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HomeMy WebLinkAbout01-1245 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. .- No. 01- P'l~ Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND AND CLAIM RIGHTS 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 LAWYER REFERRAL SERVICE Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 (717) 240-6200 NOTICIA Le han demaandado a usted en la corte. Si usted quieie defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persoa 0 por abogado y archivar en la corte enforma escrita sus defensas 0 sus objections alas 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 previa aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importanted para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OF/CINA CUYA DIRECCION SE ENCUENTRA ESCR/TA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 (717) 240-6200 ~~r/jJL~ Attorney for Plaintiff Attorney 1.0. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 Date: March 5, 2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. D/i;:r5 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED COMPLAINT COUNT I GREGORY L. SHEFFER V. JAMIE R. CANNADY 1. The Plaintiff Gregory L. Sheffer is an adult individual with an address of 1176 Rhoda Boulevard, Mechanicsburg, Pennsylvania 17055. 2. The Plaintiff Debra L. Sheffer is an adult individual and the spouse of the Plaintiff Gregory L. Sheffer and resides with him at his aforesaid address. 3. The Defendant Jamie R. Cannaday is an adult individual with an address of 22 East Street, Apartment 5, Mount Holly Springs, Pennsylvania 17065. 4. At all times relevant herein, the Plaintiff Gregory L. Sheffer was the operator of a certain 1986 Buick the Plaintiff Debra L. Sheffer owned. 5. At all time relevant herein, the Defendant Jamie R. Cannaday was operating a certain 1985 Dodge Daytona that he owned. 6. On May 26, 1999 at or about 12:00 p.m., the Plaintiff Gregory L. Sheffer had been traveling North on State Route 74 in Monroe Township, Cumberland County, in the vicinity of Miller Boulevard and stopped with his left turn signal activated waiting for southbound traffic to pass so that he could make the left hand turn onto Miller Boulevard. 7. As the Plaintiff Gregory L. Sheffer was stopped with his turn signal activated, the Defendant Jamie R, Cannaday rammed his 1985 Dodge Daytona into the rear of the Plaintiff's aforesaid vehicle. 8. The aforesaid collision was caused solely by the carelessness, recklessness and negligence of the Defendant in that he: a.) failed to keep a vigilant outlook for traffic in front of his vehicle; b.) failed to see the Plaintiff's vehicle then and there lawfully stopped with its turn signal activated waiting for southbound traffic to pass before turning onto Miller Boulevard as aforesaid; c.) failed to avoid striking the Plaintiff's aforesaid vehicle; d.) operating his vehicle at a speed in excess of the speed for safe travel; e.) failed to keep an assured clear distance between his vehicle and the Plaintiff's aforesaid vehicle; f.) struck the Plaintiff's aforesaid vehicle; g.) violated 75 Pa.C.S.A. 3714; h.) violated 75 Pa.C.S.A. 3361. 9. Solely as a result of the carelessness, recklessness and negligence of the Defendant, the Plaintiff Gregory L. Sheffer has suffered soft tissue injuries and temporomandibular joint dysfunction (TMJ). 10. Solely as a result of the carelessness, reckless and negligence of the Defendant, the Plaintiff Gregory L. Sheffer is entitled to the following elements of damage for both past and future damages: a.) medical expenses; b.) pain and suffering; c.) emotional distress; d.) loss of enjoyment of life; WHEREFORE, the Plaintiff demands judgment in his favor and against the Defendant in an amount in excess of the amount for mandatory referral to arbitration. COUNT II DEBRA L. SHEFFER V. JAMIE R. CANNADY 11. The Plaintiff incorporates herein by reference thereto paragraphs 1 through 10 inclusive of this Complaint. 12. Solely as a result of the carelessness, recklessness and negligence of the Defendant, the Plaintiff has suffered loss of consortium. WHEREFORE, the Plaintiff demands judgment in her favor and against the Defendant in an amount in excess of the amount for mandatory referral to arbitration. Respectfully submitted, Date: March 5, 2001 KNAUER & ASSOCIATES, L.S.C. 2~~~,~ Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 VERI Fie A T ION Subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities, we hereby certify that the facts in the foregoing pleading are true and correct to the best of our information and belief. Date: /e -1.,2- 00 ~c/~ (&hI. Y- .J)"~ 8 C>-c }b'-.J }T III -C. '" Vi -C. v ~ C d'; ;:,:, ~ F'~~ .... '" " =>, C) ",,'0 D '" ~ .... ;v , I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01- l.:lft,S' Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS UNDER PA. R.C.P. NO. 4009 FIRST SET TO: Jamie Cannady 22 East Street, Apartment 5 Mount Holly Springs, PA 17065 Pursuant to Pa. R.C.P. 4009, you are hereby requested to produce the below-listed documents and/or items for purposes of discovery. This material will be examined and/or photocopied, photograph negatives will be processed and photographs reproduced. Said documents or tangible things are to be produced at the offices of David W. Knauer, Esquire, 411-A E. Main Street, Mechanicsburg, PA 17055 within forty-five (45) days of the date of service hereof and supplemented thereafter in accordance with Pa. R.C.P. 4007.4: 1. The entire contents of any investigation file or files and any other documentary material in your possession which relate in any manner (excluding references to mental Impressions, conclusions or opinions regarding the value or merit of the claim or defense or respecting strategy or tactics and privileged communication from and to counsel) to the within action. 2. Any and all statements concerning the action, as defined by Rule 4003.4 from all witnesses including any statements from the parties herein, or their respective agents, servants or employees. 3. All photographs taken or diagrams prepared of the scene of the accident/incident or any instrumentality involved therein. 4. Any and all documents containing the names and home and business addresses of all individuals contacted as potential witnesses. 5. Reports of any and all experts who will testify at Trial. 6. Reports of any and all agents or employees of Defendant prepared as a result of the incident. 7. A copy of the Defendant(s) insurance policy. 8. If the Defendant's insurance company is considering or planning to withdraw its provision of a defense of the above action, please attach a copy of any and all documents involved with the decision of issuing a reservation of rights letter or document and of the provision of notice to the Defendant of its decision to reserve rights or withdraw a defense. Date: March 5, 2001 Respectfully submitted, r)AUER & ASSOCIATES, L.S.C. Vtl.~n tJ J< .., Da:~. Kn~JS=e Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 SHERIFF'S RETURN - REGULAR CASE NO: 2001-01245 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SHEFFER GREGORY L ET AL VS CANNADY JAMIE R SGT. DAVID C. ZEIGLER Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within PLTFF'S REQUEST FOR PRODU was served upon CANNADY JAMIE R the DEFENDANT , at 0013:25 HOURS, on the 2nd day of April 2001 at CUMBERLAND CTY SHERIFFS' OFF CARLISLE, PA 17013 JAMIE CANNADY 1 COURTHOUSE SQUARE by handing to a true and attested copy of PLTFF'S REQUEST FOR PRODU together with OF DOCUMENTS, INTERROGATORIES, NOTICE & COMPLAINT and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 8.06 .00 10.00 .00 36.06 Sworn and Subscribed to before me this 1/ ~ day of cy...J. j "'-0 ( A . D . n. C-~ ~ 'plo~~otary I~ So Answers: ~~ ~-.t:~~ R. Thomas Kline 04/03/2001 KNAUER & ASSOCIATES ~ By: /) ;/(J~/ / ..(U~ ( . , Deputy er~f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE PURSUANT TO Pa.R.C.P. 1012 TO THE PROTHONOTARY: Kindly enter the appearance of Michael B. Scheib, Esquires of Griffith, Strickler, Lerman, Solymos & Calkins, as attorney for the Defendant in the above- captioned matter and mark the docket accordingly. GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS BY: 1,1J/J //jj MICJK~ B. SCHEIB, EtfltlRf Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 Attorneys for Defendant Cannady Dated: . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE +h AND NOW, this 3D of April, 2001, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS, hereby certify that I have this date served a copy of Praecipe for Entry of Appearance, by United States Mail, addressed to the party or attorney of record as follows: David W. Knauer, Esq. 411-A East Main Street Mechanicsburg, PA 17055 (Attorney for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS BY: -'lU. /Jt, M f MiCh':t~. SC~, tESQ~. Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 Attorneys for Defendant Cannady " " ~ '" ~ " ,I ~ ~ o ~ ~ ~ .7". () -0 <5 ;><: m ~ ~ Z 0 m t5 ~ ~ > -< :r: m ::E ~ ~ ~ ~ ~ ~ .~ ~ ~ ~ ~ ~ Z 0 2 ~ :< w -< s:: ~ 0 ~ ~ " )> ~ ~ z ~ o ~;. -oru CPt.; Z(' {fJ_"" -<.~. ~C ~'C, ~f:~ ;:.-= =< . c:> (- -yj -,- ;"1= -< -0 r:-? C) co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED To: Gregory L. Sheffer and Debra L. Sheffer, Plaintiffs c/o David W. Knauer, Esquire 411-A East Main Street Mechanicsburg, P A 17055 NOTICE TO PLEAD You are hereby notified to file a written response to the enclosed New Matter within twenty (20) days from service hereof or a judgment may be entered against you. BY GRIFFITH, STRICKLER, LERMAN, i/:l;S11i!r MI,h.., '~'h"b' E'",,, Attorney for Defendant Cannady Supreme Court I.D. # 63868 110 South Northern Way York, Pennsylvania 17402 Telephone: (717) 757-7602 Date: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA l. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANT JAMIE R. CANNADY AND NOW COME, Defendant Jamie R. Cannady by and through his attorney, Michael B. Scheib and Griffith, Strickler, Lerman, Solymos & Calkins in response to the allegations in Plaintiffs' Complaint as follows: 1. Denied. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 1 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 2. Denied. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 2 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 3. Admitted in Part and Denied in Part. It is admitted that Defendant Cannady is an adult individual. The address in incorrect. His current address is 261 Ridge Hill Road, Mechanicsburg, PA. 4. Admitted in Part and Denied in Part. It is admitted that Plaintiff Sheffer was the operator of a 1986 Buick. The remaining allegations are denied. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 4 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 5. Admitted. 6. Admitted in Part and Denied in Part. It is admitted that at the date and time set forth, Plaintiff Sheffer was operating a vehicle on Route 74. The remaining allegations are denied. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 6 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 7. Admitted in Part and Denied in Part. It is admitted that the vehicles came into contact with one another. The remaining allegations are denied. After reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 7 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 8. Denied. This paragraph states a legal conclusion to which no response is required. To the extent that a response is required, it is specifically denied that Defendant Cannady was careless, reckless and/or negligent and that his carelessness, recklessness, and/or negligence consisted of: a.) Failing to keep a vigilant outlook for traffic in front of his vehicle; b.) Failing to see the Plaintiff's vehicle then and there lawfully stopped with its turn signal activated waiting for southbound traffic to pass before turning onto Miller Boulevard as aforesaid; c.) Failing to avoid striking the Plaintiff's aforesaid vehicle; d.) Operating his vehicle at a speed in excess of the speed for safe travel; e.) Failing to keep an assured clear distance between his vehicle and the Plaintiff's aforesaid vehicle; f.) Striking the Plaintiff's aforesaid vehicle; g.) Violating 75 Pa.C.S.A. 3714; and h. Violating 75 Pa.C.S.A. 3361. On the contrary, at all times relevant, Defendant acted in a lawful, careful, safe and prudent manner and with due care as required by the circumstances. 9. Denied. This paragraph states a legal conclusion to which no response is required. Furthermore, after reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 9 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 10. Denied. This paragraph states a legal conclusion to which no response is required. Furthermore, after reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 10 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. WHEREFORE, Defendant Cannady respectfully requests this Honorable Court to enter judgment in his favor and against the Plaintiffs together with the cost of this lawsuit. COUNT II Debra L. Sheffer v. Jamie R. Cannady 11. Paragraphs 1 through 10 of Defendant's Answer With New Matter are incorporated herein as though fully set forth at length. 12. Denied. This paragraph states a legal conclusion to which no response is required. Furthermore, after reasonable investigation, answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations contained in paragraph 12 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. WHEREFORE, Defendant Cannady respectfully requests this Honorable Court to enter judgment in his favor and against the Plaintiffs together with the cost of this lawsuit. BY WAY OF FURTHER DEFENSE: NEW MATTER OF DEFENDANT JAMIE R. CANNADY 13. Paragraphs 1 through 12 of Defendant's Answer with New Matter are incorporated herein as though fully set forth at length. 14. Plaintiff's injuries, if any, were caused by the acts or omissions of a third party over whom Defendant Cannady had no control. 15. Plaintiff's injuries, if any, were caused by events which either pre- dated or post-dated the motor vehicle accident which is the subject of this lawsuit. 16. Said Plaintiff's Complaint fails to state a cause of action upon which relief can be granted. 1 7. Said Plaintiffs' Complaint may be barred or limited by the applicable statute of limitations. 18. Plaintiffs' injuries, if any, may be caused or contributed by his own contributory negligence and/or assumption of the risk. 19. Plaintiff was previously treated for TMJ. 20. Plaintiff was previously treated for soft-tissue injuries. 21. Plaintiff has selected the limited tort option. 22. Plaintiff's recovery, if any, is limited by the Motor Vehicle Financial Responsibility law. 23. Plaintiff has not incurred any out-of-pocket expenses. WHEREFORE, Defendant respectfully requests this Honorable Court to enter judgment in their favor and against the Plaintiffs together with the cost of this lawsuit. GRIFFITH, STRICKLER, lERMAN, SOL YMOS & CALKINS By,wiJ<if 6JiJ Micha~~ B. Scherb, Esquire Attorney for Defendant Supreme Court I.D. # 63868 110 South Northern Way York, Pennsylvania 17402 Telephone: (717) 757-7602 VERIFICATION I, '\AT'fUl" R Cf/'IJJFlI\FJ-i' hereby verifY that the statements rnade in the foregoing Answer and New Matter fu1>laintiffs' Complaint are true and correct to the best of my personal knowledge or information and belief, as well as reports, records, conferences and other investigatory material made available to me. To the extent that the foregoing contains averments which are inconsistent in fact, I verifY that my knowledge or information is sufficient to form a belief that one or more of them is true, although I am currently unable, after reasonable investigation, to ascertain which of the inconsistent averments are true. To the extent that the foregoing contains legal conclusions or opinions, I hereby state that my Verification is rnade upon the advice of counsel, upon whom I have relied in the filing this document. This Verification is made subject to the penalties of 18 Pa. c.s. S 4904 related to unsworn falsifications to authorities. Dated: Co/~I r~- /d- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE i ~ jUI\e. AND NOW, this ~ of illlaV, 2001, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS, hereby certify that I have this date served a copy of the Answer With New Matter of Defendant Jamie R. Cannady by United States Mail, addressed to the party or attorney of record as follows: David W. Knauer, Esq. 411-A East Main Street Mechanicsburg, PA 17055 (Attorney for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS BY: 1iJaliJL/ MIt:L~1 B. Scheib, ESQUIRE Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 Attorneys for Defendant Cannady " ~ " ~ => .'" ~ ~ 0 -< (") C'J C) ~ ~ l' n C -d ~ " ~ ~ " r <. ,- Z 0 m -V tc) ~:~~ z c .~ ); nl j""-' (" ~ " r ~ " m ~ -7""';-" >;-, < z ~ ~ ZC'~ I > 0 ;: > Z " > 0! ~~~ .-J " ;Ii .Z ~ > ~ ~ r- e' ~ ~ z ..,- .. ~ 0 :i> 0 ~ r C) - ," (.') ~ ~ ~::':. ;;; < ;: () I " 0 > 1.:-? C;, w ~ C -.-j ~ '" ~ => ?D n > .-1 -< r ~ Z ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED Plaintiff's Reply to New Matter 14. Paragraph 14 of the Defendant's New Matter is a conclusion of law to which no reply is required pursuant to the Pennsylvania Rules of Civil Procedure and strict proof thereof is demanded at time of trial. 15. Denied. Plaintiff's injuries were caused by the accident. 16. Paragraph 16 the Defendant's New Matter is a conclusion of law to which no reply is required pursuant to the Pennsylvania Rules of Civil Procedure and strict proof thereof is demanded at time of trial. 17. Paragraph 17 of the Defendant's New Malter is a conclusion of law to which no reply is required pursuant to the Pennsylvania Rules of Civil Procedure and strict proof thereof is demanded at time of trial. 18. Paragraph 18 of the Defendant's New Malter is a conclusion of law to which no reply is required pursuant to the Pennsylvania Rules of Civil Procedure and strict proof thereof is demanded at time of trial. 19. Denied. Plaintiff was not treated for TMJ until after the accident. 20. Admitted. Plaintiff treated for a mild injury to his neck over ten years ago and made full recovery within a few weeks. 21. Paragraph 21 of the Defendant's New Matter is a conclusion of law to which no reply is required pursuant to the Pennsylvania Rules of Civil Procedure and strict proof thereof is demanded at time of trial. 22. Paragraph 22 of the Defendant's New Matter is a conclusion of law to which no reply is required pursuant to the Pennsylvania Rules of Civil Procedure and strict proof thereof is demanded at time of trial. 23. Denied. Plaintiff has incurred out-of-pocket expenses. WHEREFORE, the Plaintiffs' demand judgment in their favor and against the Defendant on her New Matter. Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. ~~~~ Date: June 21, 2001 Attorney for Plaintiff Attorney 1.0. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 21st day of June, 2001, serve a true and correct copy of the Plaintiffs Reply to New Matter on all counsel ofrecord by United States mail, first class, prepaid addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 Q~~ Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, P A 17055 (717) 795-7790 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE ~. ,\-rh AND NOW, thid I of June, 2001, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served Interrogatories/Request For Production of Documents of Defendant Cannady to Plaintiffs Sheffer by United States Mail, addressed to the party or attorney of record as follows: David W. Knauer, Esq. 411-A East Main Street Mechanicsburg, PA 17055 (Attorney for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS BY: M;OhJiuiJI1t Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 Attorneys for Defendant Cannady LAW OFFICES GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS ATTORNEYS AT LAW 110 SOUTH NORTHERN WAY YORK. PENNSYLVANIA 17402,3737 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L SHEFFER PlaIntiffs, Civil Action Law vs No. 01 1245 JAMIE R CANNADY Del'endant JURY TRIAL DEMANDED CEFlTIFICATE~9I SERVICE AND NOW, this, of P,ugust, 2001, I, Michael B. Scheib. Esquire, a member of the firm of GFtIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS, hereby certify that I have this date served Defendant Response to Plaintiff's Request For Production Of Documents by United States Mati, addressed to the party or attorney of record as follows: David W. Knauer. Esq, 411-A East lVIalrl Street Mechanlcsburg, PA '.17055 (Attorney for Plaintiff) GRIFFITH, STRICKLER. LERMAN, SOL YMOS & CALKINS t /, BY. , I ,) if "1 I ,1' I -- Michael B.. Scheib, ESQUIRE Attorney ID No, 63868 110 South Northern Way York, Pennsvlvania 17402 (717) 757-7602 Attorneys for Defendant Cannady '"'''IIIllIIlI'......,IIIMII I """," I" 111".'11"'.".11' 111111.1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certifY that I did this 22nd day of August, 2001, serve a true and correct copy ofthe Plaintiff s Answers to Interrogatories and Request for Production of Documents on all counsel of record by United States mail, first class, prepaid addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 8~/~~~1 David W. Knauer Attorney for Plaintiff Attorney LD. No. 21582 411-A East Main Street Mechanicsburg, P A 17055 (717) 795-7790 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED NOTICE OF DEPOSITION Please be advised that on November 13,2001, at 12:00 p.m., the Plaintiff will take the deposition of the Defendant Jamie R. Cannady, at the offices of Michael B. Scheib, Esquire, located at Griffith, Strickler, Lerman, Solymos & Calkins, 110 South Northern Way, York, Pennsylvania, before a person authorized by law to administer oaths. The oral examination will continue from day to day until completed. You are invited to attend and participate in this examination. Respectfully submitted, KNAUER & ASSOCIATES, LSC L. ~~ ~ 1'-.) Date: September 19,2001 David W. Knauer, Esquire Attorney for the Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 19th day of September, 2001, serve a true and correct copy of the Deposition Notice to Jamie R. Cannady on all counsel of record by United States mail, first class, prepaid addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York,PA 17402 6?~~~~ David W. Knauer /' Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, P A 17055 (717) 795-7790 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE :\.Y\ AND NOW, this J D day of September, 2001, I, Michael B. Scheib, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS, hereby certify that I have this date served the Notice Of Deposition by United States Mail, addressed to the party or attorney of record as follows: David W. Knauer, Esq. 411-A East Main Street Mechanicsburg, PA 17055 GRIFFITH, STRICKLER, LERMAN, SOL~j;LljJ MiChM. Scheib, Esquire Supreme Court 10 No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 ~_J') q "00'0 ".) ....J-j CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOtRA PURSUANT TO RULE 4009.22 0 r\ C) IN THE MATTER OF: COURT OF COMM~ PI:US -,", ."":') C~i ~ ) GREGORY & DEBRA SHEFFER TERM, .-.j C) (I,' l,_ ~ -VS- CASE NO: 01flt!+5 JAMIE R. CANNADY , (-) --0 . -< (}1 ~;:) -< As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQUIRE 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 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. 1 MCS on ~ ~ SCHEIB, ESQUIRE Attorney for DEFENDANT DATE: 10/03/2001 ......._.._..-.r'. DE12-215920 73020 -LOl ._"-_._---~.~...._..,..._,'" COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COHMON PLEAS GREGORY & DEBRA SHEFFER TERM, -VS- CASE NO: 01-1245 JAMIE R. CANNADY NOTICE OF IN'l'ENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ERIE IIISURAHCE GROUP CARLISLE HOSPITAL DOlIALD KOVACS, K.D. DAII DEFALCIS, K.D. Oil. FlIED KIllIUK ALEXAIIDER SPIlIIIG REHAB, IIIC . Oil. 1l0BERT BEADIlY IIISURAIICE MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL TO: DAVID KllAUEll, ESQUIRE KCS on behalf of KICIIAEL SCHEIB, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frOlll the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning s.- to KCS or by contacting our local KCS office. DATE: 10/03/2001 HCS on behalf of KICIIAEL SCHEIB, ESQUIRE At torney for DBFEIIIlAIl'l' CC: KICIIAEL SCIIIUB, ESQUIRE Any questions regarding this matter, cootact 'filii: KCS GROUP. IJIC. 1601 KARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-166421 73020-COl COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERL~"D GREGORY L. & DEBRA L. SHEFFER VS FiI. :-';0. 01-1245 JAMIE R. CANNADY SUBPOENA TO PRODUCE DOCUME-."TS OR THI~GS FOR DISCOVERY PURSUA.l\"T TO RULE 4009.21 TO: CUSTODIAN OF RECORDS FOR: ERIE INSURANCE GROUP (S..me of Penoft or 'Ender) Within rwe~' 1::0) d.ys ofter seNie. of this subpoena, you ue orderltd by the.....rt to produee the following doeuments 0. ,hings: SF.F. ATTAr.HF.n .t MCS GROUP INC., 1601 MARKET ST., #800,PHlLA.,PA 19103 I Addntll You m.y deih'" or mail legible eopi.. of the doo:umenll or produ.. thinp NCl"..ted by this subpoen.. together with tho c.rtifiute o! compUane.. to the pony making thil request .tthe .ddreu IUtItd abov.. You have the right to s..k, in .dnne.. tho ~uon.bl. eOlt of preparing th. eopin or produdng the thinp -!l". If ,'ou f.iI to ?:oduct tho doo:um.ntl or things r.quir.d by thillubpoe.... wiU-.in tw.nty (::0) da"1 aiter itl .e,,';ce. the parry ""'ing this ,u~po.na may leek a ecnut o.der comp.lling you to eomply with;o_ THIS SLllPOENA WAS ISSUED ATTIiE REQUEST OF THE FOLLOWING PERSON: ~AME: MICRAF.L B. SCRF.IB. ESO. ....DDRESS: 110 S. NORTHERN WAY YORK, PA 17402 TELEPHOSE: 215-246-0900 SUPREME C01.l1lT ID I: AITOR,,,n' FOR: nF.FF.NTlANT DATE: S@pkMbcl, ~'1. ~Q?I '}~U~: ~ ......--.yIC~ Ovll Olvili.. .j(~ /If! @{~ry ~ S.al of the Court (~ff. i /97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ERIE INSURANCE GROUP P.O. BOX 2013 4901 LOUISE DRIVE MECHANICSBURG, PA 17055 RE: 73020 GREGORY LYNN SHEFFER Any and all claims files. Dates Requested: up to and inclu~;l the present. Subject: GREGORY LYNN SHE R 1176 RHODA BLVD., MECHANICSBURG, PA 17055 Social Security #: 208-38-6025 Date of Birth: 12-15-1951 Date of Loss: 05/26/1999 5U10-331260 73020-LOl CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS GREGORY & DEBRA SHEFFER TERM, -VS- CASE NO: 01-1245 JAMIE R. CANNADY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQUIRE 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 and, (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 10/03/2001 MICHAEL SCHEIB, ESQUIRE Attorney for DEFENDANT DE12-215921 73020 -L02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER OF: COURT OF COMMON PLEAS GREGORY . DEBRA SHEFFER TERM, - VS- CASE NO, 01-1245 JAMIE R. CANNADY NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUAN'l' TO RULE 4009.21 RIE IMStJUMCE GROUP CAllLISLE HOSPITAL DOMALD JroVACS, M.D. DAM DEFALCIS, M.D. DR. PIED MIlfIUM ALEXAMDER SPRlMG REHAB, IHe. DR. ROBERT BEADRY IHStJUMCE MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL TO: DAVID D1AUER, ESQUIRE HCS on behalf of MICHAEL SCHEIB, ESQUIRE intend. to .erve a .ubpoena identical to the one that i. attached to this notice. You have twenty (20) day. fraa the date li.ted below in which to file of record and .erve upon the under.igned an objection to the .ubpoena. If the twenty day notice period i. vaived or if no objection i. made, then the .ubpoena may be .erved. Complete copies of any reproduced record. may be ordered at your expen.e by completing the attached coun.el card and returning .... to HCS or by contacting our local HCS office. DATE: 10/03/2001 MCS on behalf of MICHAEL SCHEIB, ESQUIRE Attorney for DEPEIIDA1l'1' CC: MICHAEL SCUIB, ESQUIU Any que.tion. regarding this matter, contact TIlE MCS GROUP. IlIC. 1601 MARKET STREET #aoo PHILADELPHIA, PA 19103 (215) 246-0900 DE02-166421 73020-CO::L COMMONWEALTH OF PENNSY1. VANIA COUNTY OF CUMBERL~"'D GREGORY L.& DEBRA L.SHEFFER VS File So. 01-1245 JAMIE R. CANNADY SUBPOENA TO PRODUCE DOctJME.,,'"TS OR TIiI~GS FOR DISCOVERY PURSUA.1'I.o"TTO RU1.E 4009.22 TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL IS.",. ot P_non or :'1Dt!) ~'i:hin r'Wf:,,"::,,:,,' (10) d.ays ~er sen'ice of this subpoeru. you ue ordered by u.. C'Outt to produce the following dQcumerus or tninS" SlI.F A1'1'Ar.HFn .. MCS GROUP INC., 1601 MARKET ST., #800,PHlLA.,PA 19103 (Ad_It You moy d.ii....r or mail l'gibl. (api.. of th. daalln.nts or product thinp req....ltd by thi. .ubpoena. 'ag..n.r with .n. <ertifica.. ai camplimc., to th. party ",wng this request at the addres listed above. You ha,', th. right 'a seek, in .d,'ance. lne ,"uonable (a.t of pr.paring th. co pi.. or producing the thinp _!hI. II ~'au /ojltc "adu(1 the do<umlnt. or things requirld by this subpoenA. wit..'Un tw.nty (~l days aiter its se,,',,". tnl patty sl,,'ing 1M subpo.na may ....k a cO\ll't ord.r camp.lling you to comply with i"_ THIS St"BPOEl'olA WAS ISSUED AT TIiE REQUEST OF THE FOLLOWING PERSON: SAME: MTCHAFL B. SCRRIB. ESO. ADDRESS: 110 S. NORTHERN WAY YORK, PA 17402 TElE?HOSE: 215-246-0900 S1.:PRE.\fE COURT 10 t: ... TTOR....n. FOR: nFl'RNTlAN1' DATE: '~ft<m b-r '-":I ~I'YJI BY THE CO~: /)I(7"L1//--;tM ProI::.:::.,1c.... Civil Civilion ~ /I'YJ ~\ ~ ee,..~ - .., " Seal of the Court (?:ff. i /97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL 246 PARKER STREET CARLISLE, PA 17013 RE: 73020 GREGORY LYNN SHEFFER Any and all records, correspondence, files and memorandums, handwritten notes, relating to any examination, consultation care or treatment. Dates Requested: up to and including the present. Subject: GREGORY LYNN SHEFFER 1176 RHODA BLVD., MECHANICSBURG, PA 17055 Social Security #: 208-38-6025 Date of Birth: 12-15-1951 5U10-331262 73020-L02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS GREGORY & DEBRA SHEFFER TERM, -VS- CASE NO: 01-1245 JAMIE R. CANNADY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQUIRE 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 and, (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 10/03/2001 MICHAEL SCHEIB, ESQUIRE Attorney for DEFENDANT DE12-215922 73020 -L03 COMMONWEALTH OF PENNSYLVAN~A COUNTY OF CUMBERLAND IN THE HATTER OF: COURT OF COHMON PLEAS GREGORY & DEBRA SHEFFER TERM, -VS- CASE NO: 01-1245 JAKIE R. CANNADY HOTICE OF INTEN'r TO SERVE A SUBPOENA TO PRODUCE DOCUMEN'rS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 nIE DlStJRAllCE GROUP CARLISLE HOSPITAL DOlIALD KOVACS, !t.D. DAM DEFALCIS, !t.D. DR. FlED KlRIUK ALEXANDER SPUKG REIIAB, INC. DR. ROBERT BEADIlY DlSURAMCE H1mICAL H1mICAL H1mICAL H1mICAL H1mICAL H1mICAL TO: DAVID IDiAtJEIl, ESQUIRE KCS on behalf of KICBAEL SCHEIB, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frOlll the date listed below in which to file of record and serve upon the undersigoed an objection to the subpoena. If the twenty day notice period is vaived or if no objection is _de, then the subpoena _y be served. Cc:aplete copies of any reproduced records may be ordered at your expense by cc:apleting the attached counsel card and returning s_ to I<<:S or by contacting our local KCS office. DATE: 10/03/2001 I<<:S on behalf of KICBAEL SCHEIB, ESQUIRE Attorney for DEFEHDAllT CC: KICBAEL SCIIBIB, ESQUIRE Any questions regarding this matter, contact TID KCS GROUP IBC. 1601 MARIBT STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-166421 73 020-CO~ COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERL"-'iD GREGORY L. & DEBRA L. SHEFFER VS File Xo. 01-1245 JAMIE R. CANNADY SUBPOENA TO PRODUCE DOCUME\"TS OR THI~GS FOR DISCOVERY PURSUA.!I"iTO RU1.E4009.22 TO: CUSTODIAN OF RECORDS FOR: DR. DONALD KOVACS {S&me o( Ptnon or Enciry) "<;i:hin rwe~'I:O) days Uter se".ite of this .ubpoena. you Ole orderN by the <:OlIn to produce the following documents or :hings: ~F.F A'l''l'Ai:H1''n al MCS GROUP INC.. 1601 MARKET ST., #800.PHlLA..PA 19103 lAd_I' You may dein'" or m.;llegible copies of the documenll or produce thinp reI!"ested by thil lubpoen.. logtlher with tho C!rtiiiult <Ii ,0mpliiUlct. to tho potty m&king rhis rtquest at the adclreu ldted above. You hav. tho right to ...k. in adnn... tho ",asonable COlt of prtparingthe copi.. or producing the thinp -ShL If ~'ou fail rc "oduc. tho documentl or things roquired by this subpoena. wit..'Un rwenry (:0) c!a~'1 ofltr its ,.,,'i,.. ,h. pony '."'ing ,itis .ubpoena may seek a court order compelling you to comply with jo_ THIS St"BPOENA WAS ISSUED ATTIiE REQUEST OF mE FOLLOWlNG PERSON: ~AME: M1CHAF.T. B. SCH1"TB. ESO. ADDRESS: 110 S. NORTHERN WAY YORK. PA 17402 TELEPHOXE: 215-246-0900 Sl,;PRE.'fE COll1lT 10 ,: A1iOR."E't. FOR: nF.1i'1"NTlAN'T' DATE: 3;P1vn b/r. tX ':f. ,RtXJf ~~O~~ p...,hon~eR.j:'O;~ili.. ..;;:t~~#I!~ D<<?u~ Seal of lhl! Court (::fl. 7/97) EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DONALD KOVACS, M.D. 1358 LUTZTOWN ROAD YELLOW BREECHES F.P. BOILING SPRINGS, P A 17007 RE: 73020 GREGORY LYNN SHEFFER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and inclu~i:i the present. Subject: GREGORY LYNN SHE R 1176 RHODA BLVD., MECHANICSBURG, PA 17055 Social Security #: 208-38-6025 Date of Birth: 12-15-1951 5UIO-331264 73020 - L 0 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS GREGORY & DEBRA SHEFFER TERM, -VS- CASE NO: 01-1245 JAMIE R. CANNADY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQUIRE 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 and, (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 10/03/2001 MICHAEL SCHEIB, ESQUIRE Attorney for DEFENDANT DE12-215923 73020 -L04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COHMON PLEAS GREGORY & DEBRA SHEFFER TERM. -VS- CASE NO: 01-1245 JAMIE R. CANNADY NOTICE OF INTEH'r TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 nIE IIISURAHCE GROUP CAIlLlSLE HOSPITAL IlOlIALD IWVACS, K.D. DAlI DEPALClS, K.D. DR. PUD MIlIl1lM ALUAlIDD SPB.1lIG IWIAJI, IIlC. DR. ROBOT BEADRY llISURAlICI MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL TO: DAVID DlAUEB., ISQUIRE MeS on behalf of KlCBAEL SCHEIB, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days froa the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is _de, then the subpoena _y be served. C.-plete copies of any reproduced records ..y be ordered at your expense by completing the attached counsel card and returning s_ to MeS or by contacting our local MeS office. DATE: 10/03/2001 . MeS on behalf of KlCBAEL SCHEIB, ISQUIRE Attorney for DE1'DDAR'r cc: KlCBAEL SCHEIB. ESQUIU Any questions regarding this matter, cODtact TIlE MeS GIOUP. 11IC. 1601 KARlE! STREET #aoo PHILADELPHIA, PA 19103 (215) 246-0900 DI02-166421 73020-C01 COMMON'WEAL TH OF PENNSYlVANIA , COUNTY OF CUMBERL~~D GREGORY L. & DEBRA L. SHEFFER VS File :-;0. 01-1245 JAMIE R. CANNADY SUBPOENA TO PRODUCE DOCtJME'o..,.S OR THI~GS FOR DISCOVERY PURSUA."'" TO RULE 4009..21 TO: CUSTODIAN OF RECORDS FOR: DR. DANIEL DEFALCLS (!':~. Q( P~non or e..,tiry) ~'ithin "",,,,,'1:0) days ofter s.rvi.. oi this SUbp....M. you u. ordered II,.- the ....." 10 prod...e the following do.um.nts or thinss: ~1':1<'. A '!''!' A~H1<'.D al MCS GROUP INC.. 1601 MARKET ST., #800,PHlLA.,PA 19103 (Adclnso' You mlY deiin, or meillegibl. .opi... of lh. docum.nts or prod.... t/Unp request.d by lhis s..bp....n.. log.th" with ,he Cfrtifi.... 0; .ompli~... to the petty mwnglhis request It lh. Idclreu Usted abov.. Yo.. na... lh. righ"o ...k, in .dven.e. the ~..onlble .ost oi pr.paringlhe .opies 0' prod..cins the thinp -!hI. Ii you foil Ie ?,odu..'he docum.nts 0' things required by this subpoena. within twenty (:0) da~" ofter its s",';ce. ,h. pony se"'ing':u. I..~po.nl may seek I ,oun o,der .ompelling you 10 .omply ..nth i'_ THIS Sl.""dPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: ~AME: MICHAF.L ll. SCHF.tB. ESO. ...OORESS: 110 S. NORTHERN WAY YORK. PA 17402 T'El.EPHO~:: 215-246-0900 ST.;PRE.\fE COtJ"KT 10 I: ,',:rrORSO' FOR: DF.nNTlAN'!' DATE: S:pihlfN,.n. ~~/ B~,THE COURb. /.y(?,,,Ui"77it ...", .,f~ PtotbOftocarylOMk. Civil O;vi,ion ,{J",~ fl/ ~ Sui of the Court (::1 i /9:-) EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DAN DEFALCIS, M.D. 175 LANCASTER BLVD P.O. BOX 2028 MECHANICSBURG, PA 17055 RE: 73020 GREGORY LYNN SHEFFER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and inclu~~;1 the present. Subject: GREGORY LYNN SHE R 1176 RHODA BLVD., MECHANICSBURG, PA 17055 Social Security #: 208-38-6025 Date of Birth: 12-15-1951 SU10-331266 73020 -LO 4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS GREGORY & DEBRA SHEFFER TERM, -VS- CASE NO: 01-1245 JAMIE R. CANNADY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQUIRE 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 and, (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena, MCS on behalf of DATE: 10/03/2001 MICHAEL SCHEIB, ESQUIRE Attorney for DEFENDANT DE12-215924 73020-LOS COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER OF: COURT OF COHMON PLEAS GREGORY & DEBRA SHEFFER TERM, -VS- CASE NO: 01-1245 JAMIE R. CANNADY NOTICE OF IlI'1'ElIT TO SERVE A SUBPOERA TO PRODUCE DOCUMEH'rS AND THINGS FOR DISCOVERY PURSUAN'r TO RULE 4009.21 nIE IHSUUIICE GROUP CAIlLISLE HOSPITAL DOHALD ItOVACS, M.D. DAII DBFALCIS, M.D. 01.. FRED KI1fitIM ALJCWIDn SPlUHG REHAB, IHe. 01.. ROBnT BJW)I.Y IHSURAIlCB KBDICAL KBDICAL KBDICAL KBDICAL KBDICAL KBDICAL TO. DAVID DAUER, BSQUIllE KCS on behalf of MICHAEL SCHEIB, BSQUIllE intends to serve a subpoena identical to the one that is attached to this notice. You b4ve twenty (20) days froa the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is _de, then the subpoena _y be served. CllIIIp1ete copies of any reproduced records _y be ordered at your espense by clllllpleting the attached counsel card and returning s_ to !'I:S or by contacting our local KCS office. DATE. 10/03/2001 !'I:S on behalf of MICHAEL SCBBIB, BSQUIllE Attorney for DBPEIIDAllT CC. MICHAEL SCBBIB, ESQUlU Any questions regarding this _tter. contact TIIB !'I:S GROUP. IHC. 1601 KABDT STllEI:T leoo PBlLADELPlIlA, PA 19103 (215) 2il6-0900 DB02-166421 73020-CO~ COMMONWEALTH OF PENNSY1. VANIA COUNTY OF CUMBERL-\..'iD GREGORY L.& DEBRA L.SHEFFER VS File So. 01-1245 JAMIE R. CANNADY SUBPOENA TO PRODUCE DOCUME-.-rS OR THl:-1GS FOR DISCOVERY PURSUA..l\-rTO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: DR. FRED MINIUM IS~me of PtrsOft or ::saC!) ""'ithin t'"Nf~. (:0) days Uter ser."jcf of this 5ubp~M. you Me ordered by th. C'OUrt to produce the follaw;n! documents or ,hin!" ~1'F. ATTAC~HRn " MCS GROUP INC., 1601 MARKET ST., #800,PHILA.,PA 19103 IAdclnl., You m.y d.liver or m&illegibl. copies of th. doxum.nts or productthinp fltI;uesttd by thi. subpoena. ,o!ethtr with ,he eonifie... of <ampHlne.. '0 .h. pony mwngthis request It the Id=- Listed abo'<.. You ha... the right '0 ,o.k. in ,dunco. 'll. ,...onlbl. co.t of preparing the copies or producing th.llUnp_ghL If ~'ou flil te ~oduc. the doxum.nt. or things required by this sub~na. wit.....in "".nty (~l day. lilfr its ",,'i,o. .ho P"'Y ,,"'in! ,his subpoenl l't,.y snk . court ord.r comp.lling you to comply with ;>- THIS SLllPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: SAME: M1CHART. B. SCHR1B. ESO. ...OORESS: 110 S. NORTHERN WAY YORK, PA 17402 TELEPHOSE: 215-246-0900 St.:PRE.\fE COljJlT 10 ,: ... TIOR."EY FOR: nRFF.NnANT o ATE: <.\,,: p Ie /YI Ix: a '1- . i 0"0 I B51~O~ ~~..~ Seal of the Court (:.if i /97') EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. FRED MINIUM 1412 BRIDGE ST. NEW CUMBERLAND, P A 17070 RE: 73020 GREGORY LYNN SHEFFER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and inclu~~l the present. Subject: GREGORY LYNN SHE R 1176 RHODA BLVD., MECHANICSBURG, PA 17055 Social Security #: 208-38-6025 Date of Birth: 12-15-1951 SU10-331268 730:Z0-L05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS GREGORY & DEBRA SHEFFER TERM, -VS- CASE NO: 01-1245 JAMIE R. CANNADY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQUIRE 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 and, (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 10/03/2001 MICHAEL SCHEIB, ESQUIRE Attorney for DEFENDANT DE12-215925 73 a 2 a - La 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS GREGORY & DEBRA SHEFFER TERM. -VS- CASE NO: 01-1245 JAMIE R. CANNADY NOTICB OF I1l'l'BRT TO SBRVE A SUBPOBMA TO PRODUCB DOCUMBRTS AND THINGS FOR DISCOVERY PURSUAR'l' TO RULE 4009.21 nIB IIISUUHCE GROUP CAIlLISLE HOSPITAL DOIIALD ltOVACS, M.D. DAlI DEPALCIS, M.D. DR. FUD KllIlUH ALUAJlDER SPRIIIG UUAB, IIIe. DR. ROBERT BEADRY IIISUUHCE MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL MEDICAL TO: DAVID DlA1JE1l, ESQUIRE HCS on behalf of MlCIIAEL SCllElB, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days fraa the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is _ived or if no objection is _de, then the subpoena _y be served. C~lete copies of any reproduced records may be ordered at your eltpense by c~leting the attached counsel card and returning same to HCS or by contacting our local HCS office. DATE: 10/03/2001 HCS on behalf of MlCUAEL scm:lB, ESQUIRE Attorney for DEPEllDAlIT CC: MlCIIAEL scaIB, BSQUlU Any questions regarding this matter, cOQuet TIIIt HCS GROUP IIIC. 1601 IWlDT STRUT #aoo PHILADELPHIA, PA 19103 (215) 246-0900 DE02-166421 73020 - C 0 :L COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLA..'.:o GREGORY L.& DEBRA L.SHEFFER VS File So. 01-1245 JAMIE R. CANNADY SUBPOENA TO PRODUCE DOCtJMEl,.iS OR THI:"IGS FOR DISCOVERY PUR5UA..l\i TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: ALEXANDER SPRING REHAB (S ..me of P.non or =ti~) ........ithin rwe~' (.:0) QilYS Uter sendee of tN' SYbpoe~. you .are ordered by ti'l. C'O\Irt to produce the (ollowing documents or 'hings: <:1'.1' ATTA~Hl',n ., MCS GROUP INC.. 1601 MARKET ST., #800,PHlLA.,PA 19103 lAd_I' You m.y deU-'or or mail legible copies of the documents or produce thinp req"ested by this subpoena. ,ogoth.' with .h. c."ifieoto oi ,ompliance. to the pony mwng this r"'luest or the .ddreu listed abo\>e. You ha.-. the ,ight to ...k, in .d\'onco. tho ,...on.ble cost of preparing the copin or produ<ing the things -SlIt. If ~'ou fail to ~odu<e the documents or things required by this subpoena. wit.....in rwenry (:0) <lays oit.r ill ,.",':r.. .h. patry Sf",'ing .his 'u~poena m.y sNk. court ardltl' compelling you to comply with r_ THIS St"BPOEN A WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: :'I:AME: MTCHAF.L B. SCHF.1B. ESO. ADDRESS: 110 S. NORTHERN WAY YORK, PA 17402 TELEPHOSE: 215-246-0900 S1.;PRE.\fE COURT 10 It: ... TTOR."E"l' FOR: nKF'F:NTlAN1' DATE: S~p-kMb(r ~'1.a.(X>1 B&~~~ Protl'loft~.... Civil Division ~ /!II ~ Oe1Nry Seal of the Court (:.:f.7/97) EXPIANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALEXANDER SPRING REHAB, INC. 27 BROOKWOOD AVENUE CARLISLE, PA 17013 RE: 73020 GREGORY LYNN SHEFFER Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: GREGORY LYNN SHEFFER 1176 RHODA BLVD., MECHANICSBURG, PA 17055 Social Security #: 208-38-6025 Date of Birth: 12-15-1951 5U10-3312.70 7302. 0 - L 0 6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOERA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS GREGORY & DEBRA SHEFFER TERM, -VS- CASE NO: 01-1245 JAMIE R. CANNADY As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL SCHEIB, ESQUIRE 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 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) The parties have waived the twenty-day notice provided in Rules 4009.21 and 4009.22 and, (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 10/03/2001 MICHAEL SCHEIB, ESQUIRE Attorney for DEFENDANT DE12-215926 73020 - L 07 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE HATTER OF: COURT OF COMMON PLEAS GREGORY & DEBRA SHEFFER TERM, -VS- CASE NO: 01-1245 JAHIE R. CANNADY NOTICE OF IN'l'ENT TO SERVE A SUBPOEMA TO PRODUCE DOCUMER'rS AND THINGS FOR DISCOVERY PURSUAHT TO RULE 4009.21 nIB IMSUUIICE GROUP CAlILISLE HOSPITAL IlOI1ALD KOVACS, M.D. DAB DEPALCIS, M.D. DR. FRED MIlIIUH ALDAllDU SPUHG 1lEBAB, IMC. DR. ROBUT BEADI.Y IMSURAIlCE MlDICAL MlDICAL MlDICAL MlDICAL MlDICAL MlDICAL TO: DAVID IDIAUD., ESQUIRE MCS on behalf of K1CIIAEL SCRBIB, ESQUIRE intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days frOlll the date listed below in which to file of record snd serve upon the undersigned sn objection to the subpoena. If the twenty day notice period is _ived or if no objection is _de, then the subpoena _y be served. COIIIplete copies of sny reproduced records _y be ordered at your expense by cOIIIpleting the attached counsel card snd returning s_ to MCS or by contacting our local MCS office. DATE: 10103/2001 MCS on behalf of KICIIAEL SCHEIB, ESQUIRE Attorney for DEPDDAII'f CC: K1CIIAEL SCBEII, ESQUIU Any questions regarding this _tter, contact 'fBB MCS GI.OUP D1C. 1601 HAKIBT STREET '800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-166421 73 020-CO~ COMMONWEALTH OF PENNSYlVANIA . COUNTY OF CUMBERL.o\..':O GREGORY L.& DEBRA L.SHEFFER VS FHeSo. 01-1245 JAMIE R. CANNADY SUBPOENA TO PRODUCE DOCUME-.l'S OR THI~GS FOR DISCOVERY PURSUA.l\-rTO RULE 4009.2:2 TO: CUSTODIAN OF RECORDS FOR: DR. ROBERT BEADRY (S.m, of Penon or a.."tif!') .....i:hin rw."')' 1::01 <lays Aft.. .ervice of tltis .ubpoena. you are or<lerl!d by the ","un to produce the follo..ing document. or .hings: SF!': A1"rA~HF.n .t MCS GROUP lNC., 1601 MARKET ST., #800,PHILA.,PA 19103 IAd_sl You may <I.in.... or malllegibl. copi.. of th. doc:um.nts or produc. thinp f'ICl....t.d by tltis subpoen~ together ..ith tho c...ifico.. 0: co"'pli~c.. to the party malc.ing this r~...st at the oddtws listl!d obov.. You Mn the right ta .eek. in adnnce. the ,,,.sonobl. cost of pr.paring the copies or proclucing the things .....!ht. [[ ~'au fail te ;:"aduc. the docum.nts or tltings requirecl by tltis ...bpoeN. wit....in tw.nty (:Ill c!o~'s aitor ilS .......ice. 'he parry "",'ing ,iUs .u~po.n. moy s..k 0 CCNft ord.r compelling you to comply with i"_ THIS Sl"BPOENA WAS ISSUED AT THE REQUEST OF THE fOLLOWING PERSON: SAME: MTC!l1\F:L B. SCIlIU!!. ESO. ADDRESS: 110 S. NORTHERN WAY YORK, PA 17402 TELEPHO:\':: 215-246-0900 S1.:PRE.'fE COURT ID I: A rrOR.,-"EY FOR: n1':FF.N11AN'l' DATE: &~/V'lbu;):t. J.aM ,~~~~ hot.t&oftOlU"!fOl-Civiloivi'ian ~ /lfI- fJf~!:.~ Seal of lhe Court i:::f i (97') EXPlANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. ROBERT BEADRY 3600 OLD GETISBURG RD. CAMP HILL, PA 17011 RE: 73020 GREGORY LYNN SHEFFER Any and alI records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and incIu~:1 the present. Subject: GREGORY LYNN SHE R 1176 RHODA BLVD., MECHANICSBURG, PA 17055 Social Security #: 208-38-6025 Date of Birth: 12-15-1951 SUlO-331272 7302.0-L07 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED NOTICE OF DEPOSITION Please be advised that on November 13, 2001, at 1:00 p.m., the Plaintiff will take the deposition of the Defendant Jamie R. Cannady, at the offices of David W. Knauer, Esquire, located at 411 A East Main Street, Mechanicsburg, Pennsylvania, before a person authorized by law to administer oaths. The oral examination will continue from day to day until completed. You are invited to attend and participate in this examination. Respectfully suhmitted, Date: November 9,2001 KNAUER & ASSOCIATES, LSC (l tJ j/ tIa~~aub Attorney for the Plaintiff Attorney J.D. No. 21582 411-A East Main Street Mechanicsburg, P A 17055 (717) 795-7790 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 9th day of November, 2001, serve a true and correct copy of the Deposition Notice to Jamie R. Cannady on all counsel of record by United States mail, first class, prepaid addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York,PA 17402 MJ~ Attorney for Plaintiff Attorney LD. No. 21582 411-A East Main Street Mechanicsburg, P A 17055 (717) 795-7790 (') r; ::,:,,,- ""Dc: rnf; ~? G') ri ~~.-' ~ ,.... ... ..; :sE; :::1 -<. c) ."... :.-S "- "') :..> ...) , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED NOTICE OF DEPOSITION Please be advised that on December 17,2001, at I 1:00 a.m., the Plaintiff will take the deposition of the Defendant Jamie R. Cannady, at the offices of David W. Knauer, Esquire, located at 411 A East Main Street, Mechanicsburg, Pennsylvania, before a person authorized by law to administer oaths. The oral examination will continue from day to day until completed. You are invited to attend and participate in this examination. Respectfully submitted, Date: November 13,2001 Z7AU~~u7~lSC ~Knaue{ESqUire Attorney for the Plaintiff Attorney LD. No. 21582 411-A East Main Street Mechanicsburg, P A 17055 (717) 795-7790 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 13th day of November, 2001, serve a true and correct copy of the Deposition Notice to Jamie R. Cannady on all counsel ofrecord by United States mail, first class, prepaid addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 ~l.iiK=~~ Attorney for Plaintiff Attorney J.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (7 I7) 795-7790 0 C:J ~: .. <;1 :':"') r,"] z;; - <- , ~j) U t-: l. -, ;~ c. :-,i-: C"-; )> (::.~ i'..,) .'~t /..~ ~, ::;! - ~iJ \0 -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMiE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE )/ d'~ .. . AND NOW, thisl..:::l.---- day of November, 2001, i, Michael B. Scheib, a member of the firm of GRIFFiTH, STRICKLER, LERMAN, SOL YMOS & CALKINS, hereby certify that I have this date served the Notice Of Deposition by United States Mail, addressed to the party or attorney of record as follows: David W. Knauer, Esq. 411-A East Main Street Mechanicsburg, PA 17055 G"fI]i};litAN MI'h'" B. ~, ",","f:!- Supreme Court ID No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 o C <":' vC::~ gJ~,;' ~( r:~ ;. '~~i:-, ';"c: ,-=:,. z :2 c.,:. .'\'~ i'.) ==: PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and suttnitted in duplicate) 'IO THE PIDrHOOOTARY OF CUMBERLAND COUNI'Y Please list the following case, ( X) for JURY trial at the next tenn of civil co~. ::3 -0 cn ~ ( ) for trial without a jury. S2S:J z ------------------------------------~-~ CAPTION OF CASE ~ C -0 (entire caption llllSt be stated in full) (check one) :;;;8::E PC: ~ Civil Action -~ ~ (Check one) o 'T: Gregory L. Sheffer and Debra L. Sheffer (X ,", -:.It:q ':>:!S) .~~~ f, ' ~ ::.tJ -< Appeal from Arbitration ) (other) (Plaintiff) vs. Jamie R. Cannady The trial list will be called on 0 2 - 1 2 - 0 2 and Trials COITIrence on 03- 11 - 0 2 ( Defendant) Pretrials will be held on 02-20-02 (Briefs are due 5 days before pretrials.) vs. (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No.01-1245 Civil Term 1.~ Indicate the attorney who will try case for the party who files this praecipe, David W. Knauer, Esquire Indicate trial counsel for other parties if known, Michael B. Scheib, Esquire This case is ready for trial. Signed, ~ hI (~ Date~ I~ ?"oOz.., Print Narre, David W. Knauer, Esquire Attorney for, Plaintiff 18. Gregory L. Sheffer and Debra L. Sheffer : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V Jamie R. Cannady : NO. 01-1245 cNIL TERM ORDER OF COURT AND NOW, February 12, 2002, counsel having failed to call the above case for triaI, the case is stricken from the March 11, 2002 trial term. Counsel is directed to relist the case when ready. By the Court, /f)'avid W. Knauer, Esquire , For the Plaintiff ~chae1 B. Scheib, Esquire For the Defendant ') [~;R() -Jf)~ O;'-}I/ -OA.' l A'XS Court Administrator ld .f '\ ; '- '\ -I I) 'I 1 ~ i-fc;( I ~ 1'((1 frano 'Cd !) ,/4 eN... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22, Defendant, James R. Cannady 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 (2) 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 Subpoenas, is attached to this Certificate, (3) no objections to the Subpoena have 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: fl \~ t 03 GRIFFITH, STRICKLER, LE;;N(j. By '71JifrLi MIOh'~ Soh.'b, E',",,,, Supreme Court 10 No. 63868 Attorney for Defendant 110 South Northern Way York, PA 17402 (717) 757-7602 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE <lor\-t, \" \ AND NOW, this -d-L day of ~J\.l \~ ' 2003, I, Michael B. Scheib, a member of the firm of GRIFFITH, STRICKL~LERMAN, SOL YMOS & CALKINS, hereby certify that I have this date served a copy of the Certificate Prerequisite to Service of Subpoena Pursuant to Rule 4009.22 by United States Mail, addressed to the party or attorney of record as follows: David W. Knauer, Esquire 411-A East Main Street Mechanicsburg, PA 17055 GRIFFITH, STRICKLER, LERMAN, ::' YMO"lJ]J~cyjJ i"er B. Sohelb. E"'I,,, Supreme Court ID No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS TO: Dan DeFalcis, M.D., 175 Lancaster Boulevard, P.O. Box 2028, Mechanicsburg. PA 17055 Within TWENTY (20) days after service of this subpoena, you are ordered by the court to produce the following documenls or things: any and all medical records, reports, notes, charts, memoranda, correspondence and other documentation pertaining to Gregory Lynn Sheffer., Social Security No. 208-38-6025; DOB - 12/15/51. 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: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402 (717) 757-7602 Supreme Court 1.0. #63868 Attorney for Defendant Date: By: Seal of Court Prothonotary c: co 0 f:~; (,..) -'1 '- ., I '"tr' c:::: q;! I' r- " ~;;;' :"'.J , r~ 6}" i~_: -', ~: ..,......" , _-:l ):-.. -:) ~~. :.:::; ~-n ).--,. , ~ .> :u (11 ..< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY l. SHEFFER and DEBRA l. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22, Defendant, James R. Cannady 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 (2) 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 Subpoenas, is attached to this Certificate, (3) no objections to the Subpoena have 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:~ \ ~9 \03 GRIFFITH, STRICKLER, lERMAN, SOL YM~S & ;rlK~N~ I! By ~~MljJhV Michael B. ~'fieib, ECc;'uire Supreme Court ID No. 63868 Attorney for Defendant 110 South Northern Way York, PA 17402 (717) 757-7602 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this...dEL ~ay of Jql1 ,2003, I, Michael B. Scheib, a member of the firm of GRIFFITH, STRICKLEk. LERMAN, SOL YMOS & CALKINS, hereby certify that I have this date served a copy of the Certificate Prerequisite to Service of Subpoena Pursuant to Rule 4009.22 by United States Mail, addressed to the party or attorney of record as follows: David W. Knauer, Esquire 411-A East Main Street Mechanicsburg, PA 17055 By: i a B. Scheib, Esquire Supreme Court ID No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS TO: DR. ROBERT BEAUDRY, 3600 Old Gettysburg Road, Camp Hill, PA 17011 Within TWENTY (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: any and all medical records, reports, notes, charts, memoranda, correspondence and other documentation pertaininQ 10 GreQory Lynn Sheffer., Social Security No. 208-38-6025; DOB -12/15/51. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, logether with the certificate of compliance, to Ihe party making this request at the address listed above. You have the right to seek in adv,ance 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: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 S. Northern Way York, PA 17402 (717) 757-7602 Supreme Court I.D. #63868 Attorney for Defendant Date: By: Seal of Court Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATION OF "SATISFACTORY ASSURANCE OF NOTICE" PURSUANT TO HIPAA 164.512 (e)(1) The undersigned hereby certifies that the patient, Gregory L. Sheffer and Debra L. Sheffer, identified as the Plaintiffs in the foregoing subpoena, are represented in this litigation by David W. Knauer, Esquire, 411-A East Main Street, Mechanicsburg, PA 17055, that written Notice of Intent to issue and serve the aforegoing subpoena to obtain records was served upon David W. Knauer on or about '1 12-~ 2003, which Notice contained required language under the Pennsylvania Rules of Civil Procedure affording Attorney Knauer, on behalf of Plaintiffs, Gregory L. Sheffer and Debra L. Sheffer, to raise objections to the Court with respect to the aforegoing subpoena and I further certify that twenty (20) days have been waived since such Notice was provided to Attorney Knauer and no objections have been filed. Date: -1 \ J.-q ~ 1) ?, GRIFF..'''', STR'CKLE 'L1JjERMAN' .JjfL1M & i LKIN By: tl{tl ~ Michael B. Scheib, Esquire Supreme Court 10 No. 63868 Attorney for Defendant 110 South Northern Way York, PA 17402 (717) 757-7602 C) C" cc~ '- " e-' " n~ ,- 2: " ::~- i. :".) U.' r= i ~~:_: " ):; C. ~J C- o ::;; - ;;:, en -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATION OF "SATISFACTORY ASSURANCE OF NOTICE" PURSUANT TO HIPAA 164.512 (e)(1) The undersigned hereby certifies that the patient, Gregory L. Sheffer and Debra L. Sheffer, identified as the Plaintiffs in the foregoing subpoena, are represented in this litigation by David W. Knauer, Esquire, 411-A East Main Street, Mechanicsburg, PA 17055, that written Notice of Intent to issue and serve the aforegoing subpoena to obtain records was served upon David W. Knauer on or about 'II iJY) 2003, which Notice contained required language under the Pennsylvania Rules of Civil Procedure affording Attorney Knauer, on behalf of Plaintiffs, Gregory L. Sheffer and Debra L. Sheffer, to raise objections to the Court with respect to the aforegoing subpoena and I further certify that twenty (20) days have been waived since such Notice was provided to Attorney Knauer and no objections have been filed. Date: 1 \ ~ \1)2> ::'FF1ttlJtliJ Michael B. Scheib, Esquire Supreme Court ID No. 63868 Attorney for Defendant 110 South Northern Way York, PA 17402 (717) 757-7602 "12(:'- D)L. ~ G? F:, < . :fi- )>c ::'3 ~ o rc. c~ ,__', "- c.:: :_0 ':_J ::-..J '(") '-1"1 '-.- .-.! ?J -< t"_- .... PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PRCYl'HOIDrARY OF CUMBERLAND COUNTY Please list the following case: (Check one) x for JURY trial at the next tenn of civil court. for trial without a jury. ----------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (check one) Gregory L. Sheffer and Debra L. Sheffer (X) Civil Action - Law Appeal from Arbitration (other) (Plaintiff) vs. Jamie R. Cannady The trial list will be called on and August 12, 2003 Trials comrence on September 8, 2003 ( Defendant) Pretrials will be held on 08-20-03 (Briefs are due 5 days before p):'etriaJ.s. ) vs. (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No. 01 Civil 1245 :ii Indicate the attorney who will try case for the party who files this praecipe: David W. Knauer, Esquire of Knauer & Associates, L.S.C. Indicate trial counsel for other parties if known: Michael B. Scheib, Esquire of Griffith, Strickler, Lerman,_ Solymos & Calkins ,,_. ~ IIJ!.,,~ Print Narre~Jlj~ZJ, r#~1t Attorney for:~a. ,Aft: t r This case is ready for trial. fu'.J1 /6, ~'3 18. Gregory 1. Sheffer and Debra 1. Sheffer v Jamie R. Cannady : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-l245 CIVIL TERM ORDER OF COURT AND NOW, August 12, 2003, by agreement of counsel, the above captioned case is hereby continued from the September 8, 2003 trial term. Counsel is directed to relist the case when ready. ~vid W. Knauer, Esquire For the Plaintiff hichael B. Scheib, Esquire For the Defendant Court Administrator ld . ?LM~ R~~ 08-/4-03 By the Court, t.) ,~'j \ :-) ~') o 20. Gregory L. Sheffer and Debra L. Sheffer v Jamie R. Cannady IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-1245 CIVIL TERM ORDER OF COURT AND NOW, October 7,2003, counsel having failed to call the above case for trial, the case is stricken from the November 3, 2003 trial term. Counsel is directed to relist the case when ready. vf>avid W. Knauer, Esquire For the Plaintiff > tlMichael B. Scheib, Esquire For the Defendant Court Administrator ld ~~~ ~){~ }D-O'l-03 By the Court, GooIl'Pl , ! ,~''':2\.:\'i'','"\}\S\\: t ~ 3r! \ '-'_.,',:;:r'~~J :'6:\;':;.>1 u--.L:JU:)J PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) 'ID THE ProrHON:JrARY OF OJMBERLAND COUNTY Please list the following case: (Check one) (X) for JURY trial at the next term of civil court. for trial without a jury. ----~---------------------~-------------- CAPTION OF CASE (entire caption must be stated in full) Gregory L. Sheffer and Debra L. Sheffer (check one) (X) Civil Action - Law Appeal from Arbitration (other) (Plaintiff) vs. Jamie R. Cannady The trial list will be called on and 10-7-03 Trials comrence on 11 - 0 3 - 0 3 (Defendant) Pretrials will be held on 1 0 - 1 5 - 0 3 (Briefs are due 5 days before p):etrials.) vs. (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No. 01-1 245 Civil Term 19 Indicate the attorney who will try case for the party who files this praecipe: David W. Knauer, 411-A E Main street, Mechanicsburg, PA Indicate trial counsel for other parties if kn~: Michael B. Scheib, 110 South Northern Way, York, PA This case is ready for trial. Signed: ()MP W!~ Date: 09-15-03 Print Narre: David W. Knauer Attorney for: Plaintiff PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) 'ID THE ProrHON:JrARY OF OJMBERLAND COUNTY Please list the following case: (Check one) (X ) for JURY trial at the next term of civil court. for trial without a jury. ----------------------------------------- CAPTION OF CASE (entire caption must be stated in full) Gregory L. Sheffer and Debra Sheffer (check one) ( X) Civil Action - Law Appeal from Arbitration (other) (Plaintiff) vs. Jamie R. Cannady The trial list will be called on and 12-16-03 Trials comrence on 01-12-03 ( Defendant) Pretrials will be held on 01- (Briefs are due 5 days before pretrials.) vs. (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No. Civil 01-1245 19 Indicate the attorney who will try case for the party who files this praecipe: David W. Knauer, 411-A E. Main st., Mechanicsburg,PA Indicate trial counsel for other parties if kn~: Michael B. Scheib, 110 S. Northern Way, York, PA This case is ready for trial. "-" ~(j~ Print Name: David W. Knauer Date: 11-24-03 Attorney for: Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW No. 01-1245 Civil Term v. JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED NOTICE OF DEPOSITION Please be advised that on January 5, 2003, at 1 :30 p.m., the Plaintiff will take the deposition of Dr. Bruce Goodman, at his offices, located at 1515 North Front Street, Harrisburg, Pennsylvania, before a person authorized by law to administer oaths. The oral examination will continue from day to day until completed. You are invited to attend and participate in this examination. Respectfully submitted, Date: December 17, 2003 KNAUER & ASSOCIATES, LSC 02p;;/~<~1 ~f~. Knauer, Esquire Attorney for the Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 17th day of December, 2003, serve a true and correct copy of the Deposition Notice of Dr. Bruce Goodman on all counsel of record by United States mail, first class, prepaid addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 ~ ~- ../? '/ -- ~.,. <-----J""...> David W. Knauer Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 ....., C"., c:::. '-'-' c r.-, c-- (l .-,) ----! l"J:.~' L.,"' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED PETITION FOR APPOINTMENT OF ARBITRATORS TO: THE HONORABLE JUDGES OF SAID COURT: MICHAEL B. SCHEIB, ESQUIRE, counsel for the Defendant in the above action respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiff in the action is less than arbitration amount. The counterclaim of the Defendant in the action is N/A. The following attorney is interested in the case as counselor is otherwise disqualified to sit as an arbitrator: David W. Knauer, Esq. 411-A East Main Street Mechanicsbur9, PA 17055 (Attorney for Plaintiff) WHEREFORE, Your Petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. By: GRIFFITH, STRICKLER, LERMAN SOL YMOS & ALKINS :~AEL B . CH"hSQUI E Supreme Court I.D. #63868 Attorney for Defendant Jarnie R. Cannady 110 South Northern Way York, PA 17402 (717)757-7602 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law V5. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED ORDER OF COURT AND NOW, C)t'v~/~ petition, L}+ ,-'1 /~ ~ 16AL-. , 2004, in consideration of the foregoing ,Esquire and ~ ~ , Esquire, are appointed arbitrators in the above- captioned action as prayed for. BY THE COURT, ~ fJ. +..:, <'i :,?, {,I.I "" 6 "'fin? lWvl> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this ~daY of July, 2004, I, Michael B. Scheib, Esquire, a rnember of the firm of GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS, hereby certify that I have this date served a copy of the Petition for Appointment of Arbitrators, by United States Mail, addressed to the party or attorney of record as follows: David W. Knauer, Esq. 4 11-A East Main Street Mechanicsburg, PA 17055 (Attorney for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS By: l~'/' J?t gjJ MICHAE~. SCHEIB, ESQ~ Supreme Court ID No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 Attorney for Defendant, Jamie Cannady Ail (J ~ t ~ 10 '- fro.. D h 6'!" 0 jj ~ ~ ....j -..() r--- '-0 }: ~ .~. , '-.) '.:- ( , C : Gregory L. Sheffer and Debra L. Sheffer Plaintiff In The Court of Common Pleas of Cumberland County, Pennsylvania No. ~_ 1245 Jamie R. Cannady Defendant Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the Untied States and the Constitution of this Commonwealth and that we will discharge the duties of r office with ldelity. Joseph D. Buckley Name (Chainnan) Law Offices of Joseph D. Buckley Law Firm Steven Howell Name Rolf E. Kroll Name Law Office of Steven Howell Law Finn Margolis Edelstein Law Finn 1237 Holly Pike Address 619 Bridge Street Address 3510 Trindle Road Address Carlisle, PA 17013 City, Zip New Cumberland, PA 17070 City, Zip Camp Hill, PA 17011 City, Zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) ,. ~~"'" OF ;:J(,Aho.lT"U"" Pe78IfA L. S~rFIi:/I.. IS J)/ShU~~C70. ;I. Jt.tIJ~ Pl>'.4 /CA?IV71~p is Jft::_ <)"1 l.. :S",';:"FtDt.,. l"iV nfi: ~ 0': ." 6,l./{)o.'" flu.. CJ)STS _411 S~"-7 "1I/1"9C-<f:ff. . Ar rator, dissents. (Insert name if applicable.) Notice of Entry of A Now, the ~~-\l. day of Sepk...I:.er, 20 01.1 , at 10: 1\ , .!L.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Date of Hearing: ~ ~ i!0ll'( Date of Award: ~ .,:zt;, ~ n to be paid upon appeal: $ aqo.oo By: ~ Ilf ~I/!!i j9'3-6CJ -'(77~ <;!;rJ-/ ;;1~c.Jf)f7 Ivv.-el! ~~r- ~ ,,,> '" D - ~ - Q "'- --<::: 23 ~ :;; i"- S-- ", ~ .:c ~ 5<.. "'-- 6-' 6 b b -4-. v) () '?' -- ,,~ ~ p " 1:; " ~ <,,(::Jr> '" '" . -, ~?- /> ~ >= ~ ,"" " "\ .... :>> ~ ~ v' ('> " ~ A- "" ~ c": ,..., c::;;::. ~ :::i~ V) :.:;:J j'q ~.~.. -n -c~ rnF f'.,) ~J-~ C() -" l6 (;~2~::~ C) i':.::;;~f1 G 12f!40.t'~ L. 5~f:#V2cL Q) s:.!Y I2B L. )"L..'2/AJL /{\ JJ P{ t((';vf; hS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA /7 Jt\.~{ t V' (2, {'!~.v~h D~fv~ NO. () I ( L tt-S NOTICE OF APPEAL FROM AWARD OF BOARD OF ARBITRATORS TO THE PROTHONOTARY: Notice is given that _~ l"'-t'Ir-~ i fA from the ,\ward of the board of arbitrators entered in this case on sr~Vt. ~ UJ() If . A jury trial is demanded O. (Check box if a jury trial is demanded. Other wise jury trial is waived.) appeals I hereby certify that: 1. The compensation of the arbitrators has been paid, or -2. f.-'flplieatieR h;l~ np.en make for peITlli~~ion to rm~eecl in fOITlll'l pl'll1pPri~ (Strike out the i plicable clause) NOTE: The demand for jury trial on appeal from compulsory arbitration is governed by Rule 1007 .1 (b), (b) No affidavit or verification is required. ~~~ ~~ =<' 3.\.. \-- L ~ D d' C) c; --I -- l'<~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND' COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED PRAECIPE TO REQUEST JURY TRIAL Pursuant to Pa. R.C.P. Rule 1007.1 (b) Defendant Cannady hereby requests a jury trial. GRIFFITH, STRICKLER, LERMAN SOLYMOS & CALKINS ./': By: / MICHA L B. SC :lB, ESO Supreme Court I.D. #63868 Attorney for Defendant Jamie Cannady 110 South Northern Way York, PA 17402 Telephone (717) 7S7-7602 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs Civil Action - Law vs. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 29th day of October, 2004, I, MichaE~1 B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS, hereby certify that I have this date served a copy of the Praecipe to Request Jury Trial, by United States Mail, addressed to the party or attorney of record as follows: David W. Knauer, Esq. 411-A East Main Street Mechanicsburg, PA 17055 (Attorney for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS By: ~ MI AEL B. S HEI~, ESQUIR Supreme Court 10 No. 63868 110 South Northern Way York, Pennsylvania 1 7402 (717) 757-7602 Attorney for Oefend,ant, Jamie Cannady (") ~~; .ut.J~:; ~~~ ~ j: ' : ';, I , }- " ,....., <:::;) = ..&:- ;;;I'" c5 ..-..;: I W ~ ~ nip -':1m 23 Cj) ~::!Q ~j) .:d .:-~ (:> om ,--I :t:~ ~'D :< -0 -",. -.... w . . (...) t\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and Civil Action - Law,~ DEBRA L. SHEFFER RECEIVED MAY 04 200slfi Plaintiffs vs. No. 01.1245 ~AMIE R. CANNADY i Defendant JURY TRIAL DEMANDED ORDER AND NOW, TO WIT, this .r day of /11~ , 2005, it is hereby ORDERED t~at Defendant's Motion to Compel is GRANTED. Plaintiffs must produce a written report f~m any individual that Plaintiffs intend to call as an expert witness within '1~ days. If I Pllaintiffs fail to produce any expert witness reports within this time frame, then Plaintiffs will I b~ precluded from calling any expert witnesses and Defendant may list the case for trial. i ,t4~ \ ;;P: ~s c:),O o I'" ( U,_:.---: So> (~ \.\- /"'}'''-:-, \ '< GjL:i: ~UJ i;'" i'S "">-. tc; L~ -:X ~','U 0.... _:T I - ~;;: >': PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) 'ID THE ProrHONJTARY OF OJMBERLAND COUNTY Please list the following case: (Check one) x for JURY trial at the next term of civil court. for trial without a jury. ----------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (check one) Civil Action - Law ( X) Appeal from Arbitration (other) GREGORY L. SHEFFER AND DEBRA L. SHEFFER, (Plaintiff) vs. The trial list will be called onMAY 16, 2006 and Trials commence on JUNE 12, 2006 JAMIE R. CANNADY, (Defendant) vs. Pretrials will be held on MAY 24, 2006 (Briefs are due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1.) No. 1245 Civil Term D: 2001 Indicate the attorney who will try case for the party who files this praecipe: MICHAEL B. SCHEIB FOR DEFENDANT Indicate trial counsel for other parties if known: DAVID W. KNAUER, FOR PLAINTIFFS This case is ready for trial. "-" /jt)JhJJI- Date: tJ!7/!J~ / I Print Name: MICHAEL B. SCHEIB Attorney for: DEFENDANT, JAMIE R. CANNADY PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROrHON:JrARY OF OJMBERLAND COUNrY Please list the following case: (Check one) x for JURY trial at the next term of civil court. for trial without a jury. ----------------------------------------- CAPTION OF CASE (entire caption must be stated in full) (check one) Civil Action - Law (X) Appeal from Arbitration GREGORY L. SHEFFER AND DEBRA L. SHEFFER, (Plaintiff) ( other) vs. The trial list will be called on MAY 16, 200 and JAKIE R. CANNADY, Trials commence on .JUNE 12, 2006 (Defendant) Pretrials will be held on MAY 24, 2006 (Briefs are due 5 days before pretrials. ) vs. (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214.1. ) No. 1245 Civil Term >tiI 2001 Indicate the attorney who will try case for the party who files this praecipe: MICHAEL B. SCHEIB FOR DEFENDANT Indicate trial counsel for other parties if known: 'iPAVID W. KNAUER, FOR PLAINTIFFS This case is ready for trial. Signed: 1/tt&J~Jtf Date: Print Name: MICHAEL B. SCHEIB Attorney for: DEFENDANT, JAKIE R. CANNADY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs, Civil Action - Law v. No. 01-1245 JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICA TE OF SERVICE AND NOW, this / 7 f~ay of April, 2006, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS, hereby certify that I have this date served a copy of the Praecipe for Listing Case for Trial, by United States Mail, addressed to the party or attorney of record as follows: David W. Knauer, Esq. 411-A East Main Street Mechanicsburg, PA 17055 (Attorney for Plaintiff) GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS By: MICHAEL B. SCHEIB, ESQU Supreme Court ID No. 63868 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602 Attorney for Defendant, Jamie Cannady ---, "-\\ (. -\,<', (;' .. David W. Knauer, Esquire Attorney 1.0. No. 21582 Knauer & Associates, L.S.C. 411-A E. Main Street Mechanicsburg, PA 17055 Knauer@early.com 717-795-7790 717-795-7793 Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW No. 01-1245 Civil Term v. JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED NOTICE OF DEPOSITION Please be advised that on May 30, 2006, at 4:30 p.m., the Plaintiff will take the deposition of Dr. Robert Beaudry, at his offices, located at 3600 Old Gettysburg Road, Camp Hill, Pennsylvania, before a person authorized by law to administer oaths. The oral examination will continue from day to day until completed. You are invited to attend and participate in this examination. Respectfully submitted, Date: May 10, 2006 ~R & ASSOCIATES, LSC ~~~ David W. nauer, Esquire Attorney for the Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 10th day of May, 2006, serve a true and correct copy of the Deposition Notice of Dr. Robert Beaudry on all counsel of record by United States mail, first class, prepaid addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 avid W, Knauer Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 ("") c ~ ....~t- ""0. l1:; n1r: Z::; Z'- a))~ :St. !.:::- ~E )>c Z ~ I""-,;) = c;:> d""' ::r;: 3> -< ~ ~~ -om ;I? X 1..-)0 .,-.\ ... :c-'d ~~ C-) .<-("11 ~ ~ ~ -0 ::a:: ':~ C) vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-1245 CIVIL GREGORY L. SHEFFER and DEBRA L. SHEFFER, Plaintiffs JAMIE R. CANNADY, Defendant IN RE: PRETRIAL CONFERENCE Present at a pretrial conference held May 24, 2006, were David W. Knauer, Esquire, attorney for the plaintiffs, and Michael B. Scheib, Esquire, attorney for the defendant. This case arises out of an automobile accident which occurred on May 26, 1999, when the defendant drove into the back of the plaintiffs' vehicle. The defendant has admitted negligence. There will be a question in the case as to the extent of the plaintifr s recovery for medical bills. The defendant contends that not all of the bills were related to the motor vehicle accident and, in any event, the plaintiff did not actually pay the medical expenses. As this case involves a limited tort election, there is a threshold question as to whether or not the plaintiff has sustained a serious impairment of a bodily function. This otherwise uncomplicated case should take no more than two days to try. David W. Knauer, Esquire For the Plaintiffs . III May 24, 2006 Michael B. Scheib, Esquire For the Defendant Court Administrator \iiNV/\~V\Si<N3d I It ,r,~. ", '~-..""n'"' AJ.. \;1 \t,,":(,'\! tv 9l :01 W1 Sl AIm 9@Z IllWIC"' .".' ,""'1 :lHl ~o I\U If \...!!\\.)n".I).:JQ -' ;:: 3~:wo-mll:J David W. Knauer, Esquire Attorney I.D. No. 21582 Knauer & Associates, L.S.C. 411-A E. Main Street Mechanicsburg, PA 17055 Knauer@early.com 717-795-7790 717-795-7793 Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW No. 01-1245 Civil Term v. JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED NOTICE OF DEPOSITION Please be advised that on June 2,2006, at 1:30 p.m., the Plaintiff will take the deposition of Dr. Bruce Goodman, at his offices, located at 1515 North Front Street, Harrisburg, Pennsylvania, before a person authorized by law to administer oaths. The oral examination will continue from day to day until completed. You are invited to attend and participate in this examination. Respectfully submitted, Date: May 24, 2006 K~ER & ASSOCIA)ES, LSC f/al.i& 4J /~/ULfl-/ David W. auer, Esquire Attorney for the Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 24th day of May, 2006, serve a true and correct copy of the Deposition Notice of Dr. Bruce Goodman on all counsel of record by United States mail, first class, prepaid addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 fi!~l!~ ~kJ) Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 (") c ., ;:gn -/",., ):- ct! ..-,: \_~ ,c." :;~ -<. ...., = = "'"' o -n --j :J:-n f"11p:: -nfl1 :.)c;:! (~?, (j~." ;~,~~~ C~ ~ "'"" -< N t.rl -v -- - ~ .l'"" <.J"j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER, Civil Action - Law Plaintiffs, No. 01-1245 v. JAMIE R. CANNADY, Defendant. JURY TRIAL DEMANDED MOTION IN LIMINE OF DEFENDANT JAMIE R. CANNADY Come Now Defendant Jamie R. Cannady, by and through his attorneys, Griffith, Strickler, Lerman, Solymos & Calkins, and Michael B. Scheib, Esquire, and files this Motion In Limine. Defendant Cannady requests this Honorable Court to: I. Preclude Mention ofInsurance; and, II. Preclude Introduction of Plaintiff s Medical Bills. I. MOTION IN LIMINE TO PRECLUDE MENTION OF INSURANCE The general rule in Pennsylvania is that evidence of insurance is irrelevant and justifies the grant of a mistrial. See, Divelv v. Penn Pittsburgh Corporation, 332 Pa. 65, 2A.2d 831 (1938): Paxton National Insurance Comoanv v. Brickailik, 513 Pa. 627, 522 A.2d 531 (1987). The mention of insurance or the fact that the Defendant has insurance coverage for this lawsuit would prejudice the Defendant and would require a mistrial. Phillios v. Shoenberger, 369 Pa. Super. 52, 534 A.2d 1075 (1987). WHEREFORE, Defendant Jamie R. Cannady respectfully requests this Honorable Court to enter an Order to preclude the parties, the attorneys and all witnesses 1 from usmg the word "insurance" during their testimony, or inferring, implying or testifying that the Defendant is covered under a liability policy. II. MOTION IN LIMINE TO PRECLUDE INTRODUCTION OF PLAINTIFF'S MEDICAL BILLS Plaintiff Gregory Sheffer is a limited tort plaintiff. Pursuant to Pennsylvania Law, Plaintiff Sheffer will be allowed to recover "his" out-of-pocket expenses. Plaintiff Sheffer does not have any lost wages. Accordingly, his out-of-pocket expenses will be limited to his medical expenses. During discovery, Plaintiff Sheffer produced a hand written note which was entitled "Out of Pocket Expenses". A copy is attached hereto as Exhibit A. This document indicates that the out-of-pocket expenses total $5,926.68. During the Pre-Trial Conference, Defense counsel showed the document to Judge Hess. Plaintiffs counsel did not indicate that the document needed to be updated. A. THE OUT OF POCKET EXPENSE FIGURE SHOULD BE REDUCED BECAUSE MR. SHEFFER DID NOT INCUR THE EXPENSE The document indicates that Crossroads Bible (Plaintiffs Sheffer's employer) paid $1,200. Thus, the out-of-pocket expense figure should be reduced by this amount. Plaintiff Sheffer did not pay this bill out of his pocket. He did not incur this expense. B. THE OUT-OF POCKET EXPENSE FIGURE SHOULD BE REDUCED BY THE AMOUNT OF DR. MINIUM'S BILLS The Out-of-Pocket Expenses Sheet prepared by Plaintiff Sheffer indicates that Dr. Minium bills totaled $1,200. Plaintiff Sheffer has indicated that he paid $556.30 and has an outstanding balance of $643.70. Since Plaintiff Sheffer has not incurred the 2 out-of-pocket expense, the outstanding balance of $643.70 should not be admitted into evidence. In addition, the entire amount of Dr. Minium's bills should not be allowed. No one will testify that Dr. Minium's bills of $1,200 are related to this motor vehicle accident. Dr. Minium will not testify at this trial. None of Plaintiffs expert witnesses have said that the $1,200 bill from Dr. Minium is related to the motor vehicle accident. The $1,200 bill from Dr. Minium is for plaintiffs new dentures. Plaintiff Sheffer had 21 year old dentures at the time of the motor vehicle accident. Dr. Boyle testified that the American Dental Association recommends that a person have his dentures rechecked every 5 years. The motor vehicle accident is not the reason for the new dentures. C. THE OUT-OF POCKET EXPENSES SHOULD BE REDUCED BECAUSE PLAINTIFF'S EXPERT WITNESS HAS NOT STATED THAT THEY WERE REASONABLE, NECESSARY, CUSTOMARY AND RELATED TO THE MOTOR VEHICLE ACCIDENT The Out-of-Pocket Expense sheet list medical bills from Central PA MRI ($875.00), PRISM, P.C. ($360.00), Alexander Springs Rehab ($508.00) and Yellow Breeches Family Practice ($33.00). These medical bills total $1,776.00. None of Plaintiff s witnesses will testify that these bills are reasonable, necessary, customary or, most importantly, related to the motor vehicle accident. Without this testimony the medical bills are not admissible. More importantly, Plaintiff Sheffer has not incurred any out-of-pocket for these expenses. In discovery, Plaintiff has produced a letter dated March 21, 2000, from American Sentinel Insurance Company (ASIC) to Central PA MRI Center. In this letter, 3 ASIC refused to pay the Central P A MRI Center bill of $850.00 because the benefits had been paid directly to the claimant, Gregory Sheffer. A few months later Plaintiff Sheffer sent a check for $850.00 to Central PA MRI Center. He however, did not incur an out- of-pocket expense. Rather, the insurance company check had been sent directly to him instead ofto the health care provider. WHEREFORE, Defendant Jamie R. Cannady respectfully requests this Honorable Court to enter an Order to preclude or limit the medical bills Plaintiff Sheffer can introduce into evidence. Date: ~/ll-~ I GRIFFITH, STRICKLER, LERMAN, SOL YMOS & CALKINS BY fi~JJJ MIC AEL B. SCHEID, ESQUIRE Supreme Court LD. No. 63868 110 South Northern Way York,PA17402 Telephone: (717) 757-7602 Attorney for Defendant 4 ~l,'b ,+ ;q Ou+ 0('"' A c.-fa...J- E;;-pe...JUJ Cc,+f~(, fa /'?!?T f~S"/ry , pc, Ck -.:/( 779 g 7-S. 00 Cl:.. ;zf. 780 C!P.. .DCFP!oS) :J (0. (>0 1) It- F(zaJ M;,.)I<.l"'1 C k. JI 17.2- (SoL sJ,t! ()UCb b ,$'3. 70 ..$S'b.. 3" tJ U.l,4.l~ fr~rl '- f?t:.~Lf Ck.. 11 7$,;). ~og 00 g[/l <J~~ .s- Ui ~ Cff77S 1'11:1. "Jrj o (U:JL 300. 00 fl r I If :H. 31 fl I' I' co C(kss.(,IA(lJ. ~"a::. Ii 'I 17 I ;2 0(" fbr~l). VaLe... bt.<<cth ~/7 f'~cc lJ. 00 - -- 98 (;,Yl. 70 ~ ;2 g). 6.i-sb,.Di.i ~ fl'<ftl:> T~L 68 S9,;J.c.., Cu-4~( /'Y}ct)jC~ t"i:1Jf( 6",v,p~ ) C T&;.ts ;/....,,+)- . r~V'\ " o ~ "" C' ,.,:,:~) d.., <-- :'::,;~ o -n -l :1;jC1 n~ =~~~; --') (:,\ . {>- -' ~ ~ ) ~-;\ )' ". N \..!? ''is :< -- ,::- .. David W. Knauer, Esquire Attorney 1.0. No. 21582 Knauer & Associates, L.S.C. 411-A E. Main Street Mechanicsburg, PA 17055 Knauer@earty.com 717-795-7190 717-795-7193 Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED PRAECIPE TO SETTLE, END, AND DISCONTINUE TO THE PROTHONOTARY Market the docket in the above case settled, ended, and discontinued. Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. -0/ Date: July 20, 2006 avid W. Knau r, Esquire Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GREGORY L. SHEFFER and DEBRA L. SHEFFER Plaintiffs CIVIL ACTION - LAW v. No. 01-1245 Civil Term JAMIE R. CANNADY Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 20th day of July, 2006, serve a true and correct copy of the Praecipe to Settle, End, and Discontinue, on all counsel of record by United States mail, first class, prepaid addressed as follows: Michael B. Scheib, Esquire Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 ~ud2~ avid W. Knau r Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 ,. --~ ... i"::' c_ ~ ;':'1;; ~ ' ,') c