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HomeMy WebLinkAbout01-0766 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDALL WILLIAM NICHOLL, Plaintiff CIVIL ACTION - LAW LEESA V. COONS, a/k/a LEESA VAUGHN SPOGLI, Defendant NO. Ol- JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty' (20) days after this Complaint 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 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 LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 226661.1\RAS\MLB IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDALL WILLIAM NICHOLL, Plaintiff CIVIL ACTION - LAW LEESA V. COONS, a/Wa LEESA VAUGHN SPOGLI, Defendant NO. JURY TRIAL DEMANDED NOT1CIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas sugnuientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la nofificacion. Usted debe presentar m~a apariencia escrita o en persona o por abogado y archivar en la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL D1NERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEPFONO A LA 0FIC1NA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA J0 PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 226661 1 \RASLMLB IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDALL WILLIAM NICHOLL, Plaintiff LEESA V. COONS, a/k/a LEESA VAUGHN SPOGLI, Defendant CIVIL ACTION - LAW NO. o J- 7C 6 C~5~ 7'-~,~ JURY TRIAL DEMANDED COMPLAINT 1. Plaintiff Randall William Nicholl is an adult individual who resides at 19 Citadel Drive, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant Leesa V. Coons, Mc/a Leesa Vaughn Spogli (hereinafter known as Leesa V. Coons) is an adult individual who resides at 5 Clemson Drive, Camp Hill, Cumberland County, Pennsylvania. 3. The facts and occurrences hereinafter related took place on or about May 5, 1999 at approximately 6:48 a.m. at the intersection of Colgate and Citadel Drive, Cumberland County, Pennsylvania. 4. At that time and place, Plaintiff Randall William Nicholl was operating a 1986 Ford F150. 5. At that time and place, Plaintiff Randall William Nicholl vehicle was traveling in a westerly direction on Citadel Drive. 225393\RAS\MLB 6. At that time and place, Defendant Leesa V. Coons was operating a 1993 Honda Accord in a northerly direction on Colgate Drive. At that time and place, traffic traveling north on Colgate Drive is controlled by a stop sign. 8. At that time and place, Defendant Coons failed to properly stop at the posted stop sign on Colgate Drive, and suddenly without warning, entered the intersection of Colgate Drive and Citadel Drive and struck Randall Nicholl's vehicle. 9. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff Randall William Nicholl are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant Coons operated her motor vehicle as follows: (a) failure to keep alert and maimain a proper watch for the presence of other motor vehicles on the highway; (b) failure to stay within her lane of travel; (c) failure to keep a proper watch for traffic on the highway; (d) failure to driver her vehicle with due regard for the highway and traffic conditions which were existing and of which she was or should have been aware; (e) failure to keep proper and adequate control over her vehicle (f) failure to have her vehicle trader such control as to be able to stop within the assured clear distance ahead; (g) failure to stop at a posted stop sign; (h) failure to apply her brakes in sufficient time to avoid Plaintiffs' vehicle; 225393\RASLMLB 2 (i) failure to travel at a safe speed; failure to yield the right of way to Plaintiff's vehicle; and (k) driving her vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 10. Plaintiff Randall William Nicholl sustained painful and severe injuries which include but are not limited to cervical sprain, myofascial pain syndrome, and headaches. 11. By reason of the aforesaid injuries sustained by Plaintiff Randall William Nicholl, he was forced to incur liability for medical treatment, medications, physical therapy, and similar miscellaneous expenses in an effort to restore himself to health, and claim is made therefor. 12. Because of the nature of his injuries, Plaintiff Randall William Nicholl has been advised and, therefore, avers that he may be forced to incur similar expenses in the future, and claim is made therefor. 13. As a result of the aforementioned injuries, Plaintiff Randall William Nicholl has undergone and in the future will undergo great physical and mental suffering, inconvenience in carrying out his daily activities, loss of life's pleasures and enjoyment, and claim is made therefor. 14. As a result of the aforesaid injuries, Plaintiff Randall William Nicholl has been and in the future will be subject to htmailiation and embarrassment, and claim is made therefor. 225393\RAS~MLB 3 15. Plaintiff Randall William Nicholl continues to be plagued by persistent pain and limitation and, therefore, avers that his injuries may be of a permanent nature, causing residual problems for the remainder of his lifetime, and claim is made therefor. 16. As a result of the aforementioned injuries, Plaintiff Randall William Nicholl sustained uncompensated work loss, and claim is made therefor. 17. As a result of the aforementioned accident and resulting injuries, Plaintiff Randall William Nicholl has sustained loss of opportunity and a permanent diminution of his earning power and capacity, and claim is made therefor. WHEREFORE, Plaintiff Randall William Nicholl demands judgment against Defendant Leesa V. Coons in an amount in excess of Twenty Five Thousand Dollars ($25,000.00), exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. ANGINO & ROV~ 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Counsel for Plaintiff Date: February 6, 2001 225393\RAS\MLB 4 VERIFICATION I, Randall William Nichoil, Plaintiff, have read the foregoing PLAINTIFF'S COMPLAINT and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. Dated: ¢~/(~/ 225468.1\RAS\MLB SHERIFF'S RETURN - CASE NO: 2001-00766 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NICHOLL RANDALL WILLIAM VS COONS LEESA V ET AL REGULAR JASON VIORAL , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE was served upon COONS LEESA V A/K/A LEESA VAUGHN SPOGLI the DEFENDANT , at 0018:10 HOURS, on the 13th day of February , __ at 5 CLEMSON DRIVE CAMP HILL, PA 17011 LEESA COONS a Sheriff or Deputy Sheriff of who being duly sworn according to law, by handing to together with true and attested copy of COMPLAINT & NOTICE 2001 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.30 Affidavit .00 Surcharge 10.00 .00 37.30 Sworn and Subscribed to before me this ~ ~ day of So Answers: R. Thomas Kline 02115/2001 ANGINO & ROVNER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RANDALL WILLIAM NICHOLL, Plaintiff NO. 01-766 LEESA V. COONS, a/k/a LEESA : JURY TRIAL DEMANDED VAUGHN SPOGLI, : Defendant : PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of George H. Eager of Eager, Reinaker & Spinello as attorney of record on behalf of Defendant in the above captioned action. EAGER, REINAKER & SPINELLO George H. Eager, Esquire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for Entry of Appearance upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Richard A. Sadlock, Esquire Angino & Rovner 4503 N. Front Street Harrisburg, PA 17110 EAGER, REINAKER & SPINELLO George H/Eager,~ire Attorney for De~ndant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL ACTION - LAW PENNSYLVANIA RANDALL WILLIAM NICHOLL, : Plaintiff : NO. 01-766 LEESA V. COONS, a/k/a LEESA : JURY TRIAL DEMANDED VAUGHN SPOGLI, : Defendant : AND NOW COMES DEFENDANT, EAGER, ANSWER BY AND THROUGH HER ATTORNEY, GEORGE AND FILES THE FOLLOWING ANSWER: 5. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). 6. Admitted. 7. 17. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). WHEREFORE, Defendant asks that judgment be entered in her favor and against the Plaintiff on all claims set forth in Plaintiff's Complaint. EAGER, REINAKER & SPINELLO George H. Eag~f, Esquire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 VERIFICATION I, LEESA V. COONS, a/k/a LEESA VAUGFIN SPOGLI, hereby verify that I am the Defendant in the foregoing action, and that the averments of the foregoing Answers to Plaintiff's Complaint are true and correct to the best of my knowledge, information and belief. To the extent that any of the averments of the Answers to the Complaint are based upon an understanding or application of law, I have relied upon counsel in making this Verification. I understand that I am subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities for any false statements made herein. LEESA V. COONS, a/k/a LEESA VAUGHN SPOGLI CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Answer upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Richard A. Sadlock, Esquire Angino & Rovner 4503 N. Front Street Harrisburg, PA 17110 EAGER, REINAKER & SPINELLO George H/Eager,~e Attorney for ~endant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 EAGER, REINAKER, & SPINELLO ATTORNF~Y$ ~,T LAW 1347 FRUITVILLE PIKE LANCASTER, PENNSYLVANIA 17601 FAX (717) 29Q-7§78 iN THE COURT OF COHMON PLEAS OF CUHBERLAND CO~!NTY, PENNSYLVANIA CIVIL ACTION LAW RANDALL WiLLI}~ NICNOLL, Plaintiff LEESA V. C©ONS, a/k/a LEESN VAUGHN SPOGLI, Defendant NO. 01 766 JURY '~ ? ~ ~R±A~ DEMANDED CERT]iFICATE OE SERVICE HEREBY , ERTIFf that: I have this {Jay served att InterreaaEories ef Defendant Addressed to Plaintiff persoR sek forth below and in the manner indicated: Firs~ ciass mail, postage pre paid: Richaro A. Sadleck, Esquire Angino & Rovner 4503 N. Front Street Harrisburg, PA 17110 EAGER, REINAKEN ~ SPINELLC DATE: BY: George H. Eager, EsquLre Attorney for [~endank I.D No. 27'740 134'7 Fruitville Pike hancas[~e~ , PA 1'760 L (7!7) 290 7971 IEAGER, REINAKER, & SPINELLO ATTORN~.L~V~ AT LAW 1347 FRUi]¥1LLE PiKE LANCASTER, PENNSYLVANIA 17601 PNON~ (717/~ggJgT~ F~ (717) Z~0-7~7~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND _OUN1 ~, PENNSYLVANIA CIVIL ACTION - LAW RANDALL WILLIAM NICHOLL~ Plaintiff LEESA V. COONS, a/k/a LEESA VAUGHN SPOGLI, Defendant N .... 01766 JURY TRIAL DEMANDED CERTIFICATE OF £ERVIC__E I HEREBY CERTIFY that i have this day serwed a true anon co~reet copy of Defendant's Requegt fox' Produczion and l~pying of Documents Set No. I Directed to Plaintiff upon the pet.son set forth below and in the manner ~ndicated: First class mail, postage pre-paid: Richard A. Sadiock, Esquire Angino & Rovner 4503 N. Front Street Harrisburg~ PA 1711.0 EAGER, REINAKER & SP]iNt,iLLO ,' Attorney for Defendant. I.D. No. 27740 1347 Pruitviile Pike Lancaster, PA 17601 (717) 290~-79~i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RANDALL WILLIAM NICHOLL, : Plaintiff : LEESA V. COONS, a/k/a : LEESA VAUGHN SPOGLI, : Defendant : NO. 01-766 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, Defendant certifies that: (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RANDALL WILLIAM NICHOLL, Plaintiff vs. LEESA V. COONS, a/k/a LEESA VAUGHN SPOGLI, Defendant NO. 01-766 GURY TRIAL DEEDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT LEESA V. COONS, to serve notice. which to objection to the subpoena. may be served. a subpoena identical You have twenty (20) a/k/a LEESA VAUGHN SPOGLI, intends to the one that is attached to this days from the date listed below in file of record and serve upon the undersigned an If no objection is made, the subpoena DATE: ATTORNEY FOR DEFENDANT I.D. NO. 27740 1347 FRUITVILLE PIKE LANCASTER, PA 17601 (717) 290-7971 COMMONWE~TH OF PENNSYLVANIA COUNTY OF CUMBERLAND RANDALL WILLIAM NICHOLL, Plaintiff : LEESA V. COONS, a/k/a LESSA VAUGHN SPOGLI, Defendant No. 01-766 SUBPOENA TO PRODUCE DOCUMENTS OR TI~NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Orthopedic Institute of Pennsylvania, 875 Poplar Church Road Camp Hill, PA 17011-4226 Within twenty (20) days after setwice of thin subpoena, you are ordered by the court to produce the follow~g doonnents or firings: An~ and all first consultation reoorts, office notes, MRI, CT and x-ray films & reports, test results, physical therapy reports, nurses' notes & doctors' orders, along with any & all other medical records & reports at 1347 Fruirville Pike, Lancaster, Pennsylvania, 17601. concerning ~iaXntllt ~.anaall William Nlukull (Address) (DOB: 04/14/53) (SSN: 198-44-9228). You may deliver or re.il legible copies of the doo,me~ or produce thin? requested by thin SubpOena, together with the certificate of compliance, to the party mnkln~ thin ~U~ at the address listed above. You have the right to seek in advance the rcasonahle cost of preparing the copies or producing the thlnL~ ~ougbt. If you fail to produce the docmnents or thin~ required by this subpoena within twenty (20) days after its service, the party serving thi~ Subpoen~ may seek a court order coml~llin~ you to comply with it. Tl4l~q SUBPOENA WAS ISSUED AT THE REQUEST OF ~ FOLLOWING PERSON: NAME: George H. Eager, Esquire ADDRESS: 1347 Fruitville Pike Lancaster, PA 17601 T~J ,~PHON~: (717) 290-7971 SUPREME COURT ~) # 27740 ATTORNEY FOR: bef emdant BY ~ COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy coMMoNWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RANDALL WILLIAM NIC~OLL, Plaimtlff : : vs. : LEESA V. COONS,. a/k/a : LESSA VAUG~ SPOGLI, : ~ No. 01-766 SUBPOENA TO PRODUCE DO~ OR THINGS FOR DISCOVERY PURSUANT TO RUI,i~. 4009.2~ To: Keystone Spine Center, Inc., 1521 Cedar Cliff Drive, Camp Hill, PA 17011 W*~hln twenty (20) days~after service of tlds subpoena, you are ordered by the court to pre4~cot~efoU~mg~or*#~:An% and all first consultation reports,-office notes, ~iRI, CT and x-ray films & reports, test results, physical therapy reports, nurses' notes & doctors' orders, along with any &.all other medical records & reports · t 1347 Fruitville Pike, Lancaster, P-~nsylvamta, 17601. concer~lmg ~laint~ ~anaall Nllll~Nlul~ll (A4~ss) (DOB: 04/14/53)' (SSN: 198-44-9228). You my deliver or m~fl legible copies of the doo~ or produce thiogs requested by ehi~ subpoena, together with the certificate of complkmee, to the party making thi~ request at the address listed above. You bare the right to seek in advance the resmmable cost of preparing the copies or producing the things sought. If you fail to produce the doonnents or thin~s required by this subpo~ wffhln twenty (20) days after its service, the party serving this subpo~-~ may seek a court order erWnl~llng you to comply with it. THI,q SUBPOENA WAS ISSUED AT .TNi~ REQUEST OF ~ FOLLOWING PERSON: N~: George H. Eager,' Esquire ADDR][SS: 1347 Frui~ville Pike Lancaster. PA 17601 TI~I .~O1~: ('717) 29~7971 S~ CO~T '~ ~ 27740 A~O~Y ~R: D~ BY Tlq~, COURT:' DAT~: Seal of the Court Pcothonotary/Clerk, Ci~H Division COMMO~TU OF PENNSYLVANIA COUNTY OF CUMBERLAND RAlqDALL WILLI. AM NICHOLL, Plaintiff vs. LEESA V. COONS,. a/k/a LESSA VAUGHN SPOGLI, Def~4ant Fi/eNo. 01-766 SUBPOENA TO PRODUCE DO~ OR TI~INGS FOR DISCOVERY PURSUANT TO RLrLE 4009./2 Physicians of Rehab±litation~ Industrial & Spine Medicine, P.C. TO: 175 Lancaster Blvd., P.O. Box 2028, Mechanicsburg, PA 17055 W"~hln twenty (20) days after smwice of th~ mbpo~% you are ordered by the court to produce the foflow~gdocm~entsor thi~?~An~ an~ all first consultation revorts, office notes, HRI, CT and x-ray films & reports,, test results, physical therapy reports, nursest notes & doctors' orders, along with any &.all other medical records & reports a~ 1347 Fruitville Pike, Lancaster, Pwnneylvania, 17601. concerning Ylalntl=r Kanoall Wllll~Nluholl (Address) (DOB: 04/14/53)' (SSN: 198-44-9228). You nmy deliver or m.fl legible copies of the dor-n~-nts or produce things requested by this subpo~u, together with the certi~.t~ of compliance, to the Imrty making this request at the address listed above. You have the right to seek in advance the reas~uh~e co~t of preparing the copies or produdng the things soughL If you fail to produce tim doc-merits or thin~ ~ by this mbporua within twenty (20) days ILPt~r it8 service, the ~ serving th/. subls~.3~ m~y seek a coort order comp~il.g you to comply with it. T~H.~ SUBPOENA WAS ~ AT ~ REQUEST OF ~ FOLLOWING PERSON:. NAME: GeorgeH. Eager,'Esqufre ADDRESS: 1347 Fruirv~lle Pike Lancaster, PA 17601 ~[~.~PHO~: (?17) 290-7971 SUPREME COURTID# 27740 A~ORNEYFOI~ Def~-aant BY ~ COURT: DATE: ScM of th,~ Court Prothonotary/Clerk. CivQ D~sian coMlViO~T~ OF PEWNS'YLVANIA COUNTY OF CUM]IERLAND RANDALL WILLIAM NICHOLL. Plaintiff LEESA V. COONS.'. a/k/a LESSA VAUGM~ SPOGLI, D~f~-4ant FHe No. 01-766 SUBPOENA TO PRODUCE DO~ OR TUINGS FOR DISCOVERY PURSUANT TO RULI~. 4009.~ To: Jonathan Tocks, M.D., 4470 Valley Road, Enola, PA 17025 Vf~hln twenty (20) days at, er service of thi~ subpo,~-~ you are ordered by the court to produce the fo~ow~ug documents or th,ns. An% and all first consultation reports, office notes, M~I, CT and x-ray films & reports~ test results, physical therapy reports, nursesf notes & doctors' orders, along with any &. all other medical records & reports a~ 1347 Fruit-villa Pike. Lancaster, P--~eylvan/a, 17601. conceru~ng ~ta~ltl~z ~ndall (Address) (OOB: 04/14/53) (5SN: 198-44-9228). You may deliver or m.n le~bl~ cop~ of the demmmm~ or preduce ~f you fail to produce the d0or,-~-~ or thin~s required by this sublmena w~hln twenty (~20) days after its service, the party se/wing thi~ subpoena my seek a court order you to comply with iL T~ SUBPOENA WAS ISSI~ AT .Tm~ REQ~T OF TUF. FOI.I.OV~NG PERSON:, N~: George H. Eager,' Esquire ~D~: 1347 F~i~ille ~cas=er, PA 17601 'I~ f,~O~:. (717) 290-7971 S~ CO~T ~ $ 27740 A~O~Y FOR: BY ~ COURT: DAT~: 'Prothonotary/Clerk, Civil Division coMMo~TH OF PENNSYLV~ COUNTY OF CUMB~ RANDALL WILLIAtiNICHOLL, Plaintiff LEESA V. COONS, a/k/a LESSA VAUGHN SPOGLI, Defendant F~leNo. 01-766 SUBPOENA TO PRODUCE DO~ OR TIHNGS FOR DISCOVERY PURSUANT TO RULi~. 4~}9.22 TO: HeaithSouth, 503 Bridge Street, New Cumberland, PA 17070 Within twenty (20) days ~ service of this subpo~% you are ordered by the court to preduce the following doo-uem~s or thiokol: An~ and all first consultation re~orts, office notes, M~I, CT and x-ray films & reports, test results, physical therapy reports, nurses' notes & doctors' orders, along with any &.all other medical records & reports at 1347 Fruitville Pike, Lancaster, P~--sylvania, 17601. concerning M£aXntlIr Kanaall Will lam N iukull (Ad4re~) (DOE: 04/14/53) ' (SSN: 198-44-9228). You my do~ver or m.fl le~b~ ¢opi~ of the do~--~-~ or produ~ *~-? rz~m~x~ by this subpaena, together wRb the certificm~ of cempli--ce, to the party m~kiug thi, ~ at the address ~ above. You lmve the right to seek in advance the re~mable co~ of prepaz~ the gopie5 or ~rodtwln~ the thln~ ~ If you fail to produce the documents or thin~ required by this subpo~- within ~en~ (20) daYs after its service, the party serving th~s subpoon- may seek a com~ order compelling you to comply ~ it. Tl~.q SUBPOENA WAS ISSUED AT ~ REQUEST OF ~ FOLLOIVING PERSON:, NAu%~I~: George H. Eager, Esquire ADDHES$: 1347 Fruitville Pike Lancaster. PA 17601 '~,T ,'I~-PHOI~:. (717) 29~7971 ~ CO~T ~ ~ f7740 BY ~ COURT: DATE: the COllrt Prothoumary/Clerk, Civ~ Division coMMoNWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RANDALL WILLIAM NICHOLL, Plaintiff : : vs. : ~e No. 01-766 : : Defendant ' LEESA V. COONS, a/k/a LESSA VAUGHN SPOGLI, SUBPOENA TO PRODUCE DOCUbfl/2qTS OR THlrNGS FOR DISCOVERY PURSUANT TO RU~,E 4009,22 To: Erie Insurance Group, 100 Eric Insurance Place, Erie; PA 16530 W'~hin twenty (20) days after service o~hi~ sxibpoena, yo~ are ordered by the court to produce thefoHowing do~mnentsorthings: ~rsc party records concerning ~laintiff Randall W~llJmm Nicholl (DOB: 04/14/53) (SSN: 198-44-9228) Policy No.: Q10 1801824 H at 1347 Fruitville Pike, Lancaster, Pennsylvania, 17601. (Addr~) You my deliver or m~ii le~le copies of the documents or produce thln~o~ requested by thi~ subpoena, together with the certificate of compliance, to the party mnkin~ thi~ request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the thln~o~ SOUght. If you fail to produce the docnments or things required by thi~ subpo~nn within twenty (20) days after its service, the party serving thi~ subpoena m.y seek a court order comp~llln~ you to comply with it. SUBPOENA WAS ISSUED AT ~ REQUEST OF ~ FOI.LOWING PERSON: NAME: GeorgeH. Eager, Esquire ADD'SS: 1347 Frultville Pike Lancaster, PA 17601 T~I.RPHON~E: (717) 290-7971 SUPREME COURT ID # 27740 ATTORNEY FOR: Defendant BY ~ COURT: DATE: Seal of the Court ~Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I HEREBY CERTIFY that I am this day served a true and correct 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 person and in the manner indicated below. Service by First Class Mail, addressed as follows: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 (Attorney for Plaintiff) EAGER, REINAKER & SPINELLO BY:George , Esquire 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 Dated: CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 DATE: EAGER, REINAKER & SPINELLO Geor~ger, quire Attorney'for Dr~'~nd~nt I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NOTICE RANDALL WILLIAM NICHOLL Plaintiff No. 01-766 LEESA V. COONS, a/k/a LEESA VAUGHN SPOGLI CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a Subpoena for documents and th'rags pursuant to Rule 4009.22, Defendant, Leesa V. Coons, a/k/a Leesa Vaughn Spogli, certifies that (1) a Notice of Intent to serve the Subpoena with a copy of the Subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the Subpoena is sought to be served; (2) a copy of the Notice of Intent, including the proposed Subpoena, is attached to this Certificate; (3) no objection to the Subpoena has been received, and (4) the Subpoena which will be served is identical to the Subpoena which is attached to the Notice of Intent to serve the Subpoena. EAGER, REINAKER & SPINELLO 1347 Fmitville Pike Lancaster, PA 17601 (717) 290-7971 Dated: April 26, 2001 IN T}{E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL ACTION - LAW PENNSYLVANIA RANDALL WILLIAM NICHOLL, : Plaintiff : : NO. 01-766 VS. : LEESA V. COONS, a/k/a : JI/RY TRIAL DEMANDED LEESA VAUGHN SPOGLI, : Defendant : NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT LEESA V. COONS, a/k/a LEESA VAUGHN SPOGLI, intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. DATE: I.D. NO. 27740 1347 FRUITVILLE PIKE LANCASTER, PA 17601 (717) 290-7971 coMMoNWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND RANDALL WILLIAM NICHOLL, Plaintiff : : vs. : l~e No. 01-766 : : Defendant : LEESA V. COONS, a/k/a LESSA VAUGHN SPOGLI, SUBPOENA TO PRODUCE DOCKS OR THINGS FOR DISCOVERY PURSUANT TO RU~,R 4009.22 To: Quaker Oats CompanY, P.O. Box 3040, Shiremanstown, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ~ny and all maployment records and reports concerning Plaintiff Randall William 'NicholI (S.S. No. 198-44-9228) 1347 Fruitville Pike, Lancaster, Pennsylvania, 17601. (Address) You my deliver or mail legible copies of the doonnents or produce thing~ requested by thi~ subpoena_, together with the certificate of compliance, to the party mnkln~ thi~ request at the address Hated 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 doenments or things required by this subpoena w~thln tWenty (20) days after its service, the party serving this subpoena may seek a court order comPelling you to comply with it. SUBPOENA WAS ISSUED AT ~ REQUEST OF Tl:rl~, FOLLOWqlNG PERSON: NA~: George H. Eager, Esquire ADDRESS: 1347 Fruitville Pike Lancaster, PA 17601 TEI,~P~O~: (717) 290-7971 SUP~I~ COURT ID # 27740 ATTORNEY FOR: Defendant BY ~ COURT: DATE: Seal of the Court 'Pr~onotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I HEREBY CERTIFY that I am this day served a true and correct 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 person and in the manner indicated below. Service by First Class Mail, addressed as follows: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 (Attorney for Plaintiff) EAGER, REINAKER & SPINELLO George ~,~.Eager/~squire Attorney for~fendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 Dated: CERTIFICATE OF SERVICE I HEREBY CERTIFY that I am this day serving a copy of the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 upon the person and in the manner indicated below. Service by first class mail, addressed as follows: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 Dated: April 26, 2001 EAGER, REINAKER & SPINELLO By I.D. No. 27740 1347 Fmitville Pike Lancaster, PA 17601 (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW R/~NDALL WILLIAM NICHOLL, : Plaintiff : LEESA V. COONS, a/k/a : LEESA VAUGHN SPOGLI, : Defendant : NO. 01-766 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, Defendant certifies that: (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: George H. Ea~er, Es/qu)rre iA~Dt?r~oe .y 2f~40Defen~a~t 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RANDALL WILLIAM NICHOLL, Plaintiff VS. LEESA V. COONS, a/k/a LEESA VAUGHN SPOGLI, Defendant NO. 01-766 J-tYRY TRIAL DEb~NDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT LEESA V. COONS, a/k/a LEESA VAUGHN SPOGLI, intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. I.D. NO. 27740 1347 FRUITVILLE PIKE LANCASTER, PA 17601 (717) 290-7971 coMMoNWEALTH OF PENNSYLVANIA COUNTY OF CUM]IERLAND RANDALL WILLIAM NICHOLL, Plaintiff : : vs. : Be No. 01-766 : : Defendant : LEESA V. COONS, a/k/a LESSA VAUGHN SPOGLI, SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Hoi'y Spirit Hospital, Department of Radiology & Diagnostic Tmmg~ng North 21st Street, Camp Hill, PA 17011 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the foilowing doo,mentsorthings: Any and .all f~l~n ~nd reportm on Pl~nv~ff Randall William Nicholl (SSN: 198-44-9228) (DOB: 04/14/53) at 1347 Fruitville Pike, Lancaster, Pennsylvania, 17601. (Address) You may deliver or mail legible copies of the docnments or produce things requested by this subpoena, together with the certificate of compliance, to the party malrln~o 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. TF/I,q SUBPOENA WAS ISSUED AT TI-gE, REQUEST OF THE FOLLOWING PERSON: N~k~E: George H. Eager, Esquire ADDRESS: 1347 Fruitville Pike Lancaster, PA 17601 T~I~HO~: (717) 290-7971 SUPRE~ECOU]~TID# 277~0 ATTORNEY FOR: Defendant BY ~ COURT: DATE: Seal of the Court 'Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I HEREBY CERTIFY that I am this day served a true and correct 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 person and in the manner indicated below. Service by First Class Mail, addressed as follows: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 (Attorney for Plaintiff) EAGER, REINAKER & SPINELLO BY: ~~Esqu Geo~ ire Attorney for ~efendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Richard A. Sadlock, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 DATE: EAGER, REINAKER & SPINELLO Geo quire Attorney f~//De fendant I.D. No. 2q740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RANDALL WILLIAM NICHOLL, Plaintiff CIVIL ACTION - LAW NO. 01-766 Civil Term LEESA V. COONS, a/kfa LEESA VAUGHN SPOGLI, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned action as settled, satisfied, and discontinued and issue a Certificate of Settlement. Date: NOvember 29, 2001 ANGINO &~g.O.vxtra~. C. Harrisburg, PA 17110 (7i7) 238-6791 Counsel tbr Plaintiff George H. Eager, Esquire Mr. James J. Ramsey, Claim Specialist (Claim #: 38-J219-546) 239245 I\RAS\MLB