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HomeMy WebLinkAbout09-7773IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ROBERT A. WILLIAMS, SR. AND ARLENE B. WILLIAMS, husband And wife 325 Wesley Drive, Apt. 105 Mechanicsburg, PA 17055 V. LISA R. BARBUSH, as Executrix of the Estate of G. Aileen Gottshall, Deceased 1370 Norton Road Steelton, PA 17113 CASE NO. Cq- '1773 CIVIL TERM C IVIL ACTION PRAECIPE FOR SUMMONS To The Prothonotary of said Court: Kindly issue summons upon Lisa R. Barbush, as the Exectrix of the Estate of G. Aileen Gottshall, Deceased. Writ of Summons shall be issued and forwarded to the Sheriff. CO COYNE, Date: 6q By: Henry F. Co e, Esq. Pa. Supreme t. No. 06250 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 WRIT OF SUMMONS TO: Lisa R. Barbush as Executrix of the Estate of G. Aileen Gottshall, Deceased YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF HAS COMMENCED ACTION AGAINST YOU Date: lI 9 0f By. FILED 1 Tyr F? n' a,';'1 FARY 2009 NOV -9 PH 2: 22 .?%g . 5,0 P6 An--/ Cu.# 451.1 R-T * a 33a3o SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff ~4y,ttiu~ of 4~iuu(~~,~,~~~~~ Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant ~- ~~r~ Edward L Schorpp Solicitor Robert A. Williams, Sr. vs. Lisa R. Barbush Case Number 2009-7773 SHERIFF'S RETURN OF SERVICE 11/10/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Lisa R. Barbush, as the Executrix of the Estate of G. Aileen Gottshall, deceased, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Writ of Summons according to law. 11/18/2009 09:26 AM -Dauphin County Return: And now November 18, 2009 at 0926 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Lisa R. Barbush, as the Executrix of the Estate of G. Aileen Gottshall, deceased by making known unto Lisa R. Barbush, As the Executrix of the Estate of G. Aileen Gottshall, deceased, at 1370 Norton Road, Steelton, PA 17113 its contents and at the same time handing to her personally the said true and correct copy of the same. ~ ~--, SHERIFF COST: $37.44 November 30, 2009 SO KLINE, SHERIFF ~~ l£cl.' C~T-i~l t~ ~ ~~ ~~~~~ C~ ~ . `v • rJ~ . ccu~, iit: She' E 7E -;'t. Im:. Mary Jane Sntyyder Real Estate Depu f~ ~' •. William T. Tully i Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717)780-6590 fax: (717)255-2889 Jack Lotwick Sheriff Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of Pennsylvania ARLENE B WILLIAMS, ET AL VS LISA R. BARBUSH, AS THE EXECUTRIX County of Dauphin OF THE ESTATE OF G. AILEEN GOTTSHALL, DECEASED Sheriff s Return No. 2009-T-2908 OTHER COUNTY NO. 20097773 And now: NOVEMBER 1~, 2009 at 9:26:00 AM served the within WRIT OF SUMMONS upon LISA R. BARBUSH, AS THE EXECUTRIX OF THE ESTATE OF G. AILEEN GOTTSHALL, DECEASED by personally handing to LISA _R..BARBUSH, AS THE EXECUTRIX OF THE ESTATE OF G. AILEEN GOTTSHALL, DECEASED 1 true attested copy of the original WRIT OF SUMMONS and making known to him/her the contents thereof at 1370 NORTON ROAD STEELTON PA 17113 Sworn and subscribed to before me this 19TH day of November, 2009 ', ~/ i ~ NOTARIAL SEAL ARY JANE SNYDER, Notary Public Highspire, Dauphin County M , Comr.:ission Ex fires S::~t 1, 2010 So Answers, ~~°.~~~ Sheriff of Dauphin County, Pa. By ~ _.~~ Deputy Sheriff Deputy: S SCHAEFFER Sheriffs Costs: $43.25 11/16/2009 In The Court of Common Pleas of Cumberland County, Pennsylvania Robert A. Williams Sr. & Arlene B. Williams vs. Lisa R. Barbush, as the Executrix of the Estate of G. Aileen Gottshall, deceased 1370 Norton Road Steelton, PA 17113 Civil No. 2009-7773 Now, November 10, 2009, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. >.uG..~.1-~, Sheriff of Cumberland County, PA Affidavit of Service Now, , 20 , at o'clock M, served the within upon at by handing to a and made known to copy of the original, the contents thereof. So answers, Sheriff of County, PA COSTS Sworn and subscribed before SERVICE $ me this day of ,20_ MILEAGE AFFIDAVIT o :~ 'x? -t "s ° .~,~ ~ r s W 1 09-020988 ~== z= - ` ~ LAW OFFICE OF SNYDER & DORER _ f~ ~. 214 Senate Avenue, Suite 600 ~_-; ~ ~~; Camp Hill, PA 17011 ~~ `~-~-' ca =~'-'~ Telephone Number: (717) 731-0988 ~ .c- " Attorneys for Defendant, Lisa R. Barbush, as ~ Executrix of the Estate of G. Aileen Gottshall ROBERT A. WILLIAMS, SR. AND ARLENE B. WILLIAMS, HUSBAND AND WIFE, PLAINTIFFS VS. LISA R. BARBUSH, AS EXECUTRIX OF THE ESTATE OF G. AILEEN GOTTSHALL, DECEASED, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 7773 CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: hereof Date: Donald R. Dore , sq Attorney for Defendant Court I.D. 39126 RULE TO FILE COMPLANVT AND NOW, this ~_ day of ~Cbr~-~' , 2010 a RULE is hereby entered upon the Plaintiffs to file a Corhplaint~her~i -within twenty (20) days after service hereof or suffer the entry of a Judgment cif ~ Pros. P R~~T ~ ~ TA Y Please enter a RULE upon Plaintiffs to file a Complaint wit irk' enty (20) days or suffer the entry of a Judgment of Non r ' t` t~ %'` February 5, 2010 r wire 09-020988 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Lisa R. Barbush, as Executrix of the Estate of G. Aileen Gottshall ROBERT A. WILLIAMS, SR. AND ARLENE B. WILLIAMS, HUSBAND AND WIFE, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. LISA R. BARBUSH, AS EXECUTRIX OF THE ESTATE OF G. AILEEN GOTTSHALL, DECEASED, DEFENDANT No. 09 - 7773 CIVIL ACTION -LAW JURY TRIAL DEMANDED 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 for Rule to File Complaint to be served by regular first class mail upon: Henry F. Coyne, Esquire 3901 Market Street Camp Hill, PA 1 701 1-4227 Attorney for Plain,t~`fg/~ , Date: February 5, 2010 Donal .Dorer, Esquire Attorney for Defendant OR tq~~~~ 2010 MAR -5 A~1 8~ 22 COYNE & COYNE, P.C. Henry F. Coyne, Esq. Pa. Supreme Ct. No. 06250 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 CJMr , ; ~ , ~:, viV~ t'C~`~i v~'~ ~.~~~'Ji `~, ATTORNEYS FOR PLAINTIFFS ROBERT A. WILLIAMS, SR. AND : IN THE COURT OF COMMON PLEAS OF ARLENE B. WILLIAMS, :CUMBERLAND COUNTY, PENNSYLVANIA Husband and wife, . Plaintiffs . vs. : N0.09-7773 LISA A. BARBUSH, AS :CIVIL ACTION -LAW EXECUTRIX OF THE ESTATE OF . G. AILEEN GOTTSHALL, DECEASED, :Jury Trial Demanded Defendant 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 and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIBIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 COYNE & COYNE, P.C. Henry F. Coyne, Esq. Pa. Supreme Ct. No. 06250 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 ATTORNEYS FOR PLAINTIFFS ROBERT A. WILLIAMS, SR. AND ARLENE B. WILLIAMS, Husband and wife, Plaintiffs vs. LISA A. BARBUSH, AS EXECUTRIX OF THE ESTATE OF G. AILEEN GOTTSHALL, DECEASED, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.09-7773 CIVIL ACTION -LAW Jury Trial Demanded COMPLAINT AND NOW COMES the Plaintiffs, Robert A. Williams, Sr. and Arlene B. Williams, husband and wife, by and through her attorneys, Coyne & Coyne, P.C., and avers the following in support of the within Complaint. 1. Plaintiffs, Robert A. Williams, Sr. and Arlene B. Williams, are adult individuals residing at Bethany Village, Apt. 105, 325 Wesley Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant, Lisa R. Barbush, is the Executrix of the Estate of G. Aileen Gottshall, an adult individual residing at 137-D Norton Road, Steelton, Dauphin County, Pennsylvania. 3. On December 24, 2007, Plaintiff Robert A. Williams, Sr. was operating his 1997 Mercury Sable Sedan. Plaintiff Robert A. Williams, Sr. had stopped his vehicle in the left turn lane of Rossmoyne Road, facing southbound, waiting to turn left onto Westport Drive, in Lower Allen Township, Cumberland County, Pennsylvania. 2 4. At the same time, the Defendant, the late G. Aileen Gottshall, was operating a 1995 Ford Explorer which was traveling south on Rossmoyne Road and entered the left turn lane to enter Westport Drive and violently struck the rear of Mr. Williams' vehicle which was stopped. 5. The damage to both vehicles, indicates Mrs. Gottshall never slowed down or controlled her vehicle prior to colliding violently with Mr. Williams' vehicle. 6. As a result of the violent collision, the trunk of Plaintiff Robert A. Williams, Sr.'s vehicle was pushed into the rear seat of his vehicle; his vehicle was destroyed beyond repair; it was inoperable; and had to be towed by wrecker from the collision site. 7. As a result of the violent collision, Plaintiff Robert A. Williams, Sr. was given emergency medical treatment at the scene and transported via ambulance to the Emergency Room of Pinnacle Health Harrisburg Hospital for medical treatment. 8. As a result of the motor vehicle collision, G. Aileen Gottshall was transported to Penn State Milton S. Hershey Medical Center, Hershey, Pennsylvania, and she expired on March 7, 2008. 9. On March 19, 2008, the Last Will of G. Aileen Gottshall was offered for probate at the Register of Wills Office in Cumberland County, Pennsylvania and the Register of Wills issued Letters Testamentary to Lisa R. Barbush. 10. The impact was due solely to the negligence and carelessness of the Defendant G. Aileen Guttshall in that: a. She operated her motor vehicle at an excessive rate of speed under the circumstances; b. She did not have her motor vehicle under proper control so as to stop her vehicle prior to making violent impact with Plaintiff, Robert A. Williams, Sr.'s vehicle; c. She operated her motor vehicle without due regard to the rights, safety, and position of Plaintiff, Robert A. Williams, Sr. 3 d. She failed to keep a proper lookout for Plaintiff, Robert A. Williams, Sr.'s vehicle; e. She failed to use due care under the circumstances; £ She failed to take evasive action in order to avoid her vehicle making violent impact with Plaintiff Robert A. Williams, Sr.'s vehicle; g. She committed or omitted actions which may be revealed in the course of discovery; h. She operated her vehicle in a careless manner in disregard of the rules of the road and the laws of the Commonwealth of Pennsylvania, including but not limited to the Motor Vehicle Code, 75 Pa. P.S § 3714. COUNT NO. 1 Robert A. Williams, Sr., Plaintiff vs. Lisa a. Barbush as Executrix of the Estate of G. Aileen Gottshall. Defendant 11. Plaintiff incorporates the preceding paragraphs 1 through 10 of this Complaint as if each and every one were individually set forth within this Count. 12. As a result of the violent impact, Plaintiff suffered severe trauma to his body; severe injuries; bruises to his neck; cervical sprain; bruises on his left arm and left hand; skin tear on his left leg; severe chest pain and experienced difficulty breathing which requires him to use oxygen and a breathing machine on a daily basis; all of which rendered him sick, sore, lame, prostrate and disoriented and he underwent great mental anguish and physical pain which he suffered; still suffers; and will continue to suffer for an indefinite time in the future. 4 13. Subsequent to being released from the Pinnacle Health Harrisburg Hospital, Plaintiff, suffered cardiac discomfort, a result of the aforementioned motor vehicle impact; and he was readmitted to the Pinnacle Health Harrisburg Hospital on January 17, 2008 suffering from shortness of breath, general weakness, and chest pain. 14. On March 17, 2009, Plaintiff began to use a breathing machine because he continues to have shortness of breath which worsens in damp weather and when ambulatory. 15. Subsequent to being released from the Pinnacle Health Harrisburg Hospital, Plaintiff was admitted to Pinnacle Health Community General Emergency Room on June 3, 2009 suffering from shortness of breath, general weakness, and chest pain. 16. On June 8, 2009, Plaintiff was prescribed oxygen on a daily basis to assist him with shortness of breath and general weakness. 17. On September 3, 2009, Plaintiff was admitted to Pinnacle Health Harrisburg Hospital suffering from shortness of breath, general weakness and chest pain which had continued to worsen since his last hospitalization. After extensive tests while hospitalized, on September 6, 2009, a pacemaker was inserted into the body of Robert A. Williams, Sr. 18. On January 5, 2010, Plaintiff was prescribed compression boots to use on a daily basis to help with circulation in his legs. 19. All the aforementioned injuries and conditions were caused by the said motor vehicle impact which rendered Plaintiff sick, sore, lame, prostrate and disoriented and he underwent great mental anguish and physical pain which he suffered; still suffers and will continue to suffer for an indefinite time in the future. 5 20. As a result of the said injuries from the motor vehicle impact, Plaintiff continues to receive professional medical treatment and therapies to treat the said injuries he received and the resulting condition of his health. 21. In order to treat and attempt to treat the above said injuries and conditions, Plaintiff Robert A. Williams, Sr. has been compelled to incur large sums of money for medical treatment and therapy and he will be required to incur additional expenses for the same purposes in the future. WHEREFORE, Plaintiff Robert A. Williams, Sr. respectfully requests that this Court find in favor of Plaintiff and against Defendant Lisa a. Barbush, as Executrix of the Estate of G. Aileen Gottshall, in an amount in excess of the mandatory arbitration amount in this jurisdiction, plus interest and docket costs. COUNT NO. II Arlene B. Williams. Sr., Plaintiff vs. Lisa a. Barbush as Executrix of the Estate of G. Aileen Gottshall, Defendant 22. Plaintiff incorporates the preceding paragraphs 1 through 21 of this Complaint as if each and every one were individually set forth within this Count. 23. As a result of Defendant's negligence, Plaintiff has been deprived of the society, companionship, contributions and consortium of her husband, Robert A. Williams, Sr. to her great detriment and loss. 24. As a result of Defendant G. Aileen Gottshall's negligence, Plaintiff has suffered disruption of her daily habits, pursuits and loss of enjoyment of life. 25. As a result of Defendant G. Aileen Gottshall's negligence, Plaintiff has incurred and will incur expenses to treat her husband's injuries and conditions as a result of the said motor vehicle impact. 6 WHEREFORE, Plaintiff Arlene B. Williams respectfully requests that this Court find in favor of Plaintiff Arlene B. Williams and against Defendant Lisa a. Barbush, as Executrix of the Estate of G. Aileen Gottshall in an amount in excess of the mandatory arbitration amount in this jurisdiction, plus interest and docket costs. Dated: ! ~' I~'f/l,{~,yt ~ ~j Respectfully submitted: COYNE & COYNE, P.C. By: Henry F. C e, Esquire Pa. Supreme Ct. No. 06250 3901 Market Street Camp Hill, PA 17011 (717) 737-0464 Attorneys for Plaintiffs 7 VERIFICATION The facts set forth in the foregoing are true and correct to the best of the undersigned's lrnowledge, information and belief and are verified subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S.A. § 4904. Dated: ~ ~ ~ ~ ~~ Dated: 3 /~//~ ~ ~~ ~ Robert A. Williams, Sr. ~~ ' Arlene B. Williams 4 CERTIFICATE OF SERVICE I, Henry F. Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Plaintiffs' Complaint was served this date upon the below-referenced individual at the below listed address by way of first class mail, postage pre-paid: Donald R. Dorer Law Office of Snyder &Dorer 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Dated: _~ By: Henry F. yne, Esquire Pa. Supreme Ct. No. 06250 3901 Market Street Camp Hill, PA 17011 (717) 737-0464 Attorneys for Plaintiffs 8 ~:,; _ T' - ,.. f~l1G' l~ ~? 4;N0 GI R S v ~..F_. . lj; i ~. ~ _. .. '.. .. . COYNE & COYNE, P.C. Henry F. Coyne, Esq. Pa. Supreme Ct. No. 06250 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Attorneys for Plaintiff ROBERT A. WILLIAMS, SR. AND : IN THE COURT OF COMMON PLEAS OF ARLENE B. WILLIAMS, :CUMBERLAND COUNTY, PENNSYLVANIA Husband and wife, . Plaintiffs vs. : N0.09-7773 LISA A. BARBUSH, AS :CIVIL ACTION -LAW EXECUTRIX OF THE ESTATE OF G. AILEEN GOTTSHALL, DECEASED, :Jury Trial Demanded Defendant CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things, pursuant to Rule 4009.22, Plaintiffs Robert A. Williams, Sr. and Arlene B. Williams, husband and wife, certify that: (1) a notice of intent to serve subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) opposing counsel by letter consents to the subpoena, (4) a copy of the letter of consent by opposing counsel is attached to this certificate, and (5) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date: i-~.Q, enry F. o e, squire 3901 Marke Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 06250 Attorney for Plaintiff COYNE & COYNE, P.C. Henry F. Coyne, Esq. Pa. Supreme Ct. No. 06250 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 ATTORNEYS FOR PLAINTIFFS ROBERT A. WILLIAMS, SR. AND ARLENE B. WILLIAMS, Husband and wife, Plaintiffs vs. LISA A. BARBUSH, AS EXECUTRIX OF THE ESTATE OF G. AILEEN GOTTSHALL, DECEASED, Defendant IN THE COURT OF CONIlVION PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.09-7773 CIVIL ACTION -LAW :Jury Trial Demanded NOTICE OF INTENT TO SERVE SUBPOENA "~ TO: Lisa A. Barbush, as Executrix of the Estate of G. Aileen Gottshall, deceased c/b Donald R. Dorer, Esquire Law Office of Snyder & Dorer 214 Senate Avenue, Suite 600, Camp Hill, PA 17011 . Attorney for Defendant Plaintiffs intend to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena maybe served. Date: Henry F. Coyn ,Esquire 3901 Market eet Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 06250 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Robert Williams, Sr. and Arlene Williams, Husband and Wife Plaintiff VS. Lisa A. Barbush, as the Executrix of the Estate of G. Aileen Gottshall, deceased Defendant File No. 09-7773, Civil Term SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Lower Allen Township Police Department -- 1993 Hummel Ave., Camp Hill, PA 17011 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you aze ordered by the court to produce the following documents or things: Police reports, photographs, and witness statements for Incident No. 20071201290 which was amulti-vehicle crash occurring on December 24, 2007 at gam at the intersection of Rossmoyne Rd. and Westport Dr. in Lower Allen Township, Cumberland County, Pennsylvania. at Law Offices of Coyne & Coyne, P.C., 3901 Market Street, Camp Hill, PA 17011 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Henry F. Coyne, Esq. ADDRESS: Coyne do Coyne, P.C. 3901 Market Street Hill, PA 17011 TELEPHONE: 71'7-~3~-oa6a SUPREME COURT ID # oG2so ATTORNEY FOR: naMd x. Bretz, Plaintiff BY THE COURT: Prothonotary, Civil Division Date: Seal of the Court Deputy LAW OFFICE OF LAW OFFICE OF JILL R SNYDER Bethlehem, PA 18017 SNYDER & BARRETT Philadelphia, PA 19103 SNYDER & VERBEKE CONSHOHOCKEN, PA 19428 214 SENATE AVENUE, SUITE 600 CAMP HILL, PENNSYLVANIA 17011 (717) 731-0988 (F?,X) (717) 731-0987 DONALD R RORER JOANNE E. KINZEL `Refer to: 09-020988 Henry F. Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 1 701 1-4227 August 6, 2010 SNYDER & ANDREWS Wexford, PA 15090 SNYDER & ASSOCIATES - Plains, PA 18705 .~ ~ /G; ~, SNYDER & SHAFFER ~~~`~' DOYLESTOWN, PA 18901 '~ ~ ~ REPLY TO: G ~~= CAMP HILL ~ ~ '/~ PARALEGALS t'y /~' CINDY M. BOO% ~ „ 1 LISA S. KEYTON /i/ \ !i// Re: Robert A. Williams, Sr. and Arlene B. Williams, husband and wife vs. Lisa R. Barbush as Executrix of the Estate of G. Aileen Gottshall, Deceased Cumberland County: No. 09-7773 Dear Henry, This is to confirm receipt of your letter dated August 3, 2010, enclosing a Notice of Intent to Serve Subpoena directed to Lower Allen Police Department in the above-referenced matter. I have no objection to your requested subpoena. I would appreciate if you would provide me with a copy of any and all records you may obtain pursuant to the issuance. of this records subpoena; you are assured of our reciprocal courtesies with respect to any records subpoenas which may be served by this office. Thank you for your attention. SNYDER & RORER Employees of Nationwide Mutual hutirance Company® Not a Partnership i rely ur onald .Rorer DRD:Isk CERTIFICATE OF SERVICE I, Henry F. Coyne, Esq., of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Certificate Prerequisite to Service of Subpoena was served this date upon the below- referenced individuals at the below listed address by way of first class mail, postage pre-paid: Donald R. Dorer, Esquire Law Office of Snyder &Dorer 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Dated: 1 ~" He F. Co e uire ~~~ "1.. ~' yn , q 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 06250 Attorney for Plaintiffs 2 G AUG 3 zuiu 09-020988 ROBERT A. WILLIAMS, SR. AND ARLENE B. WILLIAMS, HUSBAND AND WIFE, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. LISA R. BARBUSH, AS EXECUTRIX OF THE ESTATE OF G. AILEEN GOTTSHALL, DECEASED, DEFENDANT No. 09 - 7773 0 CIVIL ACTION - LAW c TRIAL DEMANDED J URY 4LO ORDER OF COURT AND NOW, this day of 2010, upon consideration of the within Motion for Pre-trial Status Conference of Defendant, Lisa R. Barbush as Executrix of the Estate of G. Aileen Gottshall, Deceased, it is hereby ORDERED that a Status Conference shall be held on the 13 day of OZZ4? 7Z5. 5 2010, at y5 M. in Chambers the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. It is so ordered. BY THE COURT, J. Distribution: V Henry F. Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011-4227 Telephone No.: (717) 737-0464 Fax No.: (717) 737-5161 Attorney for Plaintiffs, Robert A. Williams, Sr. and Arlene B. William Donald R. Dorer, Esquire Law Office of Snyder & Dorer 214 Senate Avenue Suite 600 Camp Hill, PA 17011 Telephone No. (717) 731-0988 Fax No. (717) 731-0987 Attorney for Defendant, Lisa R. Barbush, as Executrix of the Estate of G. Aileen Gottshall ;24t 09-020988 ROBERT A. WILLIAMS, SR. AND ARLENE B. WILLIAMS, HUSBAND AND WIFE, PLAINTIFFS VS. LISA R. BARBUSH, AS EXECUTRIX OF THE ESTATE OF G. AILEEN GOTTSHALL, DECEASED, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA C c? m NO. 09 - 7773 ro r? ?? CIVIL ACTION - LAW JURY TRIAL DEMANDED ORDER OF COURT Y"X AND NOW, this 13 day of 2010, it is hereby ORDERED that the Status Conference scheduled for Monday, September 13, 2010 at 8:45 a.m. has been CONTINUED to Monday, the 25th day of October, 2010, at 11:00 A.M. in Chambers of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. It is so ordered. BY THE COURT, 4 J. Distribution: enry F. Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011-4227 Telephone No.: (717) 737-0464 Fax No.: (717) 737-5161 Attorney for Plaintiffs, Robert A. Williams, Sr. and Arlene B. William Donald R. Dorer, Esquire Law Office of Snyder & Dorer 214 Senate Avenue Suite 600 Camp Hill, PA 17011 Telephone No. (717) 731-0988 Fax No. (717) 731-0987 Attorney for Defendant, Lisa R. Barbush, as Executrix of the Estate of G. Aileen Gottshall ~ ~ ~ 09-020988 ROBERT A. WILLIAMS, SR. AND ARLENE B. WILLIAMS, HUSBAND AND WIFE, PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. LISA R. BARBUSH, AS EXECUTRIX OF THE ESTATE OF G. AILEEN GOTTSHALL, DECEASED, DEFENDANT NO 09 - 7773 ~ ~ ~'' . ~'}~~' o --1 ~~ G~~ ~ Q~ rya CIVIL ACTION -LAW ~-~ ~~ ~ JURY TRIAL DEMANDED Tl ~ ~'- ~ `~ ~ ~ ~ := c~ :~ rn ~ .~- D c;~ ~ -<; ORDER OF COURT AND NOW, this G~~ day of November, 2010, upon consideration of Motion for Pre-trial Status Conference of Defendant, Lisa R. Barbush, as Executrix of the Estate of G. Aileen Gottshall, Deceased and following a Status Conference held in the Chambers of the undersigned Judge on October 25, 2010 in which the Plaintiffs were represented by Henry F. Coyne, Esquire, and Defendant, Lisa R. Barbush, as Executrix of the Estate of G. Aileen Gottshall, Deceased was represented by Donald R. Dorer, Esquire and pursuant to an agreement of counsel, it is ORDERED AND DIRECTED as follows: 1. On or before December 31, 2010, all general discovery shall have been completed; 2. On or before November 29, 2010, all medical expert report(s) of Plaintiffs shall be served upon Defendant's counsel; j:~ 3. On or before January 28, 2011, any medical expert report(s) of Defendant shall be served upon Plaintiffs' counsel; 4. On or before March 15, 2011, any alternative dispute resolution including mediation efforts, shall have been undertaken; 5. This case may be listed by counsel for trial during the trial term commencing May 2, 2011. BY THE COURT, The Honorable Albert H. Masla 2 ~ r Distribution: Henry F. Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011-4227 Telephone No.: (717) 737-0464 Fax No.: (717) 737-5161 Attorney for Plaintiffs, Robert A. Williams, Sr. and Arlene 8. William onald R. Dorer, Esquire Law Office of Snyder &Dorer 214 Senate Avenue Suite 600 Camp Hill, PA 17011 Telephone No. (717) 731-0988 Fax No. (717) 731-0987 Attorney for Defendant, Lisa R. Barbush, as Executrix of the Estate of G. Aileen Gottshall ~~~ ~~~ ,~~~./~~ ~~ t 09-020988 FfLED-OFFICE OF THE PR0THOI:d 20 11 JUL 18 PM 12: 3 Q 'CUMBERLAND COUNT PENNSYLVANIA ROBERT A. WILLIAMS, SR. AND ARLENE B. WILLIAMS, HUSBAND AND WIFE, PLAINTIFFS VS. LISA R. BARBUSH, AS EXECUTRIX OF THE ESTATE OF G. AILEEN GOTTSHALL, DECEASED, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09 - 7773 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Please mark the above-captioned case settled, discontinued and ended. COYNE & COYNE, P.C. Date: Henry F. Coy e, Esquire 3901 Market Street Camp Hill, PA 17011-4227 Telephone No. (717) 737-0464 Attorney for Plaintiffs Court I.D. 06250 09-020988 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant, Lisa R. Barbush, as Executrix of the Estate of G. Aileen Gottshall ROBERT A. WILLIAMS, SR. AND ARLENE B. WILLIAMS, HUSBAND AND WIFE, PLAINTIFFS VS. LISA R. BARBUSH, AS EXECUTRIX OF THE ESTATE OF G. AILEEN GOTTSHALL, DECEASED, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09 - 7773 CIVIL ACTION - LAW JURY TRIAL DEMANDED 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: Henry F. Coyne, Esquire 3901 Market Street Camp Hill, PA 17011-4227 Attorney for PlaiUti#-5.. Date:_ July 15, 2011 Dbffald R. Dorer, Esquire Attorney for Defendant