Loading...
HomeMy WebLinkAbout10-2988 1. i6 201U 1 .1 -; A JOHN E. MUMMA, : IN THE COURT OF COMMON PLEAS OF JANICE M. MUMMA, and : CUMBERLAND COUNTY, PENNSYLVANIA CARLISLE ELECTRIC, INC. Plaintiffs :NO. 10 - d4f- CIVIL TERM V. JESSE L. JONES, and JASON JONES, Defendants : JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 Bedford Street Carlisle, PA 17013 (717) 249-3166 11,1'e V6.? JOHN E. MUMMA, JANICE M. MUMMA, and CARLISLE ELECTRIC, INC. Plaintiffs V. JESSE L. JONES, and JASON JONES, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 10 - CIVIL TERM JURY TRIAL DEMANDED COMPLAINT Plaintiff, John E. Mumma, an adult individual, resides at 2513 Walnut Bottom Road, Box 158, Carlisle, Cumberland County, Pennsylvania 17013. 2. Plaintiff, Janice M. Mumma, an adult individual, resides at 2513 Walnut Bottom Road, Box 158, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff, Carlisle Electric, Inc., is a corporation wholly owned by John E. Mumma and authorized to do business within the Commonwealth of Pennsylvania with its principal place of business located at 1255 Claremont Road, P.O. Box 158, Carlisle, PA 17015. 4. Defendant, Jesse L. Jones, an adult individual, resides at 931 West Old York Road, Carlisle, Cumberland County, Pennsylvania 17015. 5. Defendant, Jason Jones, an adult individual, resides at 931 West Old York Road, Carlisle, Cumberland County, Pennsylvania 17015. 6. On June 29, 2009, Plaintiff John E. Mumma, the operator of a 1995 Dodge 3500, owned by Carlisle Electric, Inc., was traveling north on Route 465 in Dickinson Township, Pennsylvania at approximately 4:36 p.m. at a point located near 2371 Walnut Bottom Road. 7. At that same time and place, Defendant Jesse L. Jones, the operator of a 2004 John Deere farm tractor, owned by Jason Jones, was traveling north ahead of Plaintiff John E. Mumma. Defendant Jesse L. Jones was hauling a large, liquid manure spreader (hereinafter, "trailer"). 8. Plaintiff John E. Mumma's vehicle approached Defendant Jesse L. Jones' slow-moving farm tractor and trailer from behind, and after ensuring that the southbound lane was free of oncoming traffic, Plaintiff John E. Mumma attempted to pass Defendant Jesse L. Jones on the left-hand side of the roadway. 9. In the process of overtaking Defendant Jesse L. Jones, Plaintiff John E. Mumma's vehicle pulled along side Defendant Jesse L. Jones' farm tractor and trailer. 10. Without signaling, Defendant Jesse L. Jones turned left and crashed his farm tractor and trailer into Plaintiff John E. Mumma's vehicle, causing Plaintiff John E. Mumma's vehicle to leave the roadway where it impacted a utility pole and overturned approximately three times before coming to rest facing east in the southbound lane of the roadway. 11. Plaintiff John E. Mumma was flown by Life Lion Critical Care Transport to Penn State Hershey Medical Center with serious injuries including severe facial injuries, two broken ribs, nerve damage from the neck to the waist and extensive bruising and lacerations on the arms and legs. COUNT I: PLAINTIFF JOHN E. MUMMA v. JESSE L. JONES - NEGLIGENCE 12. Paragraphs 1-11 are incorporated herein as if set forth at length. 13. It was Defendant Jesse L. Jones' duty to operate his vehicle with due care and caution, in accordance with the applicable statues and ordinances in effect at the aforesaid time and place. 14. At the aforesaid time and place, Defendant Jesse L. Jones was guilty of one or more of the following careless and negligent acts or omissions: a. Defendant Jesse L. Jones drove, upon the highway, a vehicle that was not registered. b. Defendant Jesse L. Jones moved from a lane of traffic without first ascertaining that the movement could be made with safety. C. Defendant Jesse L. Jones turned his vehicle, while upon a roadway, without giving an appropriate signal in the manner provided by law. d. Defendant Jesse L. Jones drove a commercial motor vehicle without having been issued and without immediate possession of a valid commercial driver's license and applicable endorsements for the vehicle. e. Defendant Jesse L. Jones drove a vehicle with a total outside width in excess of that permitted by law. f. Defendant Jesse L. Jones drove, upon the highway, a vehicle designed to operate at 25 miles per hour or less without displaying a reflective slow moving vehicle emblem as regulations specify. 15. As a direct and proximate result of one or more of the aforesaid careless and negligent acts or omissions, the farm tractor and trailer driven by Defendant Jesse L. Jones violently collided with Plaintiff John E. Mumma's vehicle. 16. As a direct and proximate result of the aforesaid collision, Plaintiff John E. Mumma suffered injuries of a personal and pecuniary nature, including but not limited to: medical expenses, lost income from the running of his business, damage to property, pain and suffering, and physical and emotional trauma, all of which are permanent. WHEREFORE, Plaintiff, John E. Mumma, asks for a judgment in his favor and against Defendant Jesse L. Jones in a sum in excess of $50,000.00. COUNT II: PLAINTIFF JOHN E. MUMMA v. JASON JONES - NEGLIGENCE 17. Paragraphs 1-16 are incorporated herein as if set forth at length. 18. At the aforesaid time and place, while engaged in Defendant Jason Jones' business and for Defendant Jason Jones' benefit, Defendant Jesse L. Jones committed one or more of the following careless and negligent acts or omissions: a. Defendant Jesse L. Jones drove, upon the highway, a vehicle that was not registered. b. Defendant Jesse L. Jones moved from a lane of traffic without first ascertaining that the movement could be made with safety. C. Defendant Jesse L. Jones turned his vehicle, while upon a roadway, without giving an appropriate signal in the manner provided by law. d. Defendant Jesse L. Jones drove a commercial motor vehicle without having been issued and without immediate possession of a valid commercial driver's license and applicable endorsements for the vehicle. e. Defendant Jesse L. Jones drove a vehicle with a total outside width in excess of that permitted by law. f. Defendant Jesse L. Jones drove, upon the highway, a vehicle designed to operate at 25 miles per hour or less without displaying a reflective slow moving vehicle emblem as regulations specify. 19. As a direct and proximate result of one or more of the aforesaid careless and negligent acts or omissions, the farm tractor and trailer driven by Defendant Jesse L. Jones while engaged in Defendant Jason Jones' business and for Defendant Jason Jones' benefit violently collided with Plaintiff John E. Mumma's vehicle. 20. As a direct and proximate result of the aforesaid collision, Plaintiff John E. Mumma suffered injuries of a personal and pecuniary nature, including but not limited to: medical expenses, lost income from the running of his business, damage to property, pain and suffering, and physical and emotional trauma, all of which are permanent. WHEREFORE, Plaintiff, John E. Mumma, asks for a judgment in his favor and against Defendant Jason Jones in a sum in excess of $50,000.00. COUNT III: PLAINTIFF JOHN E. MUMMA v. JESSE L. JONES - NEGLIGENCE PER SE 21. Paragraphs 1-20 are incorporated herein as if set forth at length. 22. At the aforesaid time and place, Defendant Jesse L. Jones did negligently, carelessly and recklessly violate one or more of the following statutes that were designed to protect Plaintiff John E. Mumma from harm and damages: a. 75 Pa.C.S. § 1301 (Registration and certificate of title required) b. 75 Pa.C.S. § 3309 (Driving on roadways laned for traffic) C. 75 Pa.C.S. § 3334 (Turning movements and required signals) d. 75 Pa.C.S. § 1606 (Requirement for commercial driver's license) e. 75 Pa.C.S. § 4921 (Width of vehicles) f. 75 Pa.C.S. § 4529 (Slow moving vehicle emblem) 23. As a direct and proximate result of one or more of the aforesaid violations, the farm tractor and trailer driven by Defendant Jesse L. Jones violently collided with Plaintiff John E. Mumma's vehicle. 24. As a direct and proximate result of the aforesaid collision, Plaintiff John E. Mumma suffered injuries of a personal and pecuniary nature, including but not limited to: medical expenses, lost income from the running of his business, damage to property, pain and suffering, and physical and emotional trauma, all of which are permanent. WHEREFORE, Plaintiff, John E. Mumma, asks for a judgment in his favor and against Defendant Jesse L. Jones in a sum in excess of $50,000.00. COUNT IV: PLAINTIFF JOHN E. MUMMA v. JASON JONES - NEGLIGENCE PER SE 25. Paragraphs 1-24 are incorporated herein as if set forth at length. 26. At the aforesaid time and place, while engaged in Defendant Jason Jones' business and for Defendant Jason Jones' benefit, Defendant Jesse L. Jones did negligently, carelessly and recklessly violate one or more of the following statutes that were designed to protect Plaintiff John E. Mumma from harm and damages: a. 75 Pa.C.S. § 1301 (Registration and certificate of title required) b. 75 Pa.C.S. § 3309 (Driving on roadways laned for traffic) 75 Pa.C.S. § 3334 (Turning movements and required signals) d. 75 Pa.C.S. § 1606 (Requirement for commercial driver's license) 75 Pa.C.S. § 4921 (Width of vehicles) f. 75 Pa.C.S. § 4529 (Slow moving vehicle emblem) 27. As a direct and proximate result of one or more of the aforesaid violations, the farm tractor and trailer driven by Defendant Jesse L. Jones while engaged in Defendant Jason Jones' business and for Defendant Jason Jones' benefit violently collided with Plaintiff John E. Mumma's vehicle. 28. As a direct and proximate result of the aforesaid collision, Plaintiff John E. Mumma suffered injuries of a personal and pecuniary nature, including but not limited to: medical expenses, lost income from the running of his business, damage to property, pain and suffering, and physical and emotional trauma, all of which are permanent. WHEREFORE, Plaintiff, John E. Mumma, asks for a judgment in his favor and against Defendant Jason Jones in a sum in excess of $50,000.00. COUNT V: PLAINTIFF JANICE M. MUMMA v. JESSE L. JONES - LOSS OF CONSORTIUM 29. Paragraphs 1-28 are incorporated herein as if set forth at length. 30. Prior to June 29, 2009, Plaintiff Janice M. Mumma was legally married to Plaintiff John E. Mumma, and as husband and wife, each became entitled to the companionship, society, guidance, material services and consortium of their respective spouses during the period of coverture. 31. As a result of the injuries to her spouse, Plaintiff Janice M. Mumma was deprived, and will in the future be deprived, of the companionship, society, guidance, material services and consortium of her spouse. WHEREFORE, Plaintiff, Janice M. Mumma, asks for a judgment in her favor and against Defendant Jesse L. Jones in a sum in excess of $50,000.00. COUNT VI: PLAINTIFF JANICE M. MUMMA v. JASON JONES - LOSS OF CONSORTIUM 32. Paragraphs 1-31 are incorporated herein as if set forth at length. 33. Prior to June 29, 2009, Plaintiff Janice M. Mumma was legally married to Plaintiff John E. Mumma, and as husband and wife, each became entitled to the companionship, society, guidance, material services and consortium of their respective spouses during the period of coverture. 34. As a result of the injuries to her spouse, Plaintiff Janice M. Mumma was deprived, and will in the future be deprived, of the companionship, society, guidance, material services and consortium of her spouse. WHEREFORE, Plaintiff, Janice M. Mumma, asks for a judgment in her favor and against Defendant Jason Jones in a sum in excess of $50,000.00. COUNT VII: PLAINTIFF CARLISLE ELECTRIC, INC. v. JESSE L. JONES - PROPERTY DAMAGE 35. Paragraphs 1-34 are incorporated herein as if set forth at length. 36. As a direct and proximate result of the conduct of Defendant Jesse L. Jones, as alleged herein, Plaintiff Carlisle Electric, Inc. was caused to suffer property damage in an amount, scope and extent not fully known and subject to proof at trial but approximately $20,000.00. WHEREFORE, Plaintiff, Carlisle Electric, Inc., asks for a judgment in its favor and against Defendant Jesse L. Jones in a sum not in excess of $50,000.00. COUNT VIII: PLAINTIFF CARLISLE ELECTRIC. INC. v. JASON JONES - PROPERTY DAMAGE 37. Paragraphs 1-36 are incorporated herein as if set forth at length. 38. As a direct and proximate result of the conduct of Defendant Jesse L. Jones while engaged in Defendant Jason Jones' business and for Defendant Jason Jones' benefit, as alleged herein, Plaintiff Carlisle Electric, Inc. was caused to suffer property damage in an amount, scope and extent not fully known and subject to proof at trial but approximately $20,000.00. WHEREFORE, Plaintiff, Carlisle Electric, Inc., asks for a judgment in its favor and against Defendant Jason Jones in a sum not in excess of $50,000.00. Respectfully Submitted, Date' TURO ROBINSON Paul M. Ferguson Supreme Ct. No. 203293 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ??V'/0 Date/ ohn E. Mumma ?z8 kO --? ate J ice M. Mumma Date' Date resident, Carlisle Electric, Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor John E. Mumma (et al.) vs. Jason Jones (et al.) ~a,~r~tt' ot~ ~'~iiriC,i~,.~~~~c~ ca4- . F .. ~wi~~ ~~~~ 1~t8~'IA1' IZ AEI $t 48 L'+~dt~ ~~~~ Case Number 2010-2988 SHERIFF'S RETURN OF SERVICE 05/07/2010 08:03 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to I w, states that on May 7, 2010 at 1957 hours, he served a true copy of the within Complaint and Notice, on':the within named defendant, to wit: Jason Jones, by making known unto himself personally, at 93 W st Old York Road, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at ~~~m tim handing to him personally the said true and correct copy of the same. I r, DEPUTY 05/07/2010 08:03 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to la ,states that on May 7, 2010 at 1957 hours, he served a true copy of the within Complaint and Notice, up n he within named defendant, to wit: Jesse L. Jones, by making known unto himself personally, at 9 1 est Old York Road, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at t me ime handing to him personally the said true and correct copy of the same. ~~ / ~ SF}~AWN HARRISON, DEPUTY SHERIFF COST: $49.84 May 10, 2010 SO ANSWERS, ~~ RON R ANDERSON, SHERIFF ~cj Goun'ySutte Sher;Yt, Teleosoft. Inc. 10-009307 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Jesse L. Jones and Jason Jones JOHN E. MOMMA, JANICE M. MOMMA AND CARLISLE ELECTRIC, INC., PLAINTIFFS ~. '~"` ~ it ry a 2010rt~Y ~0 P-~ 2: S9 ~~r~r~"~~,1J~~d;.~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 - 2988 VS. JESSE L. JONES AND JASON JONES, DEFENDANTS CIVIL ACTION -LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendants, Jesse L. Jones and Jason Jones. The Defendants reserve the right to otherwise plead in this matter. Respectfully submitted FFIC F DER & DORER Date: May 19, 2010 By: Donald R. Dorer, Esquire Attorney for Defendants Court I.D. No. 39126 10-009307 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Jesse L. Jones and Jason Jones JOHN E. MUMMA, JANICE M. MUMMA AND CARLISLE ELECTRIC, INC., PLAINTIFFS VS. JESSE L. JONES AND JASON JONES, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 - 2988 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 Enter of Appearance to be served by regular first class mail upon: Paul M. Ferguson, Esquire Turo Robinson 28 South Pitt Street Carlisle, PA 17013 Attorney for Plaintiffs Date:_ Mav 19, 2010 r Donald R. Dorer, Esquire Attorney for Defendants ~r ,~F THE F;~~"°~! ~ :~ ,'• r~?Y ,,_. . ~~i 10-009307 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Jesse L. Jones and Jason Jones 2010 .~u`~ I ~+ PPS ~ ~ ~i~ :.,~., ,..,~~~,~~~ i PEl`~h5~'LVr,N~,~ JOHN E. MUMMA, JANICE M. MUMMA AND CARLISLE ELECTRIC, INC., PLAINTIFFS VS. JESSE L. JONES AND JASON JONES, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 - 2988 CIVIL ACTION -LAW JURY TRIAL DEMANDED ANSWER TO COMPLAINT WITH NEW MATTER 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8.-11. Denied. Paragraphs 8 through 11 of Plaintiffs' Complaint are generally denied pursuant to Pa. R.C.P. §1029(e). WHEREFORE, Defendants, Jesse L. Jones and Jason Jones, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. COUNT I Plaintiff John E. Mumma v. Jesse L. Jones Negligence 12. Paragraphs 1 through 11 are incorporated herein by reference, and made a part hereof as if set forth in full. 13. Admitted. 14. The allegations in paragraph 14, including subparagraphs 14(a) through 14(f) of the Complaint are conclusions of law to which no response is required. To the extent any allegations herein are deemed factual in nature, said allegations are denied generally pursuant to Pa. R.C.P. 1029(e). 15.-16. Denied. Paragraphs 15 and 16 of Plaintiffs' Complaint are generally denied pursuant to Pa. R.C.P. §1029(e). WHEREFORE, Defendants, Jesse L. Jones and Jason Jones, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. 2 COUNT II Plaintiff, John E. Mumma v. Jason Jones Negliaence 17. Paragraphs 1 through 16 are incorporated herein by reference, and made a part hereof as if set forth in full. 18.-19. The allegations in paragraphs 18 and 19, including subparagraphs 18(a) through 18(f) of the Complaint are conclusions of law to which no response is required. To the extent a response is deemed necessary, said allegations are denied generally pursuant to Pa. R.C.P. 1029(e). 20. Denied. Paragraph 20 of Plaintiffs' Complaint is generally denied pursuant to Pa. R.C.P. §1029(e). WHEREFORE, Defendants, Jesse L. Jones and Jason Jones, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. COUNT III Plaintiff, John E. Mumma v. Jesse L. Jones Negliaence Per se 21. Paragraphs 1 through 20 are incorporated herein by reference, and made a part hereof as if set forth in full. 22. The allegations in paragraph 22, including subparagraphs 22(a) through 22(f) of the Complaint are conclusions of law to which no response is required. To the extent a response is deemed necessary, said allegations are denied generally pursuant to Pa. R.C.P. 1029(e). 3 23.-24. Denied. Paragraphs 23 and 24 of Plaintiffs' Complaint are generally denied pursuant to Pa. R.C.P. §1029(e). WHEREFORE, Defendants, Jesse L. Jones and Jason Jones, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. COUNT IV Plaintiff. John E. Mumma v. Jason Jones Negligence Per se 25. Paragraphs 1 through 24 are incorporated herein by reference, and made a part hereof as if set forth in full. 26.-27. The allegations in paragraphs 26 and 27, including subparagraphs 26(a) through 26(f) of the Complaint are conclusions of law to which no response is required. To the extent a response is deemed necessary, said allegations are denied generally pursuant to Pa. R.C.P. 1029(e). 28. Denied. Paragraph 28 of Plaintiffs' Complaint is generally denied pursuant to Pa. R.C.P. §1029(e). WHEREFORE, Defendants, Jesse L. Jones and Jason Jones, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. 4 COUNT V Plaintiff, Janice M. Mumma v. Jesse L. Jones Loss of Consortium 29. Paragraphs 1 through 28 are incorporated herein by reference, and made a part hereof as if set forth in full. 30-31. Denied. Paragraphs 30 and 31 of Plaintiffs' Complaint are generally denied pursuant to Pa. R.C.P. §1029(e). WHEREFORE, Defendants, Jesse L. Jones and Jason Jones, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. COUNT VI Plaintiff. Janice M. Mumma v. Jason Jones Loss of Consortium 32. Paragraphs 1 through 31 are incorporated herein by reference, and made a part hereof as if set forth in full. 33.-34. Denied. Paragraphs 33 and 34 of Plaintiffs' Complaint are generally denied pursuant to Pa. R.C.P. §1029(e). WHEREFORE, Defendants, Jesse L. Jones and Jason Jones, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. s COUNT VII Plaintiff, Carlisle Electric, Inc. v. Jesse L. Jones Property Damage 35. Paragraphs 1 through 34 are incorporated herein by reference, and made a part hereof as if set forth in full. 36. Denied. Paragraph 36 of Plaintiffs' Complaint is generally denied pursuant to Pa. R.C.P. §1029(e). WHEREFORE, Defendants, Jesse L. Jones and Jason Jones, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. COUNT VIII Plaintiff. Carlisle Electric. Inc. v. Jason Jones Progertv Damage 37. Paragraphs 1 through 36 are incorporated herein by reference, and made a part hereof as if set forth in full. 38. Denied. Paragraph 38 of Plaintiffs' Complaint is generally denied pursuant to Pa. R.C.P. §1029(e). WHEREFORE, Defendants, Jesse L. Jones and Jason Jones, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. 6 NEW MATTER 39. Paragraphs 1 through 38 are incorporated herein by reference, and made a part hereof as if set forth in full. 40. The Plaintiffs' claims for non-pecuniary damages may be barred by the limited tort option of the Pennsylvania Motor Vehicle Financial Responsibility Act pursuant to 75 Pa. C.S.A. §1705. 41. The Plaintiffs' claims for medical expenses and/or wage losses may be barred, or should be reduced, pursuant to §1722 of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, Defendants, Jesse L. Jones and Jason Jones, respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. Respectfully submitted, ER & DORER Date: June 11.2010 By: Attorney for Defendants Court I.D. No. 39126 10-009307 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Jesse L. Jones and Jason Jones JOHN E. MOMMA, JANICE M. MOMMA AND CARLISLE ELECTRIC, INC., PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JESSE L. JONES AND JASON JONES, DEFENDANTS NO. 10 - 2988 CIVIL ACTION -LAW JURY TRIAL DEMANDED VERIFICATION DONALD R. DORER, ESQUIRE, hereby states that he is the attorney for Defendants, Jesse L. Jones and Jason Jones in this action, and is authorized to verify that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: June 11.2010 ~' Donald R. Dorer, Esq~t(re Attorney for Defendants, Jesse L. Jones and Jason Jones Identification No. 39126 10-009307 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Jesse L. Jones and Jason Jones JOHN E. MOMMA, JANICE M. MOMMA AND CARLISLE ELECTRIC, INC., PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JESSE L. JONES AND JASON JONES, DEFENDANTS NO. 10 - 2988 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 Answer to Complaint with New Matter to be served by regular first class mail upon: Paul M. Ferguson, Esquire Turo Robinson 28 South Pitt Street Carlisle, PA 17013 Attorney for Plaintiff ~ Date: June 11.2010 Donald R. Dorer, Esquire Attorney for Defendants f . ~t r~r~l i. ., ~.j JOHN E.1'vfU~IMA,,; ~ ;q,~' ~g JANICE M. M~M1C~A; and CARLISLE ELECTRIC, INC. Plaintiffs v. JESSE L. JONES, and JASON JONES, Defendants ZQ(0.~~l~d 24 i'~ 3~ ~5 CU~,~~> ~ ~JtJ` IN T>~~";~Q~~T~TQI~~OMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 - 2988 CIVIL TERM JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO DEFENDANTS' NEW MATTER 39. Paragraphs 1-38 are incorporated herein as if set forth at length. 40. Paragraph 40 of Defendants' New Matter is a conclusion of law to which no response is required. To the extent a response is required, the allegation is denied. 41. Paragraph 41 of Defendants' New Matter is a conclusion of law to which no response is required. To the extent a response is required, the allegation is denied. WHEREFORE, Plaintiffs John E. Mumma, Janice M. Mumma and Carlisle Electric, Inc. ask for a judgment in their favor and against Defendants Jesse L. Jones and Jason Jones in a sum in excess of $50,000.00. Respectfully Submitted, TURO ROBINSON Date Paul M. Ferguson Supreme Ct. No. 203293 28 South Pitt Street Carlisle, PA 17013 (717)245-9688 Attorney for Plaintiffs VERIFICATION I verify that the statements made in the foregoing Plaintiffs' Reply to Defendant's New Matter are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. f t D e ~~ohn E. Mumma ~4 > ~ h Date Janice M. Mumma ~, / 0 ~, ate esident, Carlisle Electric, Inc. JOHN E. MUMMA, : IN THE COURT OF COMMON PLEASOF JANICE M. MUMMA, and :CUMBERLAND COUNTY, PENNSYLVANIA CARLISLE ELECTRIC, INC. . Plaintiffs NO. 10 - 2988 CIVIL TERM v. JESSE L. JONES, and . JASON JONES, Defendants :JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Paul M. Ferguson, hereby certify that on this day, I served a true and correct copy of Plaintiffs' Reply to Defendants' New Matter, by depositing same in the United States Mail, first class, postage pre-paid, from Carlisle, Pennsylvania, addressed as follows: Donald R. Dorer, Esquire Law Office of Snyder &Dorer 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 TURD ROBINSON UCH ~ v ro ~ ./~~__ Dat Paul M. Ferguson Supreme Ct. No. 203293 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiffs 10-009307 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Jesse L. Jones and Jason Jones 2010 J~ 30 P~~ 12~ 5~ CU~~I~~..,.. ~, ''..;-ii~IY ~%~P,~'rv~'r ~Vr,1'~~`~'. JOHN E. MOMMA, JANICE M. MOMMA AND CARLISLE ELECTRIC, INC., PLAINTIFFS VS. JESSE L. JONES AND JASON JONES, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 10 - 2988 CIVIL ACTION -LAW JURY TRIAL DEMANDED PRAECIPE TO SUBSTITUTE VERIFICATIONS TO THE PROTHONOTARY: Kindly substitute the attached Verifications to Answer to Complaint with New Matter for the attorney's Verification that had been filed with the Court on or about June 14, 2010. Date: June 29. 2010 Respectfully submitted, LA1~,PfF~ICE OF Donald R. Dorer,`Esq~ire Attorney for Defendants Court I.D. No. 39126 DORER 10-009307 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Jesse L. Jones and Jason Jones JOHN E. MUMMA, JANICE M. MUMMA AND CARLISLE ELECTRIC, INC., PLAINTIFFS VS. JESSE L. JONES AND JASON JONES, DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 - 2988 CIVIL ACTION -LAW JURY TRIAL DEMANDED VERIFICATION I, Jason Jones verify that the statements made in the foregoing Answer to Complaint with New Matter 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. I understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete and I leave the determination of these matters to my attorneys on their advice. I understand that all statements herein are made subject to the penalties of 18 Pa. G.S.A. §4904, relating to unsworn falsifications to authorities. Dated: ~ -!~ -ld Jaso Jones 10-009307 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 600 Camp HIII, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Jesse L. Jones and Jason Jones JOHN E. MOMMA, aZANICE M. MOMMA AND CARLISLE ELECTRIC, INC., PLAINTIFFS 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JESSE L. JONES AND JASON .ZONES, DEFENDANTS NO. 10 - 2988 CIVIL ACTION -LAW JURY TRIAL DEMANDED VERIFICATION I, Jesse L. Jones verify that the statements made in the foregoing Answer to Complaint with New Matter 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. I understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete and I leave the determination of these matters to my attorneys on their advice. I understand that all statements herein are made subje~t)~o the penalties of 18 Pa. C.S.A. §4904, xelating to unsworn falsifications to oa,ea ~/~ 10-009307 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Jesse L. Jones and Jason Jones JOHN E. MOMMA, aIANICE M. MOMMA AND CARLISLE ELECTRIC, INC., PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. JESSE L. JONES AND JASON JONES, DEFENDANTS No. 10 - 2988 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 Praecipe to Substitue Verifications to be served by regular first class mail upon: Paul M. Ferguson, Esquire Turo Robinson 28 South Pitt Street Carlisle, PA 17013 Attorney for Date: June 29. 2010 Attorney for Defendants 10-009307 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Jesse L. Jones and Jason Jones JOHN E. MUMMA, JANICE M. MUMMA AND CARLISLE ELECTRIC, INC., D-L1 ?i t IGG i_ E5I. NOT?"i `,U,t13[RLAt1'O COUNTY .,1ENNSYLVOIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFFS VS. No. 10 - 2988 JESSE L. JONES AND JASON JONES, DEFENDANTS CIVIL ACTION - LAW JURY TRIAL DEMANDED MOTION FOR PRE-TRIAL STATUS CONFERENCE OF DEFENDANTS, JESSE L. JONES AND JASON JONES AND NOW, come the Defendants, Jesse L. Jones and Jason Jones, by and through their attorney, Donald R. Dorer, Esquire, and respectfully represent as follows: 1. This lawsuit, initiated in or about May 5, 2010, arises out of an automobile/tractor accident occurring on June 29, 2009 on Route 465 in Dickinson Township, Cumberland County, Pennsylvania. 2. Counsel for the Plaintiffs, John E. Mumma, Janice M. Mumma and Carlisle Electric, Inc., is Paul M. Ferguson, Esquire, Turo Robinson, 129 South Pitt Street, Carlisle, Pennsylvania 17013, telephone number (717) 245-9688. 3. Undersigned counsel for Defendants, Jesse L. Jones and Jason Jones, is Donald R. Dorer, Esquire, Law Office of Snyder & Dorer, 214 Senate Avenue, Suite 600, Camp Hill, Pennsylvania 17011, telephone (717) 731-0988. 4. Pleadings were closed on or about June 24, 2010. 5. The discovery between the parties hereto is ongoing. The parties submitted to discovery depositions on March 1, 2011. It is believed that the parties may desire to complete additional discovery before trial. 6. This matter has not yet been assigned to a Judge for disposition. 7. By letter dated March 4, 2011, counsel for Defendants notified counsel for the Plaintiffs of his intention to file a Motion for Pre-trial Status Conference. The letter dated March 4, 2011 is attached hereto as Exhibit "A". No objection was received by counsel for the Plaintiffs. 8. Defendants, Jesse L. Jones and Jason Jones, are requesting the conducting of a Pre-trial Status Conference to set forth appropriate deadlines with regard to the completion of any further discovery which may be deemed necessary by any of the other parties hereto, and to set a trial date, in the discretion of the Court. WHEREFORE, for the foregoing reasons, this Honorable Court is respectfully requested to schedule a Pre-trial Status Conference in the above matter. Respectfully submitted, LA`. OFFICE OF NYDER & DORER r Date: April 8. 2011 b6WdfR. Dor-&, Esquire Attorney for Defendants Identification No. 39126 ????'? c: kl.E ? d ?a u? c? W M ? LAW OFFICE OF SNYDER & DORER LAW OFFICE OF JILL R. SNYDER Bethlehem, PA 18017 Employees of Nationwide Mutual Insurance Company@ Not a Partnership SNYDER & ANDREWS Wexford, PA 15090 SNYDER & BARRETT Philadelphia, PA 19103 SNYDER & VERBEKE CONSHOHOCKEN, PA 19428 214 SENATE AVENUE, SUITE 600 CAMP HILL, PENNSYLVANIA 17011 (717) 731-0988 (FAX) (717) 731-0987 SNYDER & ASSOCIATES Plains, PA 18705 SNYDER & SHAFFER DOYLESTOWN, PA 18901 REPLY TO: CAMP HML DONALD R. DORER JOANNE E. KINZEL Refer to: 10-009307 Paul M. Ferguson, Esquire Turo Robinson 129 South Pitt Street Carlisle, PA 17013 March 4, 2011 PARALEGALS CINDY M. BOOK LISA S. KEYTON Re: John E. Mumma, Janice M. Mumma and Carlisle Electric, Inc. vs. Jesse L. Jones and Jason Jones Cumberland County: No. 10-2988 Dear Mr. Ferguson, In follow up to the party depositions held in your office on March 1, 2011, and as we discussed thereafter, I am requesting you address or provide the following matters: 1. Updated scar photographs; 2. Financial/tax records to the extent quantifiable business income losses will be presented; 3. Confirmation of recoverable medical expenses/liens Although we may soon arrange other depositions, such as the witnesses noted on the police report, as well as the investigating officer, I anticipate we will be requesting that the Court arrange a Pre-trial Status Conference to confirm discovery deadlines and other pre-trial matters Thank you for your further attention to this matter. Sincerely yours, Donald R. Dorer DRD:tgb 10-009307 LAW OFFICE OF SNYDER & DORER 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants, Jesse L. Jones and Jason Jones JOHN E. MUMMA, JANICE M. MUMMA AND CARLISLE ELECTRIC, INC., PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JESSE L. JONES AND JASON JONES, DEFENDANTS No. 10 - 2988 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 Motion for Pre-trial Status Conference of Defendants. Jesse L. Jones and Jason Jones to be served by electronic mail only upon: Paul M. Ferguson, Esquire Turo Robinson 129 South Pitt Street Carlisle, PA 17013 Attorney for Plaintiffs Date: April 8. 2011 D&Wd R. Dorer, Esquire Attorney for Defendants Z 10-009307 JOHN E. MOMMA, JANICE M. MUMMA AND CARLISLE ELECTRIC, INC., PLAINTIFFS VS. JESSE L. JONES AND JASON JONES, DEFENDANTS IN THE COURT OF COMMON PLEAS ANIA V CUMBERLAND COUNTY, PENNSYL ? ? C e- ? C?D .-VI rn -a -U No. 10 - 2988 < i ri c ° <? =° ;ZC) c:?-n :Z Z_3 AC= W QU-7 CIVIL ACTION - LAW v JURY TRIAL DEMANDED ORDER OF COURT AND NOW, this day of , 2011, upon consideration of the within Motion for Pre-trial Status Conference of Defendants, Jesse L. Jones and Jason Jones, it is hereby ORDERED that a Status Conference shall be held on the day of , 2011, at •3? -.M. in Chambers of the Cumberland County Courthouse, One Courthouse Square Carlisle, Pennsylvania 17013. It is so ordered. BY THE COURT, Distribution: `Paul M. Ferguson, Esquire Turo Robinson 129 South Pitt Street Carlisle, PA 17013 Telephone No. (717) 245-9688 Fax No. (717) 245-21665 Attorney for Plaintiffs, John E. Mumma, Janice M. Mumma and Carlisle Electric, 0?fil Inc. CoP?r..III II p 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 Defendants, Jesse L. Jones and Jason Jones FILED-vFICE OF THC PR07g0N0TJt yf 2011 JUL 25 PM ?JOHN E. MUMMA, COURT OF COMMON PLEASOF JANICE M. MUMMA, aridUMBEfi?-a?0 COUGUMBERLAND COUNTY, PENNSYLVANIA CARLISLE ELECTRIC, INCfEIVNSYLVANI,A Plaintiffs : NO. 10 - 2988 CIVIL TERM V. JESSE L. JONES, and JASON JONES, Defendants : JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Plaintiffs certify 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) counsel for Defendants raised no objection and waived the 20 day notice period, 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. TURO ROBINSON Attorneys at Law O 7 as l Date/ I Paul M. Ferguson ' Supreme Ct. No. 203293 129 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiffs EXHIBIT A JOHN E. MUMMA, JANICE M. MUMMA, and CARLISLE ELECTRIC, INC. Plaintiffs V. JESSE L. JONES, and JASON JONES, Defendants IN THE COURT OF COMMON PLEASOF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10 - 2988 CIVIL TERM JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 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 may be served. TURD ROBINSON Attorneys at Law o'? Date Paul M. Ferguson ' Supreme Ct. No. 203293 129 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiffs ?`?_ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND John E. Mumma, Janice M. Mumma, and Carlisle Electric, Inc., Plaintiff File No. 10 - 2988 vs. Jesse L. Jones and Jason Jones, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Pennsylvania Department of Transportation (PennDOT), Bureau of Driver Licensing (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: The entire, complete and full driving record and history of Jesse Leroy Jones; date of birth: October 28, 1982; current address: 531 West Old York Road, Carlisle, PA 17015; Pennsylvania Driver's License No. 26283997 at Turo Robinson, Attorneys at Law, 129 South Pitt Street, Carlisle, PA 17013 (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: Paul M. Ferguson - Turo Robinson ADDRESS: 129 South Pitt Street PA 17013 TELEPHONE: (717)245-9688 SUPREME COURT ID # 203293 ATTORNEY FOR: Plaintiffs BY THE COURT: `blc?b T----? Prothonotary, Civil Division Date: Seal of the Court Deputy JOHN E. MUMMA, : IN THE COURT OF COMMON PLEASOF JANICE M. MUMMA, and : CUMBERLAND COUNTY, PENNSYLVANIA CARLISLE ELECTRIC, INC. Plaintiffs NO. 10 - 2988 CIVIL TERM V. JESSE L. JONES, and JASON JONES, Defendants : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Paul M. Ferguson, hereby certify that on this day I served a copy of the foregoing Notice of Intent to Serve A Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 upon the following person by mailing the same via the United States Mail, first class, to the following address: Donald R. Dorer, Esquire Law Office of Snyder & Dorer 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 TURO ROBINSON Attorneys at Law a7 Date Paul M. Ferguson Supreme Ct. No. 203293 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiffs i JOHN E. MUMMA, JANICE M. MUMMA, and CARLISLE ELECTRIC, INC. Plaintiffs : NO. 10 - 2988 CIVIL TERM V. Donald R. Dorer, Esquire Law Office of Snyder & Dorer 214 Senate Avenue, Suite 600 Camp Hill, PA 17011 TURO ROBINSON Attorneys at Law JESSE L. JONES, and JASON JONES, Defendants IN THE COURT OF COMMON PLEASOF CUMBERLAND COUNTY, PENNSYLVANIA JURY TRIAL DEMANDED CERTIFICATE OF SERVICE 1, Paul M. Ferguson, hereby certify that on this day I served a copy of the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 upon the following person by mailing the same via the United States Mail, first class, to the following address: c 7 ')- // Date Paul M. Ferguson Supreme Ct. No. 203293 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiffs JOHN E. MUMMA, : IN THE COURT OF COMMON PLEASOF JANICE M. MUMMA, and : CUMBERLAND COUNTY, PENNSYLVANIA CARLISLE ELECTRIC, INC. Plaintiffs NO. 10 - 2988 CIVIL TERM V. JESSE L. JONES, and _C= ` JASON JONES, a -; rn Defendants : JURY TRIAL DEMANDED y° ' o --< v? ff NOTICE an To Pennsylvania De partment of Transportation (PennDOT), Bureau of Driver Licensi n?: You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, L.,U S,4 C f certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the subpoena issued on July 19, 2011 have been produced. Date kit, Signature Qev-sR Aep,( Please Print Name Pennsylvania Department of Transportation Bureau of Driver Licensing