale: Au"ust 12, 2003 Attorney for: -K;Lainti!f___. () 0 0 c c-., -, , :;?" ~ "1J ('1 ----I rn L!~ ~-i z: Z [ (J) P',) -< C: ,,- <- -'0 j;: ~ Z , > C '.' .. C ~-'" ,,'~-- :::> ~ :~ :;:t CO -< 10. Angela Dianne Zimmerman : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V Donald E, Donovan and Judy K. Donovan : NO, 01-4744 CIVIL TERM ORDER OF COURT AND NOW, August 12, 2003, the above-captioned matter is continued by agreement of counsel, from the September 8, 2003 trial term, at the plaintiff's request. Counsel is directed to relist the case when ready, By the Court, /1vfarcus A. McKnight, III, Esquire For the Plaintiff Court Administrator >~ RKs O~- J<g-~ ;Donald R. Dorer, Esquire For the Defendant :ld " , " , , , "",; :.... , .'7 t'(J '0 f' . ~ . , ',' Vlt,:vril,lg\JN3d ,. I-'~1.'.~1':'_"'~,'\!nC) \lJ ,': s~ I 8~rJ [0 1~,bV_\..C,,, . ' . L :10 ;JJ.~UO-Uj Pi]: No.: OIHB-00132 PRAECIPE FOR RELISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate.) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case (check one): ( x) for JURY trial at the next term of civil court. ( ) for trial without a jury, CAPTION OF CASE: (Entire Caption Must Be Stated In Full) (Check One) ( ) Assumpsit Angela Dianne Zimmerman, ( ) Trespass Plaintiff ( x) Trespass (Motor Vehicle) vs, ( ) (Other) Donald E, Donovan and Judy K. Donovan, Defendants The trialli"t will be called on October 7. 2003 Trials commence on November 3. 2003 Pre-trials will be held on October 15. 2003 (Briefs are due 5 days before pre-trials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel. pursuant to local Rule 214-1.) No, 2001-4744 Civil 20.Ql Indicate the attorney who will try case for the party who files this praecipe: Donald R. Dorer. EsQuire. Attornev for Defendants' Jacobs & Associates 214 enate Avenue Suite 503 Camo Hill. Pennsvlvania. 17011; (717) 731- 0988, Indicate trial counsel for other p rti s if known: Marcus A. McKnililit. III. EsQuire. Attornev for Plaintiff'lrwin M -, ht & Hu hes est Pomfret Street Carlisle Pennsvlvania 17109; (717) 249-2353 This case i I eady fo tr al. / I Signed: Print Name: Donald R, Dorer. ESQuire Attorney for: Defendants Date: Sentember 5.2003 0IHB-00132 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMPHILL,PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Angela Dianne Zimmerman, ase No,: 2001-4744 Plaintiff vs, Y TRIAL DEMANDED Donald E, Donovan and Judy K, Donovan, Defendants CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Praecipe for Re- Listing Case for Trial to be served by regular first class mail upon: Marcus A. McKnight, III Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013 Date: September 5, 2003 15; ,1) Donald R. Dorer, Esquire Attorney for Defendants [) C <' 11fT zC ~~-; !;:C: "">(" 2::('<. )>c..: ~ c:.~~ L..) C) ~q :/') -'1 ""'1 I OJ :..> '1 <) -(f' .~ ' ~ :>) <::0 , OlHB-00132 LAW OFFICES OF JACOBS & SABA 214 SENATE AVENUE, SUITE 503 CAMP HILL, P A 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Angela Dianne Zimmerman, Case No.: 2001-4744 Plaintiff fJURY TRIAL DEMMl)ED vs. Donald E, Donovan and Judy K. Donovan, Defendants ; STIPULATION OF COUNSEL It is hereby stipulated between counsel for the parties hereto that the Defendant, Judy K. Donovan, be dismissed from this action, and the caption of the case be revised to read as follows: Angela Dianne Zimmerman, Plaintiff vs, Donald E Donovan, Defendant. It is further stipulated that the Defendant, Donald E, Donovan, is solely negligent in the occurrence of the accident described in Plaintiff's Complaint, and that the only issue to be contested by Defendant is the amount of damages, if any, to which Plaintiff may be entitled to recover at time of hearing or trial. IRWIN, MCKNIGHT & By: Don ' Dorer, Esqu re Attorney for Defendants Identification Number: 39126 Date611J,. ~ ~ ~ " lCL J L J\:l Date: ~ / 01HB-00132 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMPHILL,PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Angela Dianne Zimmerman, ase No.: 2001-4744 Plaintiff Y 1RIAL DEMANDED vs, Donald E. Donovan and Judy K. Donovan, Defendants CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the: attorney for the Defendants herein, and that he caused a true and correct copy ofthe attached Stipulation of Counsel to be served by regular first class mail upon: Marcus A, McKnight, III Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, P A 17013 Date: September 5, 2003 ( Dona R. Dorer, Esquire Attorney for Defendants (') ~~ ""'Or;,,', n'li: ;~:;t L_ t,~ Cf) :~ ~c; ..;:;:- ~f~ z -;J -, o (,.~) 0.., ,." ""0 I 'D C) 'T1 ";-j -T.~i ,II :;,.;::::; -n ..... :-':) . -'""1 c:- ;Cj >~. r~1l --.-:1 'b- "'0 =< ''.) "" SEP 1 1 Z003 ~ 0IHB-00132 LAW OFFICES OF JACOBS & SABA 214 SENATE AVENUE, SUITE 503 CAMPHILL,PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA Angela Dianne Zimmerman, ase No.: 2001-4744 Plaintiff vs, Donald E. DonovaD and Judy K. Donovan, Defendants ORDER OF COURT AND NOW this ~ day of , 2003, upon consideration of the within Stipulation of Counsel, is hereby ordered and directed that the Defendant, Judy K, Donovan, be dismissed as a party in the albove action. It is further noted for the record that the Defendant, Donald E, Donovan has stipulated generally as to his sole negligence in the motor vehicle accident described in Plaintiffs Complaint, ~ ~~6?> q' \ o BY THE COURT: , , .h , VINVAlASNN3d t\lNr':[(" rl; ";-n1):Jr~,!\Jn8 ~u :2 l1d 91 d3S SO f}jV,lC,i._"J, :;. ~o 38\j~IJ-(j::~11U i ., ! ., , , 01HB-00132 LAW OFFICES OF JACOBS & SABA 214 SENATE AVENUE, SUITE 503 CAMP HILL, P A 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Angela Dianne Zimmerman, Case No.: 2001-4744 Plaintiff JURY TRIAL DEMAt'\'DED vs. Donald E, Donovan and Judy K, Donovan, Defendants STIPULATION OF COUNSEL It is hereby stipulated between counsel for the parties hereto that the Defendant, Judy K. Donovan, be dismissed from this action, and the caption of the case be revised to read as follows: Angela Dianne Zimmerman, Plaintiff vs. Donald E, Donovan, Defendant. It is further stipulated that the Defendant, Donald E, Donovan, is solely negligent in the occurrence of the accident described in Plaintiff's Complaint, and that the only issue to be contested by Defendant is the amount of damages, if any, to which Plaintiff may be entitled to recover at time of hearing or trial. I. IRWIN, MCKNIGHT & By: Don . Dorer, Esqu re Attorney for Defendants Identification Number: 39126 Date611-, L. ~ ..7d-J ~ \~UL:> LJ~J Date: cs- I / OlHB-00132 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMP HILL, P A 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Y TRIAL DEMANDED Angela Dianne Zimmerman, vs. Donald E. Donovan and Judy K, Donovan, Defendants CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of the attached Stipulation of Counsel to be served by regular first class mail upon: Marcus A, McKnight, III Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, P A 17013 Date: September 5, 2003 Dona R. Dorer, Esquire Attorney for Defendants '-, (') Cl C..J ~ (,.) '.n ~". U) ":-::1 ""UI,T; ''Tl -,"I) Mlfi -''0 Z ~j" , I I 7[ 0 W~:". CD ;:, r>'C ~~? _1.:..-i -r: ~" :~~". "- CJ ~i~~. ~. r- .'::jTl , ._, "'~ ;'-.) '",. -j ':0 -, -< " SEP 1 1 2003 ~ 01HB-00132 LAW OFFICES OF JACOBS & SABA 214 SENATE AVENUE, SUITE 503 CAMPHILL,PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Angela Dianne Zimmerman, ase No,: 2001-4744 Plaintiff vs, Donald E. Donovan and Judy K. Donovan, Defendants ORDER OF COURT AND NOW this l..i2.: day of , 2003, upon consideration of the within Stipulation of Counsel, is hereby ordered and directed that the Defendant, Judy K. Donovan, be dismissed as a party in the above action, It is further noted for the record that the Defendant, Donald E, Donovan has stipulated generally as to his sole negligence in the motor vehicle accident described in Plaintiffs Complaint. ~ ~~()?J q' \ o BY THE COURT: ~ ~ 1 'e /7 ( ==t' Jd~ . SA}: Olf'~r'1UO\~ t~ ~d YY/oo'>'fr 1n~bh ~\P '1) . 1 "f VINV/il,SNN3d AJj\J(y..t.~ n::,I':1.Y'~F:i~n8 ., ~..,; ,. . _'I , , tju :Z ILl 91 d3S SO . " !.H'fJJ., i.. :. ~O 38\ ~,~(}--'.~_'; -:,i l.-J 7, Angela Dianne Zimmerman : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V Donald E, Donovan and Judy K. Donovan : NO. 01-4744 CIVIL TERM ORDER OF COURT AND NOW, October 7,2003, counsel having failed to call the above case for trial, the case is stricken from the November 3, 2003 trial term, Counsel is directed to relist the case when ready. By the Court, ~arcus A. McKnight, 1II, Esquire For the Plaintiff ~nald R. Dorer, Esquire For the Defendant ld 7~ 1i)\~ JO'O~ -(}3 Court Administrator ifiN\~\1^SNN3d .([ \!t!(i,~', /'C~ """T;I~:ir:~i/~nJ L ~ :f: I,Jd 9- DO 80 A8VIC;<\...; , }'i.L jO 3~),:3::'C)--CJ,:n !d File No.: OIFlB-oom PRAECIPE FOR RE-LIS.TING CASE FOR TRIAL (Must be typewritten and submitted in duplicate.) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case (check one): ( x) for JURY trial at the next term of civil court, ( ) for trial without a jury, CAPTION OF CASE: (Entire Caption Must Be Stated In Full) (Check One) ( ) Assumpsit Angela Dianne Zimmerman, ( ) Trespass Plaintiff ( x) Trespass (Motor Vehicle) vs, ( ) (Other) Donald E, Donovan, Defendant The trial list will be called on December 9 2003 Trials commence on J anu 26 2004 Pre-trials will be held on December 17 2003 (Briefs are due 5 days before pre-trials.) (The party listing this case for trial shall provide forthwith a co y of the praecipe to all counsel, pursuant to local Rule 214~1.) Signed: Print Name Attorney for: Date: October 16. 2003 OIHB-00132 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMP HILL, P A 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA Angela Dianne Zimmerman, ase No,: 2001-4744 Plaintiff Y 1RIAL DEMANDED vs. Donald E. Donovan, Defendant CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy ofthe attached Praecipe for Re-Listing Case for Trial to be served by regular first class mail upon: Marcus A, McKnight, 1Il IlWin, McKnight & Hughes 60 West Pomfret Street Carlisle, P A 17013 Date: October 16, 2003 ;J[). . ... ( . l~ Donald R. Dorer, Esquire Attorney for Defendant (') (::' c) c: (.,.) .. , s: 0 ~fD C) .' mf"',".., ,--; 2::1 .r":'_ l 0')- ..... :S,. 1,-, .,-) .?J:( );(.. ;",-,) Os;; , :3 ',) :::.:::1 -, C) .< o IHB-OO 132 IN TIlE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Ange]a Dianne Zimmerman, Plaintiff Y TRIAL DEMANDED ase No,: 200]-4744 vs, Donald E. Donovan, Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Please mark the above-captioned case settled, discontinued and ended. By: Marcus A. Irwin, Mc ight 60 West Pomfr Carlisle, PA 1 Attorney I.D. Attorney for Plaintiff Date: _AL. .lu J .;1~ .;bo 3 OIHB-00132 LAW OFFICES OF JACOBS & ASSOCIATES 214 SENATE AVENUE, SUITE 503 CAMP HILL, P A 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Angela Dianne Zimmerman, ~ase No,: 2001-4744 Plaintiff vs. ~Y TRIAL DEMANDED Donald E, Donovan, Defendant CERTIFICATE OF SERVICE Donald R. Dorer, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of the attached Praecipe to Settle, Discontinue and End to be served by regular first class mail upon: Date: January 7. 2004 Marcus A. McKnight, III Irwin, McKnight & Hughes 60 West Pomfret Street 't;. ; .! , ; / / ! . VI , '. ~ Donald R. Dorer, Esquire Attorney for Defendant . . (") ....., 0 = C <.? -n z= .;:- <- --l -, ,'.--, -.- d-i ''-i-' :<>- f7i -n z:'~; :z: p= "'/,-- I -01'11 /-,. --]6 ,."'1 --^- ~. G) 0 '~~.: ::2-r, -0 _..~ ...... O~ _h ~,f~ c.;..2 ,~ -,-~ --;i' -" :'~I c-::, -~ 0> ::< VILLARI, BRANDES & KLINE, P.c. By Peter M. Villari, Esquire Theresa L. Giannone, Esquire Attorney LD. Nos.: 26875 and 77148 8 Tower Bridge, Suite 400 161 Washington Street Conshohocken, PA 19428 (610) 729-2900 ATTORNEYS FOR PLAJN77FFS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KRISTY KOELSCH and JOHN F. KOELSCH, h/w CIVIL ACTION - LAW Plaintiffs, Docket No: 04-4744 vs. JURY TRIAL DEMANDED ANGELA SOTO-HAMLIN, MD -and- SUSQUEHANNA BREAST CARE CENTER -and- HERITAGE MEDICAL GROUP, L.L.P. -and- SUSQUEHANNA SURGEONS, LTD, PC -and- STACY J. CASTALDI, DO -and- JUDITH A JOZEFIAK, M.D -and- HERITAGE DIAGNOSTIC CENTER -and- TRISTAN ASSOCIATES Defendants. CERTIFICATION OF SERVICE I, Theresa L. Giannone, Esquire, attorney for Plaintiff, hereby certifY that a true and correct copy of the Plaintiff's Amended Answers to Interrogatory No.8 of Defendants Stacy J. Castaldi, D.O., Judith A. Jozefiak and Tristan Associates, Inc. was served upon the below named counsel of record for Defendants by first -class mail, postage pre-paid and via facsimile on this dS day of February, 2005: Michael O. Pipa, Esquire Marshall, Oennehey, Warner, Coleman & Goggin 4200 Cmms Mills Road Suite B Harrisburg, PA 17112 Wiley P. Parker, Esquire Henry & Beaver, LLP 937 Willow Street PO Box 1140 Lebanon, PAl 7042-1140 Respectfully Submitted: Villari, Brandes & Kline, P.e. By: ~~~ Theresa L. Giannone, EsqUire .:'? -,I \ 0) ,/ (,.:~ f c.::' L) -