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Home My WebLink About09-6154IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiff(s) & Address(es) David Michael Hopkins 9356 Beowulf Circle Baltimore, MD 21237 VS. Case No. 0c/ - s / Civil Term Civil Action Defendant(s) & Address(es) Matthew J. Stefanic 4 Southern Cross Drive Boiling Springs, PA 17007 PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue summons in the above case Writ of Summons shall be issued and forwarded to AtLorney/Sheriff. (PlemAe Cirble choice) Date : Sign r of A mcy Print Name: Justi Stef anon Address: 1847 Center Street Camp Hill, PA 17011 Telephone #: (717) 761-6162 Supreme Court ID Number: 2 0 4 5 8 0 • • • • • WRIT OF SUMMONS TO: YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. Prothonotary/Clerk, Civil Divisio Date: d JL6f by Dep y 0 BLED-Oc i* CE OF THE PrOOT ONOTARY 2009 SEP 10 PM 3: 17 CUMBZ :i JL-,- '"iu (--U, l ifm PENNSYLVANIA qty s-r-e?? ?? ?, Sc) P C, h s ? f?7 AA ?,- 304/ 3.:l Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor QFF:fE OF *. ?E ?"ERIFF 2009 SEP IS Pi1 2: mi it clukc s' r David Michael Hopkins vs. Matthew J. Stefanic Case Number 2009-6154 SHERIFF'S RETURN OF SERVICE 09/14/2009 09:18 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 14, 2009 at 1218 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Matthew J. Stefanic, by making known unto Michael Stefanic, adult father of defendant at 4 Southern Cross Drive Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.84 SO ANSW September 15, 2009 R THOMAS KLINE, SHERIFF - - vl;?-- ty Sheriff 1555993177.1 LAW OFFICES OF TWANDA TURNER-HAWKI] JENNIFER L. LEVAN, ESQUI Identification No. 87575 Iron Run Corporate Center 7535 Windsor Drive, Suite 101 Allentown, PA 18195-1032 Telephone: (610) 398-5486 DAVID MICHAEL HO V. MATTHEW J. STEFANIC TO THE CLERK: Please enter my the above captioned case. ATTORNEY FOR DEFENDANT Matthew J. Stefanic COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 09-6154 ENTRY OF APPEARANCE on behalf of Defendant, Matthew J. Stefanic in reference to NNIFER L. LEVAN, ESQUIRE Attorney for Defendant Matthew J. Stefanic I hereby certify that I served a copy of this paper upon all other parties or their attorney of record by regular first class mail. RAM OF THE PAMMURY 2009 OCT -I PM 2* 54 CU 14:l is ?U UOUNTY PENNSYLVANIA. 1 555993 1 77.1 LAW OFFICES OF TWANDA TURNER-HAW JENNIFER L. LEVAN, ESQU Identification No. 87575 Iron Run Corporate Center 7535 Windsor Drive, Suite 101 Allentown, PA 18195-1032 Telephone: (610) 398-5486 DAVID MICHAEL H V. MATTHEW J. STEFANIC TO THE CLERK: Defendant, Matthew J. above captioned case. , Demands a Jury Trial of twelve (12) in reference to the C;??Z'-55 L. LEVAN, ESQ. Attorney for Defendant Matthew J. Stefanic I hereby certify that I ATTORNEY FOR DEFENDANT Matthew J. Stefanic COURT OF COMMON PLEAS OF CUMBERLAND COUNTY I NO. 09-6154 DEMAND FOR JURY TRIAL served a copy of this paper upon all other parties or their attorney of record by Regular "rst Class Mail. QF T EP Th CTRY 2009 OCT -I PM 2: 5 4 CUM6 #'lb %„ JL) WUN iY PENNSYLVANIA 1555993177.1 LAW OFFICES OF TWANDA TURNER-HAW ? JENNIFER L. LEVAN, ESQ IR Identification No. 87575 Iron Run Corporate Center 7535 Windsor Drive, Suite 10 -B Allentown, PA 18195-1032 Telephone: (610) 398-54861 1 DAVID MICHAEL HO V. MATTHEW J. STEFANIC TO THE PROTHONOTARY: Please enter a Rule twenty (20) days hereof or ATTORNEY FOR DEFENDANT Matthew J. Stefanic COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 09-6154 Plaintiff, David Michael Hopkins, to file a Civil Action within the entry of a Judgment of Non Pros. R L. LEVAN, ESQUIRE Attorney for Defendant Matthew J. Stefanic AND NOW, this upon Plaintiff to file a Civil entry of a Judgment of Non day of 2009, a Rule is hereby granted within twenty (20) days after service hereof or suffer the AOOTHO"TARY 6?:? OF nHEM?AFnr 2009 OCT - I FM 2: 54 CUMBEJ'.t? dL? k.:OIUNTY PENNSYLVANIA Our File No. 1555993177.1 LAW OFFICES OF TWANDA TURNER-HAWKINS JENNIFER L. LEVAN, ESQUIRE Identification No. 87575 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5486 DAVID MICHAEL HOPKINS V. MATTHEW J. STEFANIC ATTORNEY FOR DEFENDANT Matthew J. Stefanic COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 09-6154 CERTIFICATE OF SERVICE I, Jennifer L. LeVan, Esquire, hereby certify that a time-stamped copy of the Rule to File Complaint was served October 7, 2009 by United States Mail, First Class, postage prepaid, upon: Justin Stefanon, Esquire 1847 Center Street Camp Hill, PA 17011 FER L. LEVAN, ESQUIRE Attorney for Defendant Matthew J. Stefanic FILED -r=ICE OF Tttr r,11 -i ^} l9[lI n 2009 OCT 14 AN 6: 32 ANTHONY STEFANON, ESQUIRE I.D. #25497 JUSTIN STEFANON, ESQUIRE I.D. #204580 1847 Center Street Camp Hill, PA 17011-1703 Attorneys for Plaintiff DAVID MICHAEL HOPKINS IN THE COURT OF COMMON PLEAS Plaintiffs OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. MATTHEW J. STEFANIC, No. 09-6154 CIVIL Defendant JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Jennifer L. Levan LAW OFFICES OF TWANDA TURNER-HAWKINS Iron Run Corporate Center 7535 Windsor Drive Suite 101-B Allentown, PA 18195 Attorney for Defendant You are hereby notified to file a written response to Plaintiffs Complaint within twenty (20) days from the service hereof or a judgment may be entered against you. RESPECTFULLY SUBMITTED, By: 1847 Center Street Camp Hill, PA 17011-1703 (717) 761-6162 ANTHONY STEFANON, ESQUIRE I.D. #25497 JUSTIN STEFANON, ESQUIRE I.D. #204580 1847 Center Street Camp Hill, PA 17011-1703 Attorneys for Plaintiff DAVID MICHAEL HOPKINS Plaintiffs vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 09-6154 CIVIL MATTHEW J. STEFANIC, Defendant JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff is David Michael Hopkins, an adult individual who resides at 9356 Beowulf Circle, Baltimore, Maryland. 2. Defendant is Matthew J. Stefanic, an adult individual who resides at 4 Southern Cross Drive, Boiling Springs, Cumberland County, Pennsylvania. 3. These claims arise from an accident between a motor vehicle and a bicycle which occurred at or around 10AM on September 16, 2007 in West Pennsboro Township, Cumberland County, Pennsylvania, hereinafter referred to as 'the incident in question'. 4. At the time and place aforesaid, Plaintiff was operating a certain bicycle, owned by himself, in a northbound direction on Big Spring Road. 5. At the time and place aforesaid, Defendant was driving a certain red 1999 Ford Ranger pickup truck, owned by one Michael Stefanic of the same address as Defendant, in an eastbound direction on Nealy Road. 6. Immediately prior to the incident in question Defendant was stopped at a stop sign at the intersection of Nealy Road with Big Spring Road. 7. At the time and place aforesaid, Defendant operated his motor vehicle in a negligent, careless, and reckless fashion, causing the pickup truck to pull away from the stop sign and into the path of the bicycle operated by the Plaintiff. 8. Defendant was negligent in the following respects: (a) He failed to pay attention to where he was driving; and (b) He failed to take note of Plaintiff bicycling in his direction; and (c) He failed to observe that there was no stop sign on Big Spring Road, whereby Plaintiff had the right-of-way; and (d) He failed to give way to Plaintiff and his moving bicycle; and (e) He failed to maintain a lookout for moving vehicles prior to pulling away from the aforementioned stop sign; and (f) He pulled away from the stop sign in the path of oncoming traffic; and (g) He blocked the path of Plaintiff, allowing Plaintiff no opportunity to 2 avert the incident; and (h) He failed to yield the right-of-way in violation of 75 Pa.C.S. § 3323 9. After Defendant pulled away from the stop sign into the path of the bicycle Plaintiff was operating, Plaintiff was unable to avoid Defendant's vehicle and the Plaintiff and/or his bicycle impacted the side of the pickup truck. 10. After or at about the same time as striking the side of the truck, Plaintiff fell underneath the pickup truck, and Defendant continued to move forward, passing over Plaintiff until Plaintiff was no longer under the truck. 11. The impact of the collision was sufficient to damage the side of the pickup truck and caused significant damage to the bicycle. 12. The impact of the collision inflicted serious and permanent injuries to Plaintiff, as the result of which he has undergone an extended course of medical care and treatment, has incurred and will continue to incur expenses for that care and treatment. 13. As a result of his injuries, Plaintiff has been temporarily disabled from his normal employment, and has suffered past loss of earnings. 14. As the result of his injuries, Plaintiff has been prevented from attending to the normal activities of his daily life. 15. As the result of his injuries, Plaintiff has endured pain, suffering, aggravation, inconvenience, mental and emotional distress, and loss of life's pleasures, and will continue to endure these damages fro the remainder of his life. 16. As the result of his injuries, Plaintiff has suffered scarring and disfigurement, all of which have resulted in aggravation, inconvenience, embarrassment and 3 humiliation. 17. The injuries and damages suffered by Plaintiffs were caused by the negligent acts and omissions of Defendant as set forth in the foregoing paragraphs. WHEREFORE, Plaintiff demands judgment against Matthew J. Stefanic for special damages, general damages, delay damages, interest, and costs of suit, in an amount which exceeds the limit of compulsory arbitration under the local rules of the Court of Common Pleas of Cumberland County, Pennsylvania. RESPECTFULLY SUBMITTED, n fanon #204580 1847 Center Street Camp Hill, PA 17011 (717) 761-6162 DATE: 10/27/2009 4 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing COMPLAINT are true and correct to the best of her knowledge, information, and belief. The undersigned further verifies that the Plaintiff is outside the jurisdiction of the court and his verification can not be obtained within the time allowed for filing this pleading. This Verification is made subject to the penalties of 18 Pa C.S.A. § 4904 relating to unsworn falsification to authorities. :-SA Justin non DATE: 10/27/2009 5 CERTIFICATE OF SERVICE The undersigned hereby certifies that, on the date below written, he served a true copy of the foregoing COMPLAINT upon the person listed below, at the address set forth, by First Class United States Mail: Jennifer L. LeVan LAW OFFICES OF TWANDA TURNER-HAWKINS Iron Run Corporate Center 7535 Windsor Drive Suite 101-B Allentown, PA 18195 (610) 398-5486 Attorney for Defendant RESPECTFWLLY SUBMITTED, By: JUSTIN STEFANON I . D. #204580 1847 Center Street Camp Hill, PA 17011 (717) 761-6162 DATE: 10/27/2009 6 Of r FILED-CrFIGE OP THE PRGTHMTARY 2009 OCT 27 PM 4.- 09 NITY Z~iD ~Q`~ ~ 7 P~ i:'~ ~~ fLL~`1 ' _ ''-~ ANTHONY STEFANON, ESQUIRE I.D. #25497 JUSTIN STEFANON, ESQUIRE I.D. #204580 1847 Center Street Camp Hill, PA 17011-1703 Attorneys for Plaintiff DAVID MICHAEL HOPKINS Plaintiffs vs. MATTHEW J. STEFANIC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 09-6154 CIVIL JURY TRIAL DEMANDED PRAECIPE TO FILE AMENDED CERTIFICATE OF SERVICE TO THE PROTHONOTARY: Please substitute the attached Amended Certificate of Service for the Certificate of Service previously filed. DATE: ~ Z 7 ~ ~ 0 RESPECTF LL SUBMITTED, By: a JUS~?N SfiEFANON, ESQUIRE I.D. #204580 1847 Center Street Camp Hill, PA 17011 (717) 761-6162 AMENDED CERTIFICATE OF SERVICE The undersigned hereby certifies that, on the date below written, he served a true copy of the foregoing PLAINTIFF'S REPLY TO NEW MATTER upon the person listed below, at the address set forth, by First Class United States Mail: Allyn M. Starry, Esquire LAW OFFICES OF TWANDA TURNER-HAWKINS Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 DATE: ~ L7 ZoiU RESPECTFULLY SUBMITTED, By: JUSTIN STEFANON, ESQUIRE I.D. #204580 1847 Center Street Camp Hill, PA 17011 (717) 761-6162 1555993177.1-B37 LAW OFFICES OF TWANDA TURNER-HAWKINS KENNETH S. O'NEILL Identification No. 80015 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5486 DAVID MICHAEL HOPKINS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY V. MATTHEW J. STEFANIC NO. 09-6154 WITHDRAWAL OF APPEARANCE ATTORNEY FOR DEFENDANT Matthew J. Stefanic TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of Matthew J. Stefanic in reference to the above-captioned case. ~~ =~ ~~;~ ,rte . . KENNETH S. O'NEILL, ESQUIRE 1555993177.1-B37 LAW OFFICES OF TWANDA TURNER- HAWKINS ALLYN M. STARRY Identification No. 89027 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5486 DAVID MICHAEL HOPKINS V. MATTHEW J. STEFANIC ATTORNEY FOR DEFENDANT Matthew J. Stefanic E`"s --• - ~, ; -,_. --i -" -=r' -~ ~ - COURT OF COMMON PLEAS-: '`~ ~ ~' u OF CUMBERLAND COUNTY`- _ NO. 09-6154 = r. ` ~'`'' ~: ~; - ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my Appearance on behalf of Matthew J. Stefanic in reference to the above- captioned case. ALLY1~ M. TARRY Attorney for efendan Matthew J. Stefanic 1555993177.1-B37 LAW OFFICES OF TWANDA TURNER- HAWKINS ALLYN M. STARRY, ESQUIRE Identification No. 89027 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5486 DAVID MICHAEL HOPKIN'S V. MATTHEW J. STEFANIC ATTORNEY FOR DEFENDANT, v Matthew J. Stefanie COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 09-6154 DEFENDANT'S MOTION TO COMPEL DISCOVERY AND NOW, Defendant, Matthew J. Stefanie, by and through Allyn M. Starry, Esquire, respectfully requests this Honorable Court to enter a Rule upon Plaintiff to Show Cause why he should not be required to provide answers to Defendant's Interrogatories and Request for Production of Documents. In support thereof, Defendant avers as follows: 1 The Plaintiffs, David Michael Hopkins, filed a lawsuit against Defendant, Matthew J. Stefanie, seeking monetary damages for personal injuries allegedly arising from negligent conduct. 2. On December 23, 2009, pursuant to Pa.R.C.P. 4005 and 4009, Defendant served upon Plaintiff certain Interrogatories and Requests for Production of Documents. Attached hereto and marked as Exhibit A are true and correct copies of said requests. 3. Pa.R.C.P. 4006(a)(2) and 4009(b)(2) requires Plaintiff to either object to or respond to Interrogatories and Requests for Production of Documents within thirty (30) days of service thereof. 4. Plaintiff declined to either object or respond to said discovery requests. 5. Pa.R.C.P. 4019 empowers the Court to fashion an Order compelling Plaintiff to fully respond to all of Defendant's Interrogatories and Requests for Production of Documents. 6. Counsel for Defendant hereby certifies that a copy of the attached Motion was served upon counsel for Plaintiff, and it is believed the Motion is opposed WHEREFORE, Defendant, Matthew J. Stefanic, requests this Honorable Court to enter an Order compelling Plaintiff, David Michael Hopkins, to provide full and complete answers to Defendant's Interrogatories and to respond to Defendant's Request for Production of Documents. Respectfully submitted, ALLYNP. STARRY Attorney for Defendant, Matthew J. Stefanie 2 1555993177.1-B37 LAW OFFICES OF TWANDA TURNER- HAWKINS ALLYN M. STARRY, ESQUIRE Identification No. 89027 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5486 ATTORNEY FOR DEFENDANT(S) Matthew J. Stefanic DAVID MICHAEL HOPKINS COURT OF COMMON PLEAS V OF CUMBERLAND COUNTY MATTHEW J STEFANIC NO. 09-6154 BRIEF IN SUPPORT OF DEFENDANT'S MOTION TO COMPEL DISCOVERY FACTS: Plaintiff, David Michael Hopkins, has filed a lawsuit against Defendant, Matthew J. Stefanic, seeking monetary damages allegedly arising from negligent conduct. The Parties engaged in routine discovery and, on December 23, 2009, Defendant served upon Plaintiff certain Interrogatories and Requests for Production of Documents. On August 13, 2010, a ten day letter was sent to counsel for Plaintiff requesting that the discovery responses be provided. To date, Plaintiff has declined to object or respond to said discovery requests. ARGUMENT: Parties to a lawsuit are entitled to discovery of relevant information by way of Interrogatories and Requests for Production of Documents. The party upon whom such requests are served is required to disclose the requested material unless a valid objection is timely asserted. Specifically, Rule 4005(a) of the Pennsylvania Rules of Civil Procedure states that "Subject to the limitations provided by Rule 4011, any party may serve upon any other parry written interrogatories to be answered by the party served..." Supplementing Rule 4005 is Rule 4006(a)(2) which provides that "The answering party shall serve a copy of the answers, and objections if any, within thirty days after service of the interrogatories." Similarly, Rule 4009.1 allows any Party to request any other party to produce certain relevant documents. The Rule states: Any party may serve a request upon a party pursuant to Rules 4009.11 and 4009.12 or a subpoena upon a person not a party pursuant to Rules 4009.21 through 4009.27 to produce and permit the requesting party, or someone acting on the party's behalf, to inspect and copy any designated documents (including writings, drawings, graphs, charts, photographs, electronically created data, and other compilations of data from which information can be obtained, translated, if necessary, by the respondent party or person upon whom the request or subpoena is served through detection or recovery devices into reasonably usable form), or to inspect, copy, test or sample any tangible things which constitute or contain matters within the scope of Rules 4003.1 through 4003.6 inclusive and which are in the possession, custody or control of the party or person upon whom the request or subpoena is served; and may do so one or more times. Moreover, Rule 4009.12(a) requires "The party upon whom the request is served shall within thirty days after the service of the request (1) serve an answer including objections to each numbered paragraph in the request, and (2) produce or make available to the party submitting the request those documents an tldngs described in the request to which there is no objection." In the present case, Defendant served Interrogatories and Requests for Production of Documents upon Plaintiff on December 23, 2009. Thirty days have elapsed since service of said requests. A ten day letter was mailed out to Counsel for Plaintiff on August 13, 2010. Plaintiff has neither objected to nor answered the Interrogatories or the Request for Production of Documents. Rule 4019(a)(1)(i) and (vii) of the Pennsylvania Rules of Civil Procedure provides a remedy by empowering the Court to compel the Plaintiff's compliance. The Rule states: 2 (a)(1) The court may, on motion, make an appropriate order if (i) a party fails to serve answers, sufficient answers or objections to written interrogatories under Rule 4005; (vii) a party, in response to a request for production or inspection made under Rule 4009, fails to respond that inspection will be permitted as requested or fails to permit inspection as requested; The Rule further provides, in section (a)(2), that "A failure to act described in subdivision (a)(1) may not be excused on the ground that the discovery sought is objectionable unless the party failing to act has filed an appropriate objection or has applied for a protective order." Because the Plaintiff has neither served answers nor objected to Defendant's discovery requests within the thirty day requirement, the Plaintiff should be compelled to fully and completely answer Defendant's Interrogatories and Requests for Production of Documents. CONCLUSION: Defendant is entitled to obtain discovery of the matters addressed in Defendant's Interrogatories and Requests for Production of Documents. The Rules require Plaintiff to respond to said requests within thirty days of service thereof. Plaintiff declined to object or respond within the required time period. This Honorable Court should grant Defendant's Motion and compel Plaintiff's cooperation. Respectfully submitted, M. for Defendant, ? 4aAhew J. Stefanic 3 VERIFICATION Allyn M. Starry, Esquire, states that she is the Attorney for Matthew J. Stefanie and that the facts set forth in the foregoing Motion are true and correct to the best of her knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C. S. 4904 relating to unsworn falsification to authorities. ALLYI M. STARRY, ES Attorney for Defendant, Matthew J. Stefanie 4 .1555993177.1-B37 ]LAW OFFICES OF TWANDA TURNER- HAWKINS ALLYN M. STARRY, ESQUIRE Identification No. 89027 Iron Run Corporate Center '7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5486 ATTORNEY FOR DEFENDANT(S) Matthew J. Stefanie ]DAVID MICHAEL HOPK NS COURT OF COMMON PLEAS V OF CUMBERLAND COUNTY MATTHEW J. STEFANIC NO. 09-6154 CERTIFICATE OF SERVICE I, ALLYN M. STARRY, do hereby certify that service of a true and correct copy of the within Motion to Compel Discovery was made on November 9, 2010, via US first class mail, postage prepaid, upon: Justin Stefanon, Esquire .1847 Center St Camp Hill, PA 17011 ALLYN F. STARRY Attorney for Defendant(s) Matthew J. Stefanie EXHIBIT "A" DAVID MICHAEL HOPKINS V. MATTHEW J. STEFANIC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 09-6154 3 DEC 172010 RULE oil OT- AND NOW this y of 1 2 ? , 2010% upon consideration of Defendant's Motion to Compel Plaintiffs Discovery Responses, and any response thereto, A RULE is hereby issued upon Plaintiff, David Michael Hopkins, to Show Cause why the requested relief should not be granted. Rule returnable within twenty (20) days of the date hereof. Failure to comply with this RULE may result in the Defendant's Motion being granted. BY E CO J. e (20 FI F s I rxa tl tC?- 044-, j . S4 e-va'U'ai 14Z111v =MrL 2 zm r- rn t? rn? ?M -<> C: r-= --4 Ct = -? M o C . n 1555993177.1 LAW OFFICES OF TWANDA TURNER-HAWKINS ALLYN M. STARRY, ESQ. Identification No. 89027 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5486 ATTORNEY FOR DEFENDANT, Matthew J. Stefanic DAVID MICHAEL HOPKINS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY V. NO. 09-6154 MATTHEW J. STEFANIC CERTIFICATE OF SERVICE n c -0:1 a rn rT, t? .v N G CD cn rn 0 rnF am o? -1 p co-n a I do hereby certify that service of a true and correct copy of the December 21, 2010 Rule issued upon Plaintiff to Show Cause why Defendant's Motion to Compel Plaintiff's Discovery Responses should not be granted was made on January 7, 2011 via US first class mail, postage prepaid, upon: Justin Stefanon, Esquire 1847 Center St Camp Hill, PA 17011 lft*aRg?a`n? Paralegal 1555993177.1 LAW OFFICES OF TWANDA TURNER-HAWKINS ALLYN M. STARRY, ESQ. Identification No. 89027 Iron Run Corporate Center 7535 Windsor Drive, Suite 101-B Allentown, PA 18195-1032 Telephone: (610) 398-5486 DAVID MICHAEL HOPKINS V. MATTHEW J. STEFANIC a ° CO ATTORNEY FOR DEFENDANT -: -?- ?. Ica Matthew J. Stefanic N3 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 09-6154 DEFENDANT'S PRAECIPE TO WITHDRAW MOTION TO COMPEL DISCOVERY TO THE CLERK: Kindly withdraw Defendant's Motion to Compel Discovery Responses Directed to Plaintiff entered in this case. 'j ? 0, /?' I )" ALLYN .' ?F1E86 Attorney oDee nt Matthew J. Stefanic