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HomeMy WebLinkAbout10-6161FELLERMAN & CIARIMBOLT Kirby Park Commons 183 Market Street, Suite 200 Kingston, PA 18704 (570) 718-1444 (570) 714-7255 (FAX) www.714HURT.com may!AE?F.\` "4 H P'?`^r-?'7I+ HE V 1HG 03,, i l10 S E F ?'M 3" ' , r'UMBE'hAND CUNIT" Edward J. Ciarimboli, Esquire ID# 85904 ejc@714HURT.com Gregory E. Fellerman, Esquire ID# 81568 gef@714HURT.com CASEY JOHNSON IN THE COURT OF COMMON PLEAS OF 4616 Hampden Ave. CUMBERLAND COUNTY Camp Hill, PA 17011 Plaintiff CIVIL ACTION - LAW JURY TRIAL DEMANDED V. MICHAEL DONACHIE 120 Evergreen Circle Dillsburg, PA 17019-9630 10 - 61(o( 0,1vil lem NO. OF MELISSA OLSON 68 Azalea Drive - Hershey, PA 17033-2602 c ? . _; ..? ?f ' WILLIAM C. SEELY, JR. j p 13 C) 1616 Cressman Circle `=v Mechanicsburg, PA 17055-5911 L-j Defendant(s) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Kindly issue a Writ of Summons in Civil Action at Law against the Defendants in the above matter. 0 40.00 Pb c* 340' eags773 Respectfully submitted, FELLERMAN & CIARIMBOLI LAW, P.C. By: A C_&A T'. I ? _? MICHAEL J. OMANISH, ESQUIRE Attorney for the Plaintiff 183 Market Street, Suite 200 Kingston, PA 18704 Dated: ?? 1? FELLERMAN & CIARIMBOLI LAW Kirby Park Commons 183 Market Street, Suite 200 Kingston, PA 18704 (570) 718-1444 (570) 714-7255 (FAX) www.714HURT.com Edward J. Ciarimboli, Esquire I D# 85904 ejc@714HURT.com Gregory E. Fellerman, Esquire ID# 81568 gef@714HURT.com CASEY JOHNSON IN THE COURT OF COMMON PLEAS OF 4616 Hampden Ave. CUMBERLAND COUNTY Camp Hill, PA 17011 Plaintiff CIVIL ACTION - LAW JURY TRIAL DEMANDED V. MICHAEL DONACHIE 120 Evergreen Circle Dillsburg, PA 17019-9630 MELISSA OLSON 68 Azalea Drive Hershey, PA 17033-2602 WILLIAM C. SEELY, JR. 1616 Cressman Circle Mechanicsburg, PA 17055-5911 Defendant(s) Iv-6141 a;%V %ITeXh NO. OF WRIT OF SUMMONS TO: MICHAEL DONACHIE 120 Evergreen Circle Dillsburg, PA 17019-9630 A Writ of Summons has been issued in the above-referenced civil action naming you as a Defendant. Dated a PROTHONOTARY BY: D FELLERMAN & CIARIMBOLI LAW Kirby Park Commons 183 Market Street, Suite 200 Kingston, PA 18704 (570) 718-1444 (570) 714-7255 (FAX) www.714HURT.com Edward J. Ciarimboli, Esquire ID# 85904 ejc@714HURT.com Gregory E. Fellerman, Esquire I D# 81568 gef@714HURT.com CASEY JOHNSON IN THE COURT OF COMMON PLEAS OF 4616 Hampden Ave. CUMBERLAND COUNTY Camp Hill, PA 17011 Plaintiff CIVIL ACTION - LAW JURY TRIAL DEMANDED V. MICHAEL DONACHIE 120 Evergreen Circle Dillsburg, PA 17019-9630 MELISSA OLSON 68 Azalea Drive Hershey, PA 17033-2602 WILLIAM C. SEELY, JR. 1616 Cressman Circle Mechanicsburg, PA 17055-5911 Defendant(s) WRIT OF SUMMONS TO: MELISSA OLSON 68 Azalea Drive Hershey, PA 17033-2602 I 0 0141 bvi I TeXrN NO. OF A Writ of Summons has been issued in the above-referenced civil action naming you as a Defendant. Dated h& Ito PR HONOTARY BY: FELLERMAN & CIARIMBOLI LAW Kirby Park Commons 183 Market Street, Suite 200 Kingston, PA 18704 (570) 718-1444 (570) 714-7255 (FAX) www.714HURT.com Edward J. Ciarimboli, Esquire ID# 85904 ejc@714HURT.com Gregory E. Fellerman, Esquire ID# 81568 gef@714HURT.com CASEY JOHNSON IN THE COURT OF COMMON PLEAS OF 4616 Hampden Ave. CUMBERLAND COUNTY Camp Hill, PA 17011 Plaintiff CIVIL ACTION - LAW JURY TRIAL DEMANDED V. MICHAEL DONACHIE 120 Evergreen Circle Dillsburg, PA 17019-9630 MELISSA OLSON 68 Azalea Drive Hershey, PA 17033-2602 WILLIAM C. SEELY, JR. 1616 Cressman Circle Mechanicsburg, PA 17055-5911 Defendant(s) )0_414( C?vi( lets, NO. OF WRIT OF SUMMONS TO: WILLIAM C. SEELY, JR. 1616 Cressman Circle Mechanicsburg, PA 17055-5911 A Writ of Summons has been issued in the above-referenced civil action naming you as a Defendant. Dated ' P OTARY BY: Aac&ff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~4ant~, n'[ ~auutlrr~i,~r~,t} ~~~~~'0''-2 Phi I~ ~~ Richard W Stewart Solicitor ... ~.~3'~4aE~,~..~4:~u l~~~sa~ ~ , ~~~i~p~c~ a ~ , a6! r'j Casey Johnson vs. Case Number Michael Donachie (et al.) 2010-6161 SHERIFF'S RETURN OF SERVICE 09/30/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Michael Donachie, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of York County, PA to serve the within Writ of Summons according to law. 09/30/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Melissa Olson, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, PA to serve the within Writ of Summons according to law. 10/04/2010 06:26 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 4 2010 at 1826 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: William C. Seely Jr., by making known unto himself personally, at 1616 Cressman Circle, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. .\ ROB T BITNER, DEPUTY 10/12/2010 05:18 PM -York County Return: And now October 12, 2010 at 1718 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Michael Donachie by making known unto himself personally, at 120 Evergreen Circle, Dillsburg, PA 17019 its contents and at the same time handing to him personally the said true and correct copy of the same. 10/19/2010 06:48 PM -Dauphin County Return: And now October 19, 2010 at 1848 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Melissa Olson by making known unto Patricia Olson, Mother of defendant at 68 Azalea Drive, Hershey, PA 17033 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $69.00 November 01, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ,r,; C~ou ..:.f lE~ec ;oft. Irc. SHERIFF'S OFFICE OF YORK COUNTY 4 Richard P Keuerleber PETER J. MANGAN, ESQ. Sheriff Solicitor .r.r Reuben B teager Richard E Rice, II Chief Deputy, Operations Chief Deputy, Administration CASEY JOHNSON vs. MICHAEL DONACHIE Case Number 10-6161 CIVIL SHERIFF'S RETURN OF SERVICE 10/12/2010 05:18 PM -DEPUTY TERRY DRAWBAUGH, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED WRIT OF SUMMONS (WOSM) BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: MICHAEL DONACHIE AT 120 EVERGREEN CIRCLE, DILLSBURG, PA 17019. SHERIFF COST: $73.00 October 27, 2010 NOTARY TERRY DRAWBAUGH, DE UTY SO A RS, R CHARD P UE LE ER, SHERIFF Affirmed and subscribed to before me this COMMONWEALTH OF PENNSYLVANIA 2 7th day of ~~~ ,.~ OCTOBER 2 ~ 1 ~ NOTARIAL SEAL ~ G'ly""'l ~ LISA L. THORPE, NOTARY UBLIC << ' °^a~te ` "'nor "°~t"~>~>`~ ~"~ CITY OF YORK. YORK COUNTY MY COMMISSION EXPIRES AUG. 12, 2013 William T. Tully Solicitor :: Dauphin County Harrisburg, Pennsylvania 17101 ph: (717)780-6590 fax: (717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin CASEY JOHNSON MELISSA OLSEN Sheriff s Return No. 2010-T-3145 OTHER COUNTY NO.20106161 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy VS And now: OCTOBER 19, 2010 at 6:48:00 PM served the within WRIT OF SUMMONS upon MELISSA OLSEN by personally handing to PATRICIA OLSEN 1 true attested copy of the original WRIT OF SUMMONS and making known to him/her the contents thereof at 68 AZALEA DRIVE HERSHEY PA 17033 MOTHER Sworn and subscribed to before me this 21ST day of October, 2010 ~~~ COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Kazen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Ex Tres Au ust 17 2014 So Answers, ~~°i~~L. Sheriff of Dauphi o Pa By Deputy Sheriff Deputy: G MILLER Sheriff s Costs: $49.25 10/6/2010 AF FELLERMAN & CIARIMBOLI LAW Kirby Park Commons 183 Market Street, Suite 200 Kingston, PA 18704 (570) 718-1444 (570) 714-7255 (FAX) www.714HURT.com CASEYJOHNSON 4616 Hampden Ave. Camp Hill, PA 17011 V. MICHAEL DONACHIE 120 Evergreen Circle Dillsburg, PA 17019-9630 MELISSA OLSON 68 Azalea Drive Hershey, PA 17033-2602 Plaintiff WILLIAM C. SEELY, JR. 1616 Cressman Circle Mechanicsburg, PA 17055-5911 Defendant(s) Edward J. Ciarimboli, Esquire ID# 85904 ejc@714HURT.com Gregory E. Fellerman, Esquire ID# 81568 gef@714HURT.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW JURY TRIAL DEMANDED =1 cn r-- :;3 Cn CD /U NO. W-6161 CIVIL TERM PRAECIPE FOR WITHDRAWAL OF DEFENDANTS TO THE PROTHONOTARY of CUMBERLAND COUNTY, PENNSYLVANIA: KINDLY Withdraw the following named Defendants ONLY from the above-referenced lawsuit: Michael Donachie 120 Evergreen Circle Dillsburg, PA 17019-9630 Melissa Olson 68 Azalea Drive Hershey, PA 17033-2602 December 13, 2010 Pd-14 S-60 "'? F"11P'YMA'0 (I e.# ?3qjs FELLERMAN & CIARIMBOLI LAW PC (? /_*Io? C. BY: G EGORY E. FELLERMAN, ESQ. F4 t# ?53335 ORDER OF PROTHONOTARY NOW, THIS DAY OF -, 2010, the aforementioned Defendants, MICHAEL DONACHIE and MELISSA OLSON shall be removed from this lawsuit. PROTHONOTARY of CUMBERLAND COUNTY BY: f Joseph G. Muzic, Jr., Esquire NIKOLAUS & HOHENADEL, LLP 212 North Queen Street Lancaster, PA 17603 (717) 299-3726 (717) 299-1811 fax jmuzic@n-hlaw.com Attorney I.D. No. 55919 Attorney for Defendant Melissa Olson CASEY JOHNSON, Plaintiff vs. MICHAEL DONACHIE, MELISSA OLSON and WILLIAM C. SEELY, JR., Defendants TO THE PROTHONOTARY: FIL FO-O FICS l1CZAF, IT\/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 10-6161 JURY TRIAL DEMANDED ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Defendant Melissa Olson, in reference to the above matter. Date: ) - q - I Jo G uzic, Jr., Esquire tto for Defendant Melissa Olson No. 10-6161 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Entry of Appearance was sent by first-class mail, postage prepaid on the date set forth to the following: Michael J. Domanish, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street, Suite 200 Kingston, PA 18704 Mr. Michael Donachie 120 Evergreen Circle Dillsburg, PA 17019-9630 Mr. William C. Seely, Jr. 1616 Cressman Circle Mechanicsburg, PA 17055-5911 NIKOLAUS & HOHENADEL, LLP Date: / - y- ! J ph G. M c, Jr., Esquire Atto r Defendant Melissa Olson 2 Fellerman & Ciarimboli Law PC Kirby Park Commons 183 Market Street Gregory E. Fellerman, Esquire Kingston, PA 18704 I.D.#81568 (570) 718-1444 Edward J. Ciarimboli, Esquire (570)714-7255 (FAX) I.D.#85904 www.714HURT.com CASEY JOHNSON, ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PLAINTIFF ) VS. ) CIVIL ACTION - LAW WILLIAM C. SEELY, JR., )'? JURY TRIAL DEMANDED DEFENDANT ) NO. 10-6161 CIVIL TERM F " NOTICE TO DEFEND AND CLAIM RIGHTS - You have been sued in court. If you wish to defend against the claims set forth the following pages, you must take prompt action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing a writing with the Court of your defenses 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 this Complaint 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. MIDPENN LEGAL SERVICES Counties Served: Cumberland 401 East Louther Street Carlisle, PA 17013 (717) 243-9400 (800) 822-5288 Fax: (717) 243-8026 FELLERMA CIARIMBOLI LAW PC BY: GREGO Y E. FELLERMAN, ESQ. Attorney for the Plaintiffs ?i _r --t r1t CID Fri a Fellerman & Ciarimboli Law PC Kirby Park Commons 183 Market Street Kingston, PA 18704 (570) 718-1444 (570)714-7255 (FAX) www.714HURT.com Gregory E. Fellerman, Esquire I . D.#81568 Edward J. Ciarimboli, Esquire I.D.#85904 CASEY JOHNSON, ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PLAINTIFF ) VS. ) CIVIL ACTION - LAW 1 WILLIAM C. SEELY, JR., ) JURY TRIAL DEMANDED DEFENDANT ) NO. 10-6161 CIVIL TERM COMPLAINT AND NOW COMES the Plaintiff, CASEY JOHNSON by and through her legal counsel, FELLERMAN & CIARIMBOLI LAW, PC, and hereby complains against the Defendant, WILLIAM C. SEELY, JR., as follows: PARTIES 1. The Plaintiff, CASEY JOHNSON, hereinafter referred to as JOHNSON, is an adult and competent individual who currently resides at 4616 Hampden Avenue, Camp Hill, Cumberland County, PA 17011. 2. The Defendant, WILLIAM C. SEELY, JR., hereinafter referred to as SEELY, is an adult and competent individual who currently resides at 1616 Cressman Circle, Mechanicsburg, Cumberland County, PA 17055. FACTUAL BACKGROUND 3. On October 30, 2008, at approximately 04:39 p.m., JOHNSON was the owner and operator of a 2006 Honda Civic automobile, bearing PA license plate number GVT6784, hereinafter referred to as the Honda. 2 4. On October 30, 2008, at approximately 04:39 p.m., SEELY was the owner and operator of a 2001 Chevrolet Venture automobile, bearing PA license plate number GRM6247, hereinafter referred to as the Chevrolet. 5. On October 30, 2008, at approximately 04:39 p.m., JOHNSON was operating the Honda in a westerly direction on PA State Route 581 in Lemoyne Borough, Cumberland County, PA. 6. On October 30, 2008 at approximately 04:39 p.m., SEELY was operating the Chevrolet and was traveling behind JOHNSON in the same direction as JOHNSON on PA State Route 581 in Lemoyne Borough, Cumberland County, PA, when while traveling too close behind JOHNSON at a high rate of speed and with no warning, SEELY violently struck and hit the rear of the Honda, owned and operated by JOHNSON, thereby inflicting serious, and severe injuries upon JOHNSON, as are more specifically hereinafter set forth at length. The Honda sustained over $1,800.00 dollars in physical damage as a result of the negligence of SEELY. 7. The accident that is the subject of this lawsuit was caused by the negligence of Defendant, SEELY, in the operation of his vehicle. The police report filed in this matter indicates that SEELY was tailgating, which was the prime factor in the causation of this collision. 8. At all times material hereto, JOHNSON was free from any negligence and did not in any manner assume the risk of injury and/or collision. 3 COUNTI CASEY JOHNSON vs. SEELY NEGLIGENCE 9. CASEY JOHNSON incorporates by reference the allegations contained in Paragraphs 1 through 8 as if fully set forth herein. 10. The negligence and carelessness of SEELY, consisted of the following: A) Careless driving, in violation of Section 3714 of the Pennsylvania Motor Vehicle Code; B) Following too closely behind another vehicle in violation of Section 3310 of the Pennsylvania Motor Vehicle Code; C) Driving at an unsafe speed, in violation of Section 3361 of the Pennsylvania Motor Vehicle Code; D) Failing to bring his vehicle to a stop within the assured clear distance ahead of him and in striking the vehicle in front of him occupied by JOHNSON; E) Failing to keep a proper and adequate lookout for the roadway ahead; F) Failing to observe traffic patterns ahead of him in the same direction on PA State Route 581 in Lemoyne Borough, Cumberland County, Pennsylvania; G) Operating his vehicle in a manner demonstrating a total disregard for the rights and safety of others so as to endanger any person then and there lawfully traveling the said roadway; H) Failing to have his vehicle under proper and adequate control under the circumstances; and, 1) Failing to keep and maintain a proper lookout for other vehicles lawfully using the said roadway. 4 COUNT 11 CASEY JOHNSON VS. SEELY INJURIES 11. CASEY JOHNSON incorporates by reference the allegations contained in Paragraphs 1 through 10 as if fully set forth herein. 12. As a direct and proximate cause of the negligence of the defendants, JOHNSON sustained, inter alia, the following injuries: A) Cervicodorsal sprain/strain with spasm; B) Chronic cervicothoracic myofascial pain; C) Right C6 radiculitis; D) Post traumatic aggravation of cervical spondylosis; E) Lumbosacral sprain/strain with spasm; F) Left shoulder sprain/strain with resultant pain and discomfort and left hand and fingers numbness and tingling; G) Right shoulder sprain/strain with resultant crepitus, pain and discomfort; H) Anxiety and depression; 1) Contusions and abrasions; J) Limitations of activities; and K) Any and all other injuries arising out of complications from the aforementioned injuries and natural consequences thereof. 13. As a result of the aforesaid injuries, and the natural consequences thereof, the Plaintiff, JOHNSON, as of the time of the filing of this Complaint has required treatment from at least the following health care providers: A. Holy Spirit Hospital, Camp Hill, PA, emergency room treatment, October 3, 2008; B. Steven E. Morganstein, D.O., Harrisburg, PA; 5 C. Magnetic Imaging Center, Mechanicsburg, PA; , D. Pinnacle Health Physical Therapy and Spine Center, Mechanicsburg, PA; E. Edwin A. Aquino, M.D., Harrisburg, PA; F. Others. 14. The Plaintiff, JOHNSON, continues to require treatment for the aforesaid injuries and the natural consequences thereof. 15. As a result of the aforesaid serious and painful injuries and natural consequences thereof, JOHNSON has been rendered sick, sore, disabled and has sustained physical and mental pain and suffering all of which have required and/or will require medical care and treatment in the future. 16. As a result of the aforesaid injuries and natural consequences thereof, JOHNSON is suffering physical and mental discomfort, inconvenience, anxiety, and permanent limitations on her ability to do normal everyday activities and will continue to suffer into the future. 17. As a result of the aforesaid injuries and natural consequences thereof, JOHNSON has been forced to receive and undergo medical attention and care, to expend various sums of money for treatment and medication for the aforesaid injuries and will be obligated to continue to expend such sums and incur such expenses for an indefinite period into the future. 18. As a further result of the aforesaid injuries and natural consequences thereof, JOHNSON has endured significant pain and suffering from her injuries which are likely to cause significant pain, soreness, limitation and discomfort into the future. 6 19. As a result of the aforesaid injuries and natural consequences thereof, Plaintiff, JOHNSON has sustained and continues to sustain the loss of everyday pleasures and enjoyments of life, and will continue to so suffer for an indefinite period of time into the future. 20. As a result of the aforesaid injuries, and natural consequences thereof, the Plaintiff has a sustained a significant loss of income and an impairment of her future earning capacity. WHEREFORE, the Plaintiff, CASEY JOHNSON, seeks all damages allowed under the laws of the Commonwealth of Pennsylvania in an amount in excess of $50,000, plus costs of suit, which sum is in excess of the amount requiring compulsory arbitration under the applicable statutes of the Commonwealth of Pennsylvania and Local Rules of Court. Respectfully submitted, FELLERMAN & CIARIMBOLI LAW PC By: -C& GREGOR E. FELLERMAN, ESQ. KIRBY PARK COMMONS 183 MARKET STREET KINGSTON, PA 18704 (570) 718-1444 December 2010 7 7172144650 nextel fax 0 •12:46:41 VERIFICATION 11-19-2008 9/20 !C; ?f? C `? ?L JJ hereby certify that the facts, contained in the foregoing CO' A-A t A1T are true and correct to the best of my kraMedge, information and belef. I make this statement subject to the penalties of 18 4904 r+eWng to unswom falsification to authorities. Fellerman & Ciarimboli Law PC Kirby Park Commons 183 Market Street Kingston, PA 18704 (570) 718-1444 (570)714-7255 (FAX) www.714HURT.com Gregory E. Fellerman, Esquire I.D.#81568 Edward J. Ciarimboli, Esquire I.D.#85904 CASEY JOHNSON, PLAINTIFF VS. WILLIAM C. SEELY, JR., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW t:.`x acv JURY TRIAL DEMANDED rri c. ?--?•? m DEFENDANT ) NO. 10-6161 CIVIL TERM -"a I, GREGORY E CERTIFICATE OF SERVICE ?- FELLERMAN, ESQUIRE, hereby certify and state that I served the following upon defendant, WILLIAM C. SEELY, JR., at 1616 Cressman Circle, Mechanicsburg, PA 17055, via first class mail, postage prepaid, this 29th day of December, 2010: Plaintiff's Complaint; Plaintiff's First Set of Interrogatories Propounded by Plaintiff to Defendant; Plaintiff's Second Set of Interrogatories Propounded by Plaintiff to Defendant; Plaintiff's First Request for Production of Documents addressed to Defendant; Plaintiff's Second Request for Production of Documents addressed to Defendant; Certificate of Service. FELLER G & CW&WBOLI LAW PC RY E. FELLERMAN, ESQ. for Plaintiff DATE: December 29, 2010 Fellerman & Ciarimboli Law PC Kirby Park Commons 183 Market Street Kingston, PA 18704 (570) 718-1444 (570)714-7255 (FAX) www.714HURT.com Gregory E. Fellerman, Esquire I.D.#81568 Edward J. Ciarimboli, Esquire 1. D.#85904 CASEY JOHNSON, ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PLAINTIFF ) 1 VS. ) CIVIL ACTION - LAW WILLIAM C. SEELY, JR., ) JURY TRIAL DEMANDED DEFENDANT ) NO. 10-6161 CIVIL TERM FIRST REQUEST FOR PRODUCTION OF DOCUMENTS ADDRESSED TO DEFENDANT(S) FROM (PLAINTIFF (S) PLEASE TAKE NOTICE that pursuant to Pa.R.C.P. Nos. 4003.4 and 4009.1, please furnish at our expense, at our office, on or before thirty (30) days of service hereof, a copy or like reproduction of the materials concerning this action or its subject matter which are in your possession, custody or control and which are not protected by the attorney/client privilege; or in the alternative, produce the said matter at said time to permit inspection and copying thereof. ^? r.a "S r-n rr, . , _ INSTRUCTIONS ?. °' :Z!: ? If you object to the production of any document on basis of attor gclis"#t -.5 7?7- r r- privilege, attorney work product or on the basis of any other privilege dd?tri6?, c7 7:', statute or rule, please state the following: (a) the nature of the document; (b) the date of the document; (c) the author of the document; T (d) the current location of the document; (e) the individual who has current control over the documeht; and (f) adequate information pertaining to how the document falls within the protection of non-disclosure. DOCUMENTS 1. Any and all documents referred to, relating to or pertaining to any answer to any Interrogatory. 2. Any and all documents containing information relating to any answer to any Interrogatory. 3. Any and all statements concerning this action or its subject matter obtained by you or anyone acting on your behalf. 4. Any and all investigation reports, except those protected from discovery, prepared by you or by anyone on your behalf in regard to the evaluation and litigation of the instant action. 5. Any and all curriculum vitae for each and every person whom you expect to call as an expert witness at trial. 6. Any and all expert reports from each person whom you expect to call as an expert witness at trial. 7. Any and all writings, memoranda, reports, statements and records, etc which you, your company and/or client possess concerning the case, investigation or review of the Plaintiffs and their case. 8. Copies of all statements, memoranda, summaries of other writings, documents, diagrams and pictures obtained from your investigation, your insurance company's investigation or your attorney's investigation into the incident involved. You need not supply any attorney's "work product" or other material that is specifically excepted as privileged by the above rule. 9. All documents in your possession, custody, or control prepared in anticipation of litigation or trial of this case, except those documents which disclose the mental impressions of your attorney or your attorney's conclusions, opinions, memoranda, notes or summaries, legal research, or legal theories, and except those documents prepared in anticipation of litigation by your representatives to the extent that they would disclose the representatives' mental impression, conclusions, or opinions respecting the value or merit of the claim or defense. 10. To the extent that you have not already provided the same in response to previous requests herein, all statements obtained from any witnesses or memoranda of conversations' with witnesses or recordings of witnesses' statements made or obtained during the course of the investigation or matters relating to his lawsuit, and all such statements, memoranda or records made by parties to this lawsuit or their representatives. 11. To the extent not already provided in previous requests herein, all statements made by any party to this action, including written statements, signed or otherwise adopted or approved by the person making it, or stenographic, mechanical, electrical or other recording or transcription thereof, which is a substantially verbatim recital of an oral statement and contemporaneously recorded, as allowed by Pa.R.C.P. 4003.4. 12. To the extent that you have not already provided the same, copies of all records, documents and memoranda which have any bearing upon the matters alleged against the requesting party or upon the responsibility of the requesting party for the matters alleged against the requesting party. 13. To the extent not already provided, copies of all experts' reports made or secured by you in connection with your investigation of the matters relating to this lawsuit. 14. To the extent not already provided, copies of all exhibits that you intend to use at trial and/or to offer into evidence at the trial of this matter. 15. To the extent not already provided, all photographs, motion pictures, diagrams, maps, surveys, plans and models of the site of the incident and of the vehicles in question that are in your possession or in the possession of anyone under your control. 16. Copies of Declaration Sheets for each and every policy insuring you against the claims made in the instant action. 17. Any and all surveillance tapes, films, motion pictures, photographs or other documents conducted, prepared, taken or filmed in the nature of surveillance or as part of a surveillance of any of the parties. 18. Any and all documents which evidence any facts on the basis of which you will assert a defense against the cause of action stated in the Complaint. Respectfully submitted., FELLERMAN BY: GREGORY E. FELLERMAN, ESQUIRE SUPREME COURT I.D. NO. 81568 KIRBY PARK COMMONS 183 MARKET STREET, SUITE 200 KINGSTON, PENNSYLVANIA 18704 (570) 718-1444 Dated: December 15, 2010 Fellerman & Ciarimboli Law PC Kirby Park Commons 183 Market Street Kingston, PA 18704 (570) 718-1444 (570)714-7255 (FAX) www.714HURT.com Gregory E. Fellerman, Esquire I.D.#81568 Edward J. Ciarimboli, Esquire I.D.#85904 CASEY JOHNSON, ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PLAINTIFF ) VS. ) CIVIL ACTION - LAW WILLIAM C. SEELY, JR., ) JURY TRIAL DEMANDED DEFENDANT ) NO. 10-6161 CIVIL TERM SECOND REQUEST FOR PRODUCTION OF DOCUMENTS ADDRESSED TO DEFENDANT(S) BY PLAINTIFF(S) PLEASE TAKE NOTICE that pursuant to Pa.R.C.P. Nos. 4003.4 and 4009.1, please furnish at our expense, at our office, on or before thirty (30) days of service hereof, a copy or like reproduction of the materials concerning this action or its subject matter which are in your possession, custody or control and which are not protected by the attorney/client privilege; or in the alternative, produce the said matter at said time to permit inspection and copying thereof. rat L - Vi = Z = i n? I U ? _ .. s- CD? -1- Instructions If you object to the production of any document on basis of attorney/client privilege, attorney work product or on the basis of any other privilege doctrine, statute or rule, please state the following: (a) the nature of the document; (b) the date of the document; (c) the author of the document; (d) the current location of the document; (e) the individual who has current control over the document; and (f) adequate information pertaining to how the document falls within the protection of non-disclosure. DOCUMENTS 1. Any and all insurance policies, and for each such policy declaration sheets or pages, addenda, riders, amendments, and conditions thereto for insurance which covers or which may cover the liability and/or damages for the subject incident. This request includes but is not limited to all primary coverage, all secondary coverage, all excess coverage, all umbrella coverage, all general liability coverage, and all specific liability coverage. Respectfully submitted, FELLERMAN & CIARIMBOLI LAW PC BY: GR GORY E. FELLERMAN, ESQUIRE SUPREME COURT I.D. NO. 81568 KIRBY PARK COMMONS 183 MARKET STREET, SUITE 200 KINGSTON, PENNSYLVANIA 18704 (570) 718-1444 DATED: December 15, 2010 -2- R ! FILED-OFFICE OF THE PROTHONOTARY 2011 'l'r;! 1- pi's 1. 18 JOHNSON, DUFFIE, STEWART & WEIDNER By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 As@jdsw.com CASEY JOHNSON, V. WILLIAM C. SEELY, JR., Plaintiff Defendant CUnc ',', t"pMjor Defendant pLI. YL.Vr,l!A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-6181 Civil Term 6IN CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned on behalf of the Defendant in the above-captioned matter. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER Date: January 2011 427012 vl? e fferson J. Shipman, Esquire ttorney I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Counsel for Defendant A .L CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe for Entry of Appearance has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on January (1, 2011: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law; P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 JOHNSON, DUFFIE, STEWART & WEIDNER 4 Y ),4 Z?4?- 44,44 Ze-&( Je s n . Shipman r , JOHNSON, DUFFIE, STEWART & WEIDNER By: Jefferson J. Shipman I . D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jjs@jdsw.com CASEY JOHNSON, V. WILLIAM C. SEELY, JR., Plaintiff Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Casey Johnson c/o Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 AND NOW, this (Li day of January, 2011, you are hereby notified to plead responsively within twenty (20) days of the date of service hereof, or judgment may be entered against you. w OF THE RO HONO TA RY .Iii v f,'J 1011 J ` 11 ` l; 24 CUI?iBci?? C?C neys for Defendant r; . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-6161 CIVIL TERM JOHNSON, DUFFIE, STEWART & WEIDNER J son J. Sh man eAttorneys s for Defendant 427072 f , JOHNSON, DUFFIE, STEWART & WEIDNER By: Jefferson J. Shipman I . D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jjs@jdsw.com CASEY JOHNSON, Plaintiff V. WILLIAM C. SEELY, JR., Defendant Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-6161 Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT WILLIAM C. SEELY. JR. AND NOW, comes the Defendant, William C. Seely, Jr., by and through his counsel, Jefferson J. Shipman, Esquire and Johnson, Duffie, Stewart & Weidner, and files the following Answer and New Matter to Plaintiffs Complaint: 1. Admitted upon information and belief. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted in part, denied in part. It is admitted, only, that on said date Mr. Seely was operating a vehicle on Route 581, when he made contact with the rear of the Plaintiffs vehicle. The remaining averments of paragraph 6 are conclusions of law and I I fact to which no response is required averments contained therein are denied. If a response is deemed to be required, the 7. Denied. The averments contained in paragraph 7 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averment contained therein are specifically denied. 8. Denied. The averments contained in paragraph 8 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averment contained therein are specifically denied. COUNTI CASEY JOHNSON v. SEELY 9. Mr. Seely incorporates herein by reference his answers to paragraphs 1 through 8 above, as though fully set forth herein at length. 10. Denied. The averments contained in paragraph 10 and each and every subparagraph A through I are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. A. Denied. It is specifically denied that Mr. Seely was driving carelessly in violation of 3714 of the Pennsylvania Motor Vehicle Code; B. Denied. It is specifically denied that Mr. Seely was following too closely in violation of Section 3310 of the Pennsylvania Motor Vehicle Code; C. Denied. It is specifically denied that Mr. Seely was driving at an unsafe speed in violation of Section 3361 of the Motor Vehicle Code; D. Denied. It is specifically denied that Mr. Seely was negligent in allegedly failing to bring his vehicle to a stop within the assured clear distance ahead; E. Denied. It is specifically denied that Mr. Seely failed to keep a proper and adequate lookout for the roadway ahead; F. Denied. It is specifically denied that Mr. Seely was negligent in allegedly failing to observe traffic patterns ahead of him; G. Denied. It is specifically denied that Mr. Seely operated his vehicle in a manner demonstrating a total disregard for the rights and safety of others; H. Denied. It is specifically denied that Mr. Seely failed to have his vehicle under proper and adequate control; and 1. Denied. It is specifically denied that Mr. Seely failed to keep and maintain a proper lookout for other vehicles. COUNT II CASEY JOHNSON v. SEELY 11. Mr. Seely incorporates herein by reference his answers to paragraphs 1 through 10 above, as though fully set forth herein at length. 12. Denied. The averments contained in paragraph 12 are, in part, conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. After reasonable investigation, Mr. Seely is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of paragraph 12 and the same are therefore denied and strict proof is demanded at the time of trial. 13. Denied. After reasonable investigation, Mr. Seely is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of paragraph 13 and the same are therefore denied and strict proof is demanded at the time of trial. 14. Denied. After reasonable investigation, Mr. Seely is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of paragraph 14 and the same are therefore denied and strict proof is demanded at the time of trial. 15. Denied. After reasonable investigation, Mr. Seely is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of paragraph 15 and the same are therefore denied and strict proof is demanded at the time of trial. 16. Denied. After reasonable investigation, Mr. Seely is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of paragraph 16 and the same are therefore denied and strict proof is demanded at the time of trial. 17. Denied. After reasonable investigation, Mr. Seely is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of paragraph 17 and the same are therefore denied and strict proof is demanded at the time of trial. 18. Denied. After reasonable investigation, Mr. Seely is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of paragraph 18 and the same are therefore denied and strict proof is demanded at the time of trial. 19. Denied. After reasonable investigation, Mr. Seely is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of paragraph 19 and the same are therefore denied and strict proof is demanded at the time of trial. 20. Denied. After reasonable investigation, Mr. Seely is without sufficient knowledge or information to form a belief as to the truth of the remaining averments of paragraph 20 and the same are therefore denied and strict proof is demanded at the time of trial. WHEREFORE, the Defendant, William C. Seely, Jr., respectfully requests that judgment be entered in his favor and that Plaintiffs Complaint be dismissed with prejudice. NEW MATTER 21. That Plaintiffs alleged cause of action may be barred in whole or in part by the applicable statute of limitations. 22. That the Plaintiffs alleged cause of action may be barred in whole or in part by the Pennsylvania Motor Vehicle Financial Responsibility Law and the limited tort option. 23. That if it should be found that there is any negligence on the part of Mr. Seely, which is denied, then in that, event, any such negligence was not a factual cause of any harm or the harm alleged in the Plaintiffs Complaint. 24. That the Plaintiffs alleged injuries may have been pre-existing. 25. That the Plaintiff may have failed to mitigate her alleged injuries. 26. That the Plaintiffs sole cause of action may have been caused by third parties or entities not presently involved in this action. 27. That the Plaintiffs alleged cause of action may have been caused by a dangerous condition of the highway. 28. That the Plaintiffs alleged cause of action may have been caused by a sudden emergency. WHEREFORE, the Defendant, William C. Seely, Jr., respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER B Jeffdrson J. Shipman, Esquire Attorney I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 -- Telephone (717) 761-4540 Date: January 2011 Counsel for Defendant 427037 VERIFICATION The undersigned verifies that the facts set forth in the foregoing document are true and correct to the best of his knowledge, information and belief. This Verification is made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsifications to authorities. / William C. Seely, Jr. Date: 427070 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Answer and New Matter of Defendant has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on January 2011: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 JOHNSON, DUFFIE, STEWART & WEIDNER qJerson J. Shipman -OFFICE i ,Y a -I PROTHONOTAR`t 2011 FEB 28 APB 11: 18 Fellerman & Ciarimboli Law PC CUMBERLAND COUNTY Kirby Park Commons PENNSYLVANIA 183 Market Street, Suite 200 Gregory E. Fellerman, Esquire Kingston, PA 18704 I.13181568 (570) 718-1444 Edward J. Ciarimboli, Esquire Fax (570)714-7255 I.D. #85904 www.714HURT.com CASEYJOHNSON, PLAINTIFF VS. WILLIAM C. SEELY, JR., DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW JURY TRIAL DEMANDED NO. 10-6161 CIVIL TERM PLAINTIFF'S ANSWER TO DEFENDANT'S NEW MATTER The Plaintiff, Casey Johnson, by and through her counsel, FELLERMAN AND CIARIMBOLI LAW PC, files the within Plaintiff's Answer To Defendant's New Matter and in support thereof sets forth the following: 21. DENIED. Pursuant to Pa. R.C.P. 1029(d) no responsive pleading is required as the averment is a conclusion of law. To the extent a responsive pleading is required, this averment is DENIED and strict proof is demanded at the time of trial. 22. DENIED. Pursuant to Pa. R.C.P. 1029(d) no responsive pleading is required as the averment is a conclusion of law. To the extent a responsive pleading is required, this averment is DENIED and strict proof is demanded at the time of trial. 23. DENIED. Pursuant to Pa. R.C.P. 1029(d) no responsive pleading is required as the averment is a conclusion of law. To the extent a responsive pleading is required, this averment is DENIED and strict proof is demanded at the time of trial. 24. DENIED. Pursuant to Pa. R.C.P. 1029(d) no responsive pleading is required as the averment is a conclusion of law. To the extent a responsive pleading is required, this averment is DENIED and strict proof is demanded at the time of trial. 25. DENIED. Pursuant to Pa. R.C.P. 1029(d) no responsive pleading is required as the averment is a conclusion of law. To the extent a responsive pleading is required, this averment is DENIED and strict proof is demanded at the time of trial. 26. DENIED. Pursuant to Pa. R.C.P. 1029(d) no responsive pleading is required as the averment is a conclusion of law. To the extent a responsive pleading is required, this averment is DENIED and strict proof is demanded at the time of trial. 27. DENIED. Pursuant to Pa. R.C.P. 1029(d) no responsive pleading is required as the averment is a conclusion of law. To the extent a responsive pleading is required, this averment is DENIED and strict proof is demanded at the time of trial. 28. DENIED. Pursuant to Pa. R.C.P. 1029(d) no responsive pleading is required as the averment is a conclusion of law. To the extent a responsive pleading is required, this averment is DENIED and strict proof is demanded at the time of trial. WHEREFORE, Plaintiff, Casey Johnson, demands that Defendant's New Matter be dismissed and judgment entered in favor of the Plaintiff along with costs and any other legal remedy deemed appropriate by this Court. Respectfully submitted: FELLERMAN & CIARIMBOLI LAW PC BY: E ORY E. FELLERMAN, ESQ. A orney for KPlaintiffs Dated: February 14, 2011 Fellerman & Ciarimboli Law PC Kirby Park Commons 183 Market Street Kingston, PA 18704 (570) 718-1444 (570)714-7255 (FAX) www.714HURT.com Gregory E. Fellerman, Esquire I.D.#81568 Edward J. Ciarimboli, Esquire I.D.#85904 CASEY JOHNSON, ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PLAINTIFF ) ) VS. ) CIVIL ACTION - LAW WILLIAM C. SEELY, JR., ) JURY TRIAL DEMANDED DEFENDANT ) NO. 10-6161 CIVIL TERM CERTIFICATE OF SERVICE I, GREGORY E. FELLERMAN, ESQUIRE, hereby certify and state that I served the following upon defendant, WILLIAM C. SEELY, JR., at 1616 Cressman Circle, Mechanicsburg, PA 17055, via first class mail, postage prepaid, this 14'h day of February, 2011: Plaintiff's Answer to Defendant's New Matter; Certificate of Service. FELLERMAN & CIARIMBOLI LAW PC By G GO Y E. FELLERMAN, ESQ. Aft rney for Plaintiff DATE: February 14, 2011 JOHNSON, DUFFIE, STEWART & WEIDNER By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 76141540 jjs@jdsw.com CASEY JOHNSON, V. WILLIAM C. SEELY, JR., F I?{II-{{f.: TAR ? 1 APR -6 Ail 10: 314- Attorneys for Defendant CUMBERLAQ COUNT)' 'HNNSYLYA IA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 10-6161 CIVIL TERM CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 TO: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas attached thereto, was mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoenas were sought to be served; (2) A copy of the Notice of Intent including the proposed subpoenas, is attached to this Certificate; (3) No objection to the subpoenas has been received; and (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. JOHNSON DUFFIE, STEWART & WEIDNER By: T J rson J. Shipman, squire A or ney I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: April , 2011 Counsel for Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been duly served upon the following counsel of record, by depositing the same in the United States Mail, certified, postage prepaid, in Lemoyne, Pennsylvania, on April 5- , 2011: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 JOHNSON, DUFFIE, STEWART & WEIDNER By: t p ?"'? ?r J erson J. Shipman, Esquire SHNSON, DUFFIE, STEWART & WEIDNER By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 hs@jdsw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 10-6161 CIVIL TERM CASEY JOHNSON, V. WILLIAM C. SEELY, JR., Attorneys for Defendant : CIVIL ACTION - LAW Defendant : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 PLEASE TAKE NOTICE that Defendant intends to serve four (4) subpoenas identical to the ones attached to this notice. You have twenty (20) days from the date listed below in which to file of records and serve upon the undersigned objections to the subpoenas. If no objections are made, the subpoenas may be served. Date: March/1,1_, 2011 JOHNS,,O , DUFFIE, STEWART & WEIDNER By: r? fferson J. Shipman, Esquire Attorney I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Counsel for Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been duly served upon the following counsel of record, by depositing the same in the United States Mail, certified, postage prepaid, in Lemoyne, Pennsylvania, on March ?, 2011: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 JOHNSON, DUFFIE,_STEWART & WEIDNER By: Je rson J. Shipman COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Casey Johnson, Plaintiff vs. William C. Seely, Jr., Defendant File No. 10-6161 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Holy Spirit Hospital (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports, diagnostic test results, office notes, correspondence from 1/1/03 through the present regarding Casey Johnson Vogelsong DOB: 5/8/80 SSN: 178-68-4500 at Johnson, Duffie. Stewart & Weidner. 301 Market Street P.O. Box 109, Lemoyne PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Jefferson J. Shipman. Esquire ADDRESS: 301 Market Street Lemoyne. PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendants BY THE COURT: ry%CI rk, Civil Division DATE: 3-]'S1.1 Seal of the Court Deputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Casey Johnson, Plaintiff vs. William C. Seely, Jr., Defendant File No. 10-6161 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Magnetic Imaging Center (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports, diagnostic test results including actual films or diskette of MRI of cervical spine dated 3/17109 regarding Casey Johnson Vogelsong DOB: 518180 SSN: 178-68-4500 at Johnson. Duffie. Stewart & Weidner, 301 Market Street. P.O. Box 109, Lemoyne PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: Jefferson J. Shipman. Esouire 301 Market Street Lemovne. PA 17043 717-761-4540 51785 Defendants BY THE COURT: Proth /Clerk, C iI Division DATE: Seal of the Court Deputy (Eff.7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Casey Johnson, Plaintiff vs. William C. Seely, Jr., Defendant File No. 10-6161 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PinnacleHealth Neuroscience Rehab Center (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports, diagnostic test results, office notes, correspondence, physical therapy records regarding Casey Johnson Vogelsong DOB: 5/8/80 SSN: 178-68-4500 at Johnson. Duffle. Stewart & Weidner. 301 Market Street. P.O. Box 109. Lemoyne PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: Jefferson J. Shipman. Esquire 301 Market Street Lemoyne. PA 17043 717-761-4540 51785 Defendants BY THE Civi/ Division DATE: 9, IS-1i Seal of the Court Deputy (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Casey Johnson, Plaintiff vs. William C. Seely, Jr., Defendant File No. 10-6161 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Morcianstein DeFalsis Rehabilitation Institute (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports, diagnostic test results, office notes, correspondence, physical therapy records regarding Casey Johnson Vogelsong DOB: 5/8/80 SSN• 178-68-4500 at Johnson. Duffle. Stewart & Weidner, 301 Market Street P.O. Box 109, Lemoyne PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: ADDRESS: TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: DATE: 9`. J. S. .7', 1 - Seal of the Court Jefferson J. Shipman. Esquire 301 Market Street Lemoyne. PA 17043 717-761-4540 51785 Defendants Deputy (Eff. 7/97) Fellerman & Ciarimboli Law PC Kirby Park Commons 183 Market Street, Suite 200 Gregory E. Fellerman, Esquire Kingston, PA 18704 I.D.#81568 (570) 718-1444 Edward J. Ciarimboli, Esquire Fax (570)714-7255 I.D. #85904 www.714HURT.com CASEY JOHNSON, PLAINTIFF VS. WILLIAM C. SEELY, JR., DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY., c) N rnm 2 U rn CIVIL ACTION - LAW 2 = -a -<> OQ JURY TRIAL DEMANDED Co CD z° C-? Z:C> 311 Mc CD-n acs NO. 10`-6'1`61 CIVIL TER CERTIFICATE OF SERVICE I, GREGORY E. FELLERMAN, ESQUIRE, hereby certify and state that I served the following upon defense counsel, JEFFERSON J. SHIPMAN, ESQUIRE, of LAW OFFICES OF JOHNSON, DUFFIE, STEWART & WEIDNER, at 301 Market Street, P.O. Box 109, Lemoyne, PA, 17043-0109 via first class mail, postage prepaid, this 6th day of April, 2011: Plaintiff's Answers to Interrogatories Addressed to Plaintiff; Plaintiff's Responses to Request for Production of Documents Addressed to Plaintiff; Certificate of Service. April 6, 2011 FEWOR ARIMBOLI LAW By: GR7FELLERMAN, ESQ. Attorney For Plaintiff -1?0 ; I'0' OVA` fA'f JOHNSON, DUFFIE, STEWART & WEIDNER By: Jefferson J. Shipman I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jjs@jdsw.com CASEY JOHNSON, V. WILLIAM C. SEELY, JR., Plaintiff Defendant IiiZ` 23 A. Ii "?'l L 'D COUNTY i ? i i ' iV I ?' S "(LVA' NIA Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-6161 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 TO: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoena attached thereto, was mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoenas were sought to be served; (2) A copy of the Notice of Intent including the proposed subpoena, is attached to this Certificate; (3) No objection to the subpoena has been received; the twenty day waiting period for objections was waived by Plaintiffs counsel; and (4) The subpoena to be served is identical to the subpoena attached to the Notice Of Intent. JOHNSON, UFFIE, =STEWARTDNER By: Jeff on J. Shipman, Esquire Atto ey I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: March, 2012 Counsel for Defendant JOHNSON, DUFFIE, STEWART & WEIDNER By: Jefferson J. Shipman I. D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jjs@jdsw.com CASEY JOHNSON, Plaintiffs V. Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-6161 CIVIL TERM WILLIAM SEELY, JR., Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Casey Johnson C/O Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 PLEASE TAKE NOTICE that Defendant intends to serve one (1) subpoena identical to the one attached to this notice. You have twenty (20) days from the date listed below in which to file of records and serve upon the undersigned objections to the subpoena. If no objections are made, the subpoena may be served. JOHNSON UFFIE, STEWART & WEIDNER By: Je rson J. Shipman, Esquire Attorney I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: March , 2012 Counsel for Defendant :485661 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Casey Johnson, Plaintiff vs. William C. Seely, Jr., Defendant File No. 10-6161 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dr. Michael L. Brooks, M.D., J.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records, reports, diagnostic test results, office notes, & correspondence regarding Casey Johnson Vogelsong DOB: 5/08/80 SSN: 178-68-4500 at Johnson. Duffie, Stewart & Weidner. 301 Market Street, P.O. Box 109, Lemoyne PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Jefferson J. Shipman, Esquire ADDRESS: 301 Market Street Lemoyne. PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID #: 51785 ATTORNEY FOR: Defendant BY THE COURT: ary/Clerk, Civil/Division i 1 DATE: 3 Seal f the 'ourt Deputy (Eff. 7/97) CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been duly served upon the following counsel of record, by depositing the same in the United States Mail, certified, first class postage prepaid, in Lemoyne, Pennsylvania, on March ? , 2012: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 JOHNSON, DUFFIE, STEWART & WEIDNER By: Jeffer n J. Shipman 485661 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing document has been duly served upon the following counsel of record, by depositing the same in the United States Mail, certified, postage prepaid, in Lemoyne, Pennsylvania, on March ?, 2012: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 JOHNSON, DUFFIE, STEWART & WEIDNER By: Jeffer n J. Shipman, Esquire Fellerman & Ciarimboli ?-akl? C'. Kirby Park Coa"ons'- 183 Market Stree ?' Gregory E. Fellerman, Esquire Kingston, PA 18 I.D.#81568 (570) 718-1444 t J,` (? s r Edward J. Ciarimboli, Esquire Fax (570)714-7255 1,S i L , I.D. #85904 www.714HU---&W CASEY JOHNSON, PLAINTIFF VS. WILLIAM C. SEELY, JR., DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW JURY TRIAL DEMANDED NO. 10-6161 CIVIL TERM CERTIFICATE OF SERVICE rya _ I, GREGORY E. FELLERMAN, ESQUIRE, hereby certify and state that I served the following upon defendant, WILLIAM C. SEELY, JR., through his counsel, JEFFERSON J. SHIPMAN, ESQ., of JOHNSON DUFFIE law offices, at 301 Market Street, P.O. Box 109, Lemoyne, PA 17043-0109, via first class mail, postage prepaid, this 15th day of May, 2012: Plaintiff's Answers to Defendant's Supplemental Interrogatories; Certificate of Service. FELLERMAN-&,CIARIMBOLI LAW PC GRqGOI Y E. FELLERMAN, ESQ. Atto nev for Plaintiff DATE: May 15, 2012 a JOHNSON, DUFFIE, STEWART & WEIDNER By: Matthew Ridley, Esquire I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 MR@jdsw.com V. CASEY JOHNSON, WILLIAM C. SEELY, JR., Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 10-60&il Term Defendant E _ v _ v CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO SUBSTITUTE APPEARANCE TO THE PROTHONOTARY: Please substitute the appearance of Matthew Ridley of Johnson, Duffie, Stewart & Weidner as counsel on behalf of the Defendant in the above-captioned matter. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: It /1 , Matthew Ridley, Esquire Attorney I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: October 16, 2012 Counsel for Defendant 521033 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe to Substitute Appearance has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on October -IL, 2012: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 JOHNSON, DUFFIE, STEWART & WEIDNER By: Mich le E. Neff, Legal Se , ary to Matthew Ridley, Esquire rILED-OFF10E FHE PPOTH014?tAr� 2013 APR 25 PN 2: 49 CUMBERLAND COUNTY PENNSYLVANIA JOHNSON, DUFFIE, STEWART&WEIDNER Attorneys for Defendant By: Matthew Ridley I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 mr @jdsw.com CASEY JOHNSON, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 10-6161 CIVIL TERM V. CIVIL ACTION — LAW WILLIAM C. SEELY, JR., Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things'pursuant to Rule 4009.22, Defendant hereby 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 20 days prior to the date on which the subpoena was sought to be served; 2) A copy of the Notice of Intent, including the proposed subpoena, is attached to this certificate; 3) The 20-day waiting period has passed, and no objection to the subpoena was received; and 4) The subpoena to be served is identical to the subpoena attached to the Notice of Intent. By: Matthew Ridley, Esquire Attorney I.D. No. 204265 301 Market Street Lemoyne, PA 17043-0109 Telephone (717) 761-4540 DATE: 4/24/13 Counsel for Defendant 553116 JOHNSON, DUFFIE, STEWART&WEIDNER Attorneys for Defendant By: Matthew Ridley I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 mr @jdsw.com CASEY JOHNSON, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 10-6161 CIVIL TERM V. CIVIL ACTION — LAW WILLIAM C. SEELY, JR., Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Casey Johnson C/O Gregory E. Fellerman, Esquire - Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 PLEASE TAKE NOTICE that Defendant, William C. Seely, intends to serve one (1) subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned objections to the subpoena. If no objections are made, the subpoena may be served. JOHNSON, DUFFIE, STEWART & WEIDNER By: /U 4 Matthew Ridley, Esquire Attorney I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Counsel for Defendant Date: March 8, 2013 544841 22740-2723 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CASEY JOHNSON Plaintiff File No.File No.10-6161 Civil Term VS. WILLIAM C.SEELY,JR. Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Erie Insurance Group ATTN: First Party Benefits,P.O.Box 2,013,Mechanicsburg,PA 17055 (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all documents including entire first-party benefits file,application for benefits,PIP payout summary,all memoranda,reports,statements,medical records,phone messages,adjuster notes, expert reports,tort election form,policy information and any other documentation pertaining to Casey M.Johnson a/k/a Casey Vogelsong;DOB: 5/8/1980;SS#:xxx-xx-4500;Claim No.: 010171002806. at Johnson, Duffle,-Stewart& Weidner, 301 Market.Street, Lemoyne, PA..17d43 (Address) You may deliver or mail legible copies of the documents.-Pr produce things requested by this subpoena, together with the certificate of compliance,to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to-produce the documents or things required by this subpoena within twenty(20) days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Matthew Ridley,Esquire ADDRESS: 301 Market Street P.O.Box 109 Lemoyne,PA 17043 - TELEPHONE: (717)761-4540 SUPREME COURT ID 4 204265 ATTORNEY FOR: Defendant BY THE COURT: Prothonotary,Civil Division,, Zee Date., ���� J _. - - .- . Seal ofthe Court Deputy' CERTIFICATE OF SERVICE hereby certify that a copy of the foregoing Notice of Intent has been duly served upon the following counsel of record, by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on March 8, 2013: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 JOHNSON, DUFFIE, STEWART & WEIDNER By: Lindsey P. Rftdhey Litigation Paralegal CERTIFICATE OF SERVICE HEREBY CERTIFY that I served a true and correct copy of the foregoing Certificate Prerequisite of Subpoenas upon all parties or counsel of record by depositing a copy of same in the United States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on the 24th day of April, 2013, addressed to the following: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 JOHNSON, DUFFIE, STEWART &WEIDNER Lindsey Pa itchey r I�._CJ` C3 r K �,, 0i: T i E PR00TH0N0 TAR� CUMBERLAND COUNTY PENNSYLVANIA JOHNSON, DUFFIE, STEWART&WEIDNER Attorneys for Defendant By:. Matthew Ridley I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 mr @jdsw.com CASEY JOHNSON, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 10-6161 CIVIL TERM V. CIVIL ACTION — LAW WILLIAM C. SEELY, JR., Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: 1) A Notice of Intent to sere the subpoena, with a copy of the subpoena attached thereto, was mailed or delivered to each party at least 20 days prior to the date on which the subpoena was sought to be served; 2) A copy of the Notice of Intent, including the proposed subpoena, is attached to this certificate; 3) Plaintiff's counsel has waived the 20-day waiting period, and said waiver is attached; and 4) The subpoena to be served is identical to the subpoena attached to the Notice of Intent. 6 By. I'dla thew Ridley, Esquire Attorney I.D. No. 204265 301 Market Street Lemoyne, PA 17043-0109 Telephone (717) 761-4540 DATE: May 21, 2013 Counsel for Defendant 557482 JOHNSON, DUFFIE, STEWART&WEIDNER Attorneys for Defendant By: Matthew Ridley I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 mr @jdsw.com CASEY JOHNSON, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 10-6161 CIVIL TERM V. CIVIL ACTION — LAW WILLIAM C. SEELY, JR., Defendant JURY TRIAL DEMANDED WAIVER OF 20-DAY SUBPOENA OBJECTION PERIOD I, Gregory Fellerman, Esquire, agree to waive the 20-day objection period for the notice of intent to subpoena records from: (1) United Healthcare Dater 110115 By: G . Fellerman, Esquire JOHNSON, DUFFIE, STEWART&WEIDNER Attorneys for Defendant By: Matthew Ridley I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 mr @jdsw.com CASEY JOHNSON, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 10-6161 CIVIL TERM V. CIVIL ACTION — LAW WILLIAM C. SEELY, JR., Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Casey Johnson C/O Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 PLEASE TAKE NOTICE that Defendant, William C. Seely, intends to serve one (1) subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file on record and serve upon the undersigned objections to the subpoena. If no objections are made, the subpoena may be served. JOHNSON, DUFFIE, STEWART &WEIDNER By: , Matthew Ridley, Esquire Attorney I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Counsel for Defendant Date: May 7, 2013 555815 22740-2723 J COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CASEY JOHNSON Plaintiff File No.File No.10-6161 Civil Term vs. WILLIAM C. SEELY,JR. Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: United Healthcare (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all documents including but not limited to medical records, bills submitted and/or paid, memoranda,reports, statements, policy information, adjuster notes, and any other documentation pertaining to Casey M. Johnson a/k/a Casey Vogelsong;DOB: 5/8/1980; SS#: xxx-xx-4500; Group No. 712603;ID No. 845090822. at Johnson,:Duffie, Stewart& Weidner, 301 Market Street, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance,to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty(20)days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Matthew Ridley,Esquire ADDRESS: 301 Market Street P.O.Box 109 Lemoyne,PA 17043 TELEPHONE: (717)761-4540 SUPREME COURT ID#204265 ATTORNEY FOR: Defendant BY THE COURT: —7r—o—th'Zno—tar ,Civil ivision Date; 410146 Seal e the Court Deputy CERTIFICATE OF SERVICE hereby certify that a copy of the foregoing Notice of Intent has been duly served upon the following counsel of record, by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on May 7, 2013: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 JOHNSON, DUFFIE, STEWART &WEIDNER By: `,.. Lindsey P. Ritchey Litigation Paralegal CERTIFICATE OF SERVICE HEREBY CERTIFY that I served a true and correct copy of the foregoing Certificate Prerequisite of Subpoenas upon all parties or counsel of record by depositing a copy of same in the United States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on the 21st day of May, 2013, addressed to the following: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183,Market Street Kingston, PA 18704 JOHNSON, DUFFIE, STEWART &WEIDNER By: ` Lindsey P. chey, Paralegal t is r, EE e r, ‘ID cc,31, Q a i } l ri NtAl to JOHNSON, DUFFIE, STEWART&WEIDNER Attorneys for Defendant By: Matthew Ridley I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 mr @jdsw.com CASEY JOHNSON, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 10-6161 CIVIL TERM v. : CIVIL ACTION — LAW WILLIAM C. SEELY, JR., Defendant : JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant hereby 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 20 days prior to the date on which the subpoena was sought to be served; 2) A copy of the Notice of Intent, including the proposed subpoena, is attached to this certificate; 3) Plaintiffs counsel has waived the 20-day waiting period, and said waiver is attached; and 4) The subpoena to be served is identical to the subpoena attached to the Notice of Intent. By: Matthew Ridley, Esquire Attorney I.D. No. 204265 301 Market Street Lemoyne, PA 17043-0109 Telephone (717) 761-4540 DATE: July 26, 2013 Counsel for Defendant 571388 Page 1 of 1 Lindsey P. Ritchey From: Amy M. Lukeski [alukeski @fclawpc.com] Sent: Friday, July 26, 2013 10:28 AM To: Lindsey P. Ritchey Cc: Greg Fellerman; Cheryl Mizenko Subject: Regarding: Johnson, Casey v. Seely, William.JR-MVA D/L: 10/30/2008 Dear Lindsey: Per our discussion a few moments ago, please allow this e-mail correspondence to confirm that we are willing to waive the 20-day objection period for your Subpoenas. Thank you. Awvy M. Lukkv, Ca4e/Mc viager Fellerman & Ciarimboli Law, PC 183 Market Street, Suite 200 Kingston, PA 18704 570-718-1444 570-714-7255 (fax) alukeski @fclawpc.com www.fclawpc.com This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you received this email in error please notify the system manager.This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. 'Pl, II FELLERMAN , , L iii „.;‘ , ; ,,-:,,;,I,NieT7 ! k' A Thft IN 11,µ _ I 7/26/2013 JOHNSON, DUFFIE, STEWART&WEIDNER Attorneys for Defendant By: Matthew Ridley I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 m r @jdsw.corn CASEY JOHNSON, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 10-6161 CIVIL TERM v. : CIVIL ACTION — LAW WILLIAM C. SEELY, JR., Defendant : JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Casey Johnson C/O Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 PLEASE TAKE NOTICE that Defendant, William C. Seely, intends to serve one (1) subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file on record and serve upon the undersigned objections to the subpoena. If no objections are made, the subpoena may be served. JOHNSON, DUFFIE, STEWART &WEIDNER By: Matthew Ridley, Esquire Attorney I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: July 25, 2013 Counsel for Defendant 570108 22740-2723 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CASEY JOHNSON • Plaintiff , File No.File No.10-6161 Civil Term VS. WILLIAM C. SEELY,JR. Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Sprint Nextel (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all employment records,W-2 statements, 1099 statements, other payroll records, performance evaluations,performance reviews,sicknesses or illnesses,disciplinary actions, correspondence,attendance records,handwritten notes,medical reports,workers' compensation records,or other records in your possession(from 10/30/2003 to present)pertaining to Casey M. Johnson a/k/a Casey Vogelsong;DOB: 5/8/1980;SSN:xxx-xx-4500 at Johnson, Duffle, Stewart & Weidner, 301 Market Street, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Matthew Ridley,Esquire ADDRESS: 301 Market Street P.O.Box 109 Lemoyne,PA 17043 TELEPHONE: (717)761-4540 SUPREME COURT ID#204265 ATTORNEY FOR: Defendant BY THE da•T: Pr? ' ivil Divi on Date: Seal f the ourt Deputy CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Notice of Intent has been duly served upon the following counsel of record, by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on July 25, 2013: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 JOHNSON, DUFFIE, STEWART &WEIDNER By:y: indsey P. • ey Litigation Paralegal CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing Certificate Prerequisite of Subpoenas upon all parties or counsel of record by depositing a copy of same in the United States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on the 26th day of July, 2013, addressed to the following: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 JOHNSON, DUFFIE, STEWART & WEIDNER By: dmay. st che Paralegal Y Y, 9 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 In the Matter of: CASEY JOHNSON Cumberland County 14- 01726MG 4-k rn Court of Common Please v cry ra _ J wa -VS - WILLIAM C. SEELY, JR. No. 10 -6161 � Ccz) .F, t� As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 CCLR on behalf of MATTHEW RIDLEY, ESQUIRE Defendant certifies that (1) A notice of intent to serve the subpoena(s) with a copy of the subpoena(s) attached thereto was /were mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is /are sought to be served. (2) A copy of the notice of intent, including the proposed subpoena(s), is attached to the certificate. (3) No objection to the subpoena(s) has been received. (4) The subpoena(s) which will be served is /are identical to the subpoena(s) which is /are attached to the notice of intent to serve the subpoena(s). DATE: 3/31/2014 phi „) MATTHEW RIDLEY, ESQUIRE Counsel for Defendant CCL1 Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732 -1177 fax (215)732 -5637 Online Services www.cclrinc.com CASEY JOHNSON VS. WILLIAM C. SEELY, JR. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 10 -6161 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS GREGORY E. FELLERMAN, ESQUIRE FELLERMAN & CIARIMBOLI LAW 183 MARKET STREET SUITE 200 KINGSTON, PA 18704 Please take notice there has been a request by MATTHEW RIDLEY, ESQUIRE, counsel for the Defendant in the above case for production and copying of records in the possession of (see enclosures). These records pertain to CASEY JOHNSON - VOGELSONG. Enclosed is(are) a copy (copies) of the subpoena(s) to be served on the custodian of such records and also a Counsel Return Page for you to fill out and return to us stating whether you would like to order a copy of the records and whether you have any objections to the production and copying of such records or manner thereof. The fee per location is enclosed on the Counsel Return Page. The subpoena will be sent to the records custodian twenty (20) days from the date of this notice requesting that the records be produced on or before ten (10) days thereafter unless we hear from you to the contrary on the Counsel Return Page. If you state an objection on the Counsel Return Page, we will proceed accordingly. If you require assistance, please contact our office. DATE: March 10, 2014 Enclosures : Copy (copies) of Subpoena(s) Counsel Return Page CCLR . • Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732 -1177 fax (215)732 -5637 Online Services www.cclrinc.com CASEY JOHNSON vs. WILLIAM C. SEELY, JR. CCLR File NO. 14- 01726MG COUNSEL RETURN PAGE I have received the Notice of Records Reproduction Request dated 3/10/2014 regarding records in the custody of (see attached subpoena(s)) and respond as follow: (1) COPIES yes / no I would like a copy of the records in question sent to me, and agree to pay the price noted in the Notice of Records Reproduction Request. (2) I would like copies of X -Rays sent to me. (3) OBJECTION In accordance to rules governing civil procedure a copy of date /time stamped filing needs to be sent to Center City Legal Reproductions prior to 3/31/2014. Failure to do so shall serve as an agreement that the records reproduction service should proceed with the records collection process. (4) I would like to look at the records at a Center City location before deciding whether to order a copy. 2014 Copy Fees /Per Location Administrative Fee $17.00 Pages 1 -20 $.95 Pages 21 -60 $.65 Pages 61 & Above $.20 Date: yes / no yes / no Attorney for plaintiff(s) / defendant(s) GREGORY E. FELLERMAN, ESQUIRE FELLERMAN & CIARIMBOLI LAW 183 MARKET STREET SUITE 200 KINGSTON, PA 18704 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CASEY JOHNSON VS. WILLIAM C. SEELY, JR. Plaintiff . : File No. 1 0— 61 61 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: WESLEY L. VOGELSONG— RECORDS DEPARTMENT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ** *SEE ATTACHED ADDENDUM * ** at CENTER CITY LEGAL REPRODUCTIONS, INC. • (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS:ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME:MATTHEW RIDLEY, ESQUIRE ADDRESS: TELEPHONE: SUPREME COURT ID # ATTORNEY FOR DEFENDANT Date:�_,4��� /� Seal of the'Court Deputy BY THE COURT• Prot a. vi Divisiin ■ f s.s. Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732 -1177 fax (215)732 -5637 CCLR File No. 14- 01726MG * * * * * * * * * * * * * * * * * * * * * * * * ** ADDENDUM TO SUBPOENA * * * * * * * * * * * * * * * * * * * * * * * * ** To: WESLEY L. VOGELSONG - RECORDS DEPT Re: CASEY JOHNSON - VOGELSONG THE GUEST LIST -FROM YOUR WEDDING TO -CASEY JOHNSON; THE NAMES AND ADDRESSES OF ANY PHOTOGRAPHERS OR VIDEOGRAPHERS PRESENT AT THE WEDDING; AND COPIES. OF ANYAND ALL PHOTOGRAPHS AND VIDEOS PERTAINING TO ANY ASPECT -OF YOUR WEDDING TO CASEY JOHNSON, INCLUDING BUT NOT LIMITED TO THE WEDDING, THE RECEPTION, ANY AFTER WEDDING PARTY, AND ANY AND ALL HONEYMOON 'PHOTOGRAPHS AND /OR VIDEOS. **CERTIFICATION PAGE MUST BE SIGNED AND DATED** -(DOB: 05/08/1980) -7 JOHNSON, DUFFIE, STEWART&WEIDNER Attorneys for Defendant r,},d By: Matthew Ridley ,L I.D. No. 204265 ,'S 301 Market Street P. 0. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 mr @jdsw.com CASEY JOHNSON, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 10-6161 Civil Term • WILLIAM C. SEELY, JR., • CIVIL ACTION — LAW Defendant : JURY TRIAL DEMANDED UNCONTESTED MOTION TO ENFORCE SUBPOENA And now comes the Defendant, William C. Seely, Jr., by and through its counsel, Johnson, Duffie, Stewart & Weidner, P.C., who files this Uncontested Motion to Enforce Subpoena, and hereby avers as follows: 1. This matter stems from a two-vehicle accident that occurred on October 30, 2008 Route 581 in Lemoyne, Pennsylvania, when the front of the Defendant's vehicle came into contact with the rear of the Plaintiff's. 2. On January 6, 2011, the Plaintiff filed a civil Complaint, sounding in negligence, and alleging physical injuries and damages, including lost wages. 3. As the Plaintiff is alleging lost wages due to her alleged injuries, the Defendant requires the Plaintiff's records from Sprint/Nextel, which was her employer at the time of the accident. 1 4. On May 29, 2013, defense counsel faxed an authorization signed by the Plaintiff and requested a copy of her employment records. (See letter of May 29, 2013 and authorization, attached as Exhibit A). 5. Sprint/Nextel did not produce the requested records. 6. In a certified letter of July 26, 2013, defense counsel mailed a subpoena to Sprint/Nextel, received by the company on August 12, 2013, which requested the following documents within 20 days: Copies of all employment records, W-2 statements, 1099 statements, other payroll records, performance evaluations, performance reviews, sicknesses or illnesses, disciplinary actions, correspondence, attendance records, handwritten notes, medical reports, workers' compensation records, or other records in your possession (from 10/30/2003 to present) pertaining to [the Plaintiff]. (See letter of July 26, 2013, signed receipt, and subpoena, attached as Exhibit B). 7. In a certified letter of October 2, 2013, received by the company on October 3, 2013, defense counsel again mailed the subpoena to Sprint/Nextel, and requested the Plaintiffs employment records. (See letter of October 2, 2013, signed receipt, and subpoena, attached as Exhibit C). 8. In letters of October 28 and November 13, 2013, defense counsel advised Sprint/Nextel that if it did not provide the Plaintiffs employment records, he would seek court intervention. (See letters of October 28 and November 13, 2013, attached as Exhibit D). 2 9. Pursuant to Pa.R.C.P. 4009.23, Sprint/Nextel was required to provide the requested documents within 20 days of service of the subpoena. 10. As of the date of this filing, Sprint/Nextel has failed to comply with the subpoena. 11. The Defendant therefore respectfully requests this Court issue an order compelling Sprint/Nextel to comply with the Defendant's subpoena, and produce the Plaintiffs employment file within 20 days of the Court's order. 12. No judge has ruled upon an issue in this matter. 13. Plaintiffs counsel concurs with the relief sought in this Motion. Wherefore, the Defendant, William C. Seely, Jr., respectfully requests this Honorable Court grant his Uncontested Motion to Enforce Subpoena and issue an order requiring Sprint/Nextel to produce the Plaintiffs employment file within 20 days of the order or be subject to such sanctions that the court may impose, including, but not limited to, the imposition of attorneys' fees incurred in pursuing the requested records. Respectfully submitted, JOHNSON, DUFFIE, STEWART &WEIDNER By: ( : -) Matthew Ridley, Esquire Attorney I.D. No. 204265 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: May h , 2014 Counsel for Defendant 603954 3 EXHIBIT A JERRY R.DUFFIE ELIZABETH D.SNOVER RICHARD W.STEWART CAROLYN B.MCCLAIN EDMUND G.MYERS L A W O F F I C E S JOHN A.LUCY DAVID W.DELUGE UYSES N JOHRSON ULIA APS MATTHEW RIDLEY MARK C.DUFFIE BARRIE B.GEHRLEIN JOHN R.NINOSKY DUFFIE MICHAEL J.CASSIDY OF COUNSEL MELISSA P GREEVY HORACE A.JOHNSON WADE D.MANLEY C. ROY WEIDNER,Bt. CONSTANCE P.BRUNT \YirPPER$EYT.No.10) 1s,IVIA1 t,l.pnEjt.l .cm May 29, 2013 VIA FACSIMILE (866-299-7725) Sprint Nextel Attn: Employee Records 6391 Sprint Parkway Overland Park, KS 66251 Re: Casey Johnson v. William C. Seely, Jr. Cumberland County Court of Common Pleas; No. 10-6161 Civil Term Date of Birth: 5/8/1980 S.S.#: xxx-xx-4500 • Dear Sir/Madam: Enclosed please find an authorization for the release of employment records pertaining to Casey Johnson a/k/a Casey Vogelsong, the Plaintiff in the above-captioned case. Our office represents the Defendant, William C. Seely, Jr., in this matter. Please copy and send all records contained in your file as outlined in the language of the . authorization. If you have any questions, please contact me. Very truly yours, JOHNSON, DUFFIE, STEWART &WEIDNER Lindsey P. Ritchey Litigation Paralegal 560284 22740-2723 Enclosure cc: Gregory E. Fellerman, Esquire (w/enclosure) Susan Philson, AIC, AIS (w/o enclosure, via e-mail) (Claim No.: 010171002790) 301 MARKET STREET P.O.BOX 109 LEMOYNE,PENNSYLVANIA 17043-0109 WWW,JDSW,COM 717.761.4540 FAX: 717.761.3015 MAIL @JDSW.COM JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. AU ORIZATION •R RELEA E OF INFORM I hereby authorize the use or disclosure of the information as described below I understand ttii � authorization is voluntary. Name. Casey M.Johnson a/k/a Casey Voaelsonq DOB 8/8/1980 SSN xxx-xx-Oi Q Organization Providing the Information Sprint Nextel Organization(s) or Person(s) Receiving the Information , Matthew Ridley, EsiicLUir'nx Jahnsvn btii•ffie Stewart&Weidner 301 Market St. P.O. Box 109 Lemo e PA 17043 Specific Description of Information Disclosed Co•les of :II e •to mont records W=2 ate Moils 1099 statements other •a roll records •erformance valuations •erformanc rstyjnyylk., sicknesses or illnesses disci•liner actions co es•onden o attendance records handwritten notes medical re•orts workers' corn•ensation recor•s or other records in our •ossess !pn pertaining to Casey M.Johnson a/k/a Casey Voneisono. Purpose of Disclosure Litigation Dates of Records 10/30/2003 to present YOU MUST READ AND INITIAL THE FOLLOWING STATEMENTS 1 I understand this Authorization will expire on 4/11/2014 or on the resolution of this Otis a ion. Irntkals '` A 2 I understand that I may revoke this Authorization at any time by notifying Sprint Nextet in writing, but if I do, it will not have any effect on any actions Sprint Nextel took before receiving the revocation. unigo Initial :. (4 ; 11: Casey Joh 7 on a/ - Casey elsong Data 550788 22740-2723 EXHIBIT B • JERRY R.DUFFIE ELIZABETH D.SNOVER RICHARD W.STEWART CAROLYN B.MCCLAIN EDMUND G.MYERS LAW O F F I C E S JOHN A.LUCY DAVID W.DELUGE ULYSSES S.WILSON JOHN A.STATLER JOHNSON MATTHEW RIDLEY MARK C.DUFFIE DUFFIE BARRIE B. GEHRLEIN JOHN R.NINOSKY MICHAEL J.CASSIDY OF COUNSEL MELISSA P.GREEVY HORACE A.JOHNSON WADE D.MANLEY C.ROY WEIDNER,JR. CONSTANCE P.BRUNT 9171 9690 0935 0039 8917 75 kvy;.; ,T„r:YT.NO. 611 E-MAIL%i. ;:c:jd'aw,com, July 26, 2013 VIA FACSIMILE (913-523-0393) VIA CERTIFIED MAIL Sprint Nextel Sprint Nextel Attn: Sharon Bundy, Legal Department 4000 Crums Mill Road 6391 Sprint Parkway Suite 101/102 Overland Park, KS 66251• Harrisburg, PA 17112 Re: Casey Johnson v.William C.Seely,Jr. Cumberland County Court of Common Pleas; No. 10-6161 Civil Term Date of Birth: 5/8/1980 S.S.#: xxx-xx-4500 Dear Sir/Madam: Enclosed please find a subpoena for employment records pertaining to Casey Johnson a/k/a Casey Vogelsong, the Plaintiff in the above-captioned action. Our office represents the Defendant, William C. Seely, Jr., in this matter. Also enclosed is a copy of the Notice of Intent that was sent to the attorney representing Ms. Johnson, and a copy of the Certificate Prerequisite filed with the court confirming that there is no objection to the service of this subpoena for the records. Please copy and send all records contained in your file as outlined in the language of the subpoena. Also, please execute and return the Certificate of Compliance which is also enclosed. If you have any questions, please contact me. Very truly yours, JOHN ON, DUFFIE, STEWART&WEIDNER Li d ey P.Rit ey Litigation Paralegal : 571397 22740-2723 Enclosure cc: Gregory E. Fellerman, Esquire(w/enclosure) Susan Philson, AIC, AIS (w/o enclosure, via e-mail) (Claim No.: 010171002790) 301 MARKET STREET P.O.BOX 109 LEMOYNE,PENNSYLVANIA 17043-0109 WWW.JDSW.COM 717.761.4540 FAX: 717.761.3015 MAIL@JDSW.COM JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. JOHNSON,DUFFLE,STEWART&WEIDNER Attorneys for Defendant By:Matthew Ridley I.D.No.204265 301 Market Street P.O.Box 109 Lemoyne,PA 17043-0109 (717)761-4540 mr @jdsw.com CASEY JOHNSON, : IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff . NO. 10-6161 CIVIL TERM v. CIVIL ACTION—LAW WILLIAM C.SEELY,JR., Defendant JURY TRIAL DEMANDED NOTICE TO: SPRINT NEXTEL You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.22 I certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the subpoena issued on July 23. 2013 have been produced. Date: By: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CASEY JOHNSON • Plaintiff File No.File No.10-6161 Civil Term VS. WILLIAM C. SEELY,JR. •• Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Sprint Nextel (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all employment records,W-2 statements, 1099 statements,other payroll records, performance evaluations,performance reviews,sicknesses or illnesses,disciplinary actions, correspondence,attendance records,handwritten notes,medical reports,workers' compensation records,or other records in your possession(from 10/30/2003 to present)pertaining to Casey M. Johnson a/k/a Casey Vogelsong;DOB: 5/8/1980; SSN:xxx-xx-4500 at Johnson, Duffie, Stewart& Weidner, 301 Market Street, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty(20)days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Matthew Ridley,Esquire ADDRESS: 301 Market Street P.O.Box 109 Lemoyne,PA 17043 TELEPHONE: (717)761-4540 SUPREME COURT ID#204265 ATTORNEY FOR: Defendant BY THE _ •T: --ENHOMMILft. /�4 Pr�� 'ivil Divi on Date: _l S_ Seal f the ourt Deputy UNITED STATES POSTAL SERVICE Date: January 31, 2014 Ipritchey RITCHEY: The following is in response to your January 31, 2014 request for delivery information on your Certified Mail item number 9171969009350039891775. The delivery record shows that this item was delivered on August 12, 2013 at 9:15 am in LEMOYNE, PA 17043. The scanned image of the recipient information is provided below. Signature of Recipient : Nun K._. r , • Address of Recipient : Pori bias 1t d ' e (70 r 6o,c / 7 Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service EXHIBIT C JERRY R.DUFFIE BARRIE B.GEHRLEIN RICHARD W. STEWART ANTHONY T.LUCIDO EDMUND G.MYERS L A W O F F I C E S CAROLYN B.MCCLAIN DAVID W.DELUCE l __� Tc ON JOHN A.LUCY JOHN A.STATLER JOHNS\1 JULYSSES S.WILSON JEFFREY B.RETTIG 1111 ��II JULIA A.MORRISON MARK C.DUFFIE DUFFIE RIDLEY JOHN R.NINOSKY MICHAEL J.CASSIDY OF COUNSEL MELISSA P.GREEVY HORACE A.JOHNSON WADED.MANLEY C.ROY WEIDNER.JR. October 2, 2013 VIA CERTIFIED MAIL Sprint Nextel C/O Corporation Service Company 9171 9690 0935 0039 8791 31 2595 Interstate Drive, Suite 103 Harrisburg, PA 17110 Re: Casey Johnson v.William C.Seely_,Jr. Cumberland County Court of Common Pleas; No. 10-6161 Civil Term Date of Birth: 5/8/1980 S.S.#: xxx-xx-4500 Dear Sir/Madam: Enclosed please find a subpoena for employment records pertaining to Casey Johnson a/k/a Casey Vogelsong, the Plaintiff in the above-captioned action. Our office represents the Defendant, William C. Seely, Jr., in this matter. Also enclosed is a copy of the Notice of Intent that was sent to the attorney representing Ms. Johnson, and a copy of the Certificate Prerequisite filed with the court confirming that there is no objection to the service of this subpoena for the records. Per instructions from Sprint's Legal Department, we served this subpoena on Sprint Nextel via facsimile on July 26, 2013, but we have not received a response. Therefore, we are now serving the subpoena by mail. Please copy and send all records contained in your file as outlined in the language of the subpoena. If the reproduction charges are in excess of $150.00, please contact our office for prior approval. Also, please execute and return the Certificate of Compliance which is also enclosed. If you have any questions, please contact me. Very truly yours, JOHNSON, DUFFIE, STEWART&WEIDNER V✓Lf,k4-(r 4-2-1/ indsey P. Rifhey Litigation Paralegal 583728 22740-2723 . Enclosure cc: Gregory E. Fellerman, Esquire (w/enclosure) 301 MARKET STREET P.O.BOX 109 LEMOYNE,PENNSYLVANIA 17043-0109 WWWJDSW.COM 717.761.4540 FAX:717.761.3015 MAIL @JDSWCOM JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. JOHNSON,DUFFIE,STEWART&WEIDNER Attorneys for Defendant By: Matthew Ridley I.D.No.204265 301 Market Street P.O.Box 109 Lemoyne,PA 17043-0109 (717)761-4540 mr @jdsw.com CASEY JOHNSON, : IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 10-6161 CIVIL TERM v. . CIVIL ACTION—LAW WILLIAM C. SEELY,JR., Defendant JURY TRIAL DEMANDED NOTICE TO: SPRINT NEXTEL You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.22 I certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the subpoena issued on July 23, 2013 have been produced. Date: By: UNITED STATES POSTAL SERVICE, Date: October 17, 2013 Lindsey Ritchey: The following is in response to your October 17, 2013 request for delivery information on your Certified MaiITM item number 9171969009350039879131. The delivery record shows that this item was delivered on October 3, 2013 at 12:29 pm in HARRISBURG, PA 17110. The scanned image of the recipient information is provided below. Signature of Recipient • $1 «; A Address of Recipient • }}} �r. , ,�,,,,.,, i Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service EXHIBIT D • JERRY R.DUFFIE BARRIE B.GEHRLEIN RICHARD W.STEWART ANTHONY T.LUCIDO EDMUND G.MYERS LAW 0 F F ICE S CAROLYN B.MCCLAIN DAVID W.DELUCE JOHN A.LUCY JOHN A.STATLER JOHNSON ULYSSES S.WILSON JEFFREY B.RETTIG JULIA A.MORRISON MARK C.DUFFIE DUFFIE MATTHEW RIDLEY JOHN R.NINOSKY MICHAEL J.CASSIDY OF COUNSEL MELISSA P.GREEVY HORACE A.JOHNSON WADE D.MANLEY C.ROY WEIDNER,JR. WlllTER'S ENT.NO.]16 E-RLUL•mr•,&jjdsw.com October 28, 2013 Sprint Nextel CIO Corporation Service Company 2595 Interstate Drive, Suite 103 Harrisburg, PA 17110 Re: Casey Johnson v. William C. Seely, Jr. Cumberland County Court of Common Pleas; No. 10-6161 Civil Term Employee: Casey Johnson a/k/a Casey Vogelsong Date of Birth: 5/8/1980; SSN: xxx-xx-4500 Dear Sir/Madam: On October 2, 2013, a certified letter was served upon you enclosing a subpoena for employment records pertaining to Casey Johnson a/k/a Casey Vogelsong. Pursuant to the subpoena, records were to be supplied to my office within 20 days of the date of service of the subpoena. As of this writing, the records have not been provided to my office. I am enclosing a copy of the original letter and attachments. Please forward a copy of all records contained in your file as outlined in the language of the subpoena within 14 days from the date of this letter so that I may avoid seeking court intervention. Please notify me immediately should you need additional time to comply with the subpoena. Thank you. Very truly yours, JOHNSON, DUFFIE, STEWART &WEIDNER 4. 71 Matt Ridley • MR/Ipr: 588204 22740-2723 Enclosures cc: Sprint Nextel Corporation, Legal Department (w/enc.) Gregory E. Fellerman, Esquire (w/o enc.) 301 MARKET STREET P.O.BOX 109 LEMOYNE,PENNSYLVANIA 17043-0109 WWW.JDSW.COM 717.761.4540 FAX: 717.761.3015 MAIL@JDSW.COM JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. JERRY R.DUFFIE BARRIE B.GEHRLEIN RICHARD W. STEWART ANTHONY T.LUCIDO EDMUND G.MYERS LAW OFFICES CAROLYN B.MCCLAIN DAVID W.DELUCE JOHN A.LUCY A.STATLER JEFFREY B.RETTIG JOHNS\SONT JULIA A.MORRISON JEFFREY C.DUFFIE DUFFIE MATTHEW RIDLEY JOHN R.NINOSKY MICHAEL J.CASSIDY OF COUNSEL MELISSA P.GREEVY HORACE A.JOHNSON WADED.MANLEY C.ROY WEIDNER,JR. I 16 E 1\LVi.mr ejdlsv,.ci}m November 13, 2013 VIA MAIL AND FACSIMILE: (913) 523-0393; (913) 523-0563 Sprint Nextel C/O Corporation Service Company 2595 Interstate Drive, Suite 103 Harrisburg, PA 17110 Re: Casey Johnson v. William C. Seely, Jr. Cumberland County Court of Common Pleas; No. 10-6161 Civil Term Employee: Casey Johnson a/k/a Casey Vogelsong Date of Birth: 5/8/1980; SSN: xxx-xx-4500 Dear Sir/Madam: On October 2, 2013, a certified letter was served upon you enclosing a subpoena for employment records pertaining to Casey Johnson a/k/a Casey Vogelsong. Pursuant to the subpoena, records were to be supplied to my office within 20 days of the date of service. On October 28, 2013, I mailed your office copies of the original letter and enclosures and requested that records be supplied within 14 days. As of this writing, the records have not been provided to my office. Please forward a copy of all records contained in your file as outlined in the language of the subpoena immediately, or I will seek a court order to enforce the subpoena. Please notify me immediately should you need additional time to comply with the subpoena. Thank you. Very truly yours, JOHNSON, DUFFIE, STEWART &WEIDNER ( n ' • Matt Ridley M R/l pr: 591475 22740-2723 cc: Sprint Nextel Corporation, Legal Department Gregory E. Fellerman, Esquire 301 MARKET STREET P.O.BOX 109 LEMOYNE,PENNSYLVANIA 17043-0109 WWW.JDSW.COM 717.761.4540 FAX:717.761.3015 MAIL @JDSW.COM JOHNSON, DUFFIE, STEWART & WEIDNER, P.C. 11/13/2013 13:15 FAX U001 *************************** *** ACTIVITY REPORT *** *************************** ST. TIME DESTINATION TEL/ID NO. MODE PGS. RESULT *11/11 10:25 918145396789 2796 TRANSMIT 0 NG 00'36 0 #0018 *11/11 10:34 918145395934 2797 TRANSMIT 0 NG 00'00 0 #0018 *11/11 10:45 8577 AUTO R% G3 1 OK 00'45 *11/11 11:50 717+761+6860 8578 AUTO R% G3 5 OK 02'47 *11/11 12:33 8579 AUTO RI G3 1 OK 00'45 *11/11 12:52 8580 AUTO RX G3 5 OK 03'06 *11/11 13:18 7172335830 8581 AUTO RI G3 6 OK 03'21 *11/11 13:22 918145395934 2798 TRANSMIT 0 NG 00'00 0 #0018 *11/11 14:34 8582 AUTO RI G3 2 OK 01'08 *11/11 15:16 610 667 3440 8583 AUTO RI G3 2 OK 01'12 *11/11 15:50 8584 AUTO RI G3 11 OK 09'44 *11/11 16:24 8585 AUTO RI G3 7 OK 07'11 *11/11 16:38 610 435 8164 8586 AUTO RI G3 2 OK 01'58 *11/11 16:59 916104025823 2799 TRANSMIT G3 12 OK 08'06 *11/11 19:03 9167891513 8587 AUTO R% G3 39 OK 21'06 *11/12 07:22 8588 AUTO R% G3 3 OK 02'43 *11/12 09:28 8589 AUTO R% G3 1 OK 00'57 *11/12 10:20 7172335830 8590 AUTO RI G3 4 OK 02'10 *11/12 10:44 610 402 1690 8591 AUTO R% G3 1 OK 00'44 *11/12 10:50 570 288 3048 8592 AUTO RI G3 2 OK 02'17 *11/12 13:53 918453331560 2800 TRANSMIT G3 6 OK 04'00 *11/12 14:40 8593 AUTO R% G3 2 NG 01'54 2 *11/12 14:51 8594 AUTO RI G3 9 NG 11'25 9 *11/12 15:07 8595 AUTO RI G3 5 NG 04'49 5 *11/12 15:18 8596 AUTO R% G3 20 OK 10'37 *11/12 15:46 7172343611 8597 AUTO RI G3 4 OK 02'18 *11/12 15:57 8598 AUTO R% G3 4 OK 02'16 *11/12 16:14 916108989011 2801 SEQ. B'CAST G3 2 OK 01'28 *11/12 16:16 912155616913 2801 SEQ. B'CAST G3 2 OK 01'59 *11/12 16:19 912152741735 2801 SEQ. B'CAST G3 2 OK 01'29 *11/12 16:21 912153626722 2801 SEQ. B'CAST G3 2 OK 01'17 *11/12 16:23 916108256555 2801 SEQ. B'CAST G3 2 OK 01'28 *11/13 09:14 918145395934 2802 TRANSMIT 0 NG 00'00 0 #0018 *11/13 09:16 17172093277 8599 AUTO R% G3 3 OK 01'37 *11/13 09:24 8600 AUTO R% G3 2 OK 01'10 *11/13 09:50 7177371389 8601 AUTO RX G3 1 OK 00'45 *11/13 10:39 95310212 2803 TRANSMIT G3 4 OK 02'41 11/13 10:55 , 8692_AUTO RI G3 2 OK 02'01 11/13 11:14 919135230393 2804 TRANSMIT G3 1 OK 00'54 1 y 11/13 11:15 919135230563 2805 TRANSMIT G3 1 OK 00'44 J'/C CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Uncontested Motion to Enforce Subpoena has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on May , 2014: Gregory E. Fellerman, Esquire Fellerman & Ciarimboli Law, P.C. Kirby Park Commons 183 Market Street Kingston, PA 18704 JOHNSON, DUFFIE, STEWART & WEIDNER By: Matthew Ridley CASEY JOHNSON, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. WILLIAM C. SEELY, JR., Plaintiff Defendant ORDER AND NOW, this 9 day of M A`( NO. 10-6161 Civil Term CIVIL ACTION — LAW JURY TRIAL DEMANDED , 2014 upon consideration of Defendant's Uncontested Motion to Enforce Subpoena, it is hereby ORDERED that Sprint/Nextel shall produce to Defendant William C. Seely, Jr., the Plaintiff's `entire Sprint/Nextel employment file within 20 days, or face such sanctions as this Court may impose, including, but not limited to, the imposition of attorneys' fees incurred by the Defendant in pursuing the requested records. BY THE COURT: ,71 Distribution: res /Gregory E. Fellerman, Esquire, Fellerman & Ciarimboli Law, P.C., Kirby Park Commons, 183 Market Street, Kingston, PA 18704 /Matthew Ridley, Esquire, Johnson, Duffie, Stewart & Weidner, 301 Market Street, P.O. Box 109, Lemoyne, PA 17043-0109 4 14-05434LG/R CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 In the Matter of: Court of Common Pleas CASEY JOHNSON Cumberland County - VS - WILLIAM C. SEELY, JR. No. 10-6161 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 CCLR on behalf of MATTHEW RIDLEY, ESQUIRE Defendant certifies that (1) A notice of intent to serve the subpoena(s) with a copy of the subpoena(s) attached thereto was/were mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is/are sought to be served. (2) A copy of the notice of intent, including the proposed subpoena(s), is attached to the certificate. (3) No objection to the subpoena(s) has been received. (4) The subpoena(s) which will be served is/are identical to the subpoena(s) which is/are attached to the notice of intent to serve the subpoena(s). v3 co r cp C) c DATE: 7/8/2014 MAT Counsel for Defendant Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com CASEY JOHNSON VS. WILLIAM C. SEELY, JR. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 10-6161 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS GREGORY E. FELLERMAN, ESQUIRE FELLERMAN & CIARIMBOLI LAW 183 MARKET STREET SUITE 200 KINGSTON, PA 18704 Please take notice there has been a request by MATTHEW RIDLEY, ESQUIRE, counsel for the Defendant in the above case for production and copying of records in the possession of (see enclosures). These records pertain to CASEY JOHNSON, A/K/A VOGELSONG. Enclosed is(are) a copy (copies) of the subpoena(s) to be served on the custodian of such records and also a Counsel Return Page for you to fill out and return to us stating whether you would like to order a copy of the records and whether you have any objections to the production and copying of such records or manner thereof. The fee per location is enclosed on the Counsel Return Page. The subpoena will be sent to the records custodian twenty (20) days from the date of this notice requesting that the records be produced on or before ten (10) days thereafter unless we hear from you to the contrary on the Counsel Return Page. If you state an objection on the Counsel Return Page, we will proceed accordingly. If you require assistance, please contact our office. DATE: July 8, 2014 Enclosures : Copy (copies) of Subpoena(s) Counsel Return Page ccLR• • • • Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 Online Services www.cclrinc.com CASEY JOHNSON vs. WILLIAM C. SEELY, JR. CCLR File NO. 14-05434LG/R COUNSEL RETURN PAGE have received the Notice of Records Reproduction Request dated 7/8/2014 regarding. records in the custody of (see attached subpoena(s)) and respond as follow: (1) COPIES I would like a copy of the records in question sent to me, and agree to pay the price noted in the Notice of Records Reproduction Request. (2) I would like copies of X -Rays sent to me. (3) OBJECTION In accordance to rules governing civil procedure a copy of date/time stamped filing needs to be sent to Center City Legal Reproductions prior to 7/8/2014. Failure to do so shall serve as an agreement that the records reproduction service should proceed with the records collection process. (4) I would like to look at the records at a Center City location before deciding whether to order a copy. 2014 Copy Fees/Per Location Administrative Fee $17.00 Pages 1-20 $.95 Pages 21-60 $.65 Pages 61 & Above $.20 Date: yes / no yes / no yes / no Attorney for plaintiff(s) / defendant(s) GREGORY E. FELLERMAN, ESQUIRE FELLERMAN & CIARIMBOLI LAW 183 MARKET STREET SUITE 200 KINGSTON, PA 18704 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CASEY JOHNSON Plaintiff . : File No. 10-6 1 6 1 VS. • WILLIAM C. SEELY, JR Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: WEST SHORE EMS -CARLISLE -RECORDS DEPARTMENT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ***SEE ATTACHED ADDENDUM*** at CENTER CITY LEGAL REPRODUCTIONS , INC. (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MATTHEW RIDLEY, ESQUIRE ADDRESS: CCLR, Int 1315 Walnut Street, Ste. 601 1'IiilacicIpItia, 1'.•1 19107 213-732-1177 TELEPHONE: SUPREME COURT ID # ATTORNEY FOR: DEFENDANT Date:�r__ Q� S; al of the Court Deputy BY T UR Illirr onotary, Civil t'ivision CCLR . • .. Center City Legal Reproductions, Inc. 1315 Walnut Street, Suite 601, Philadelphia, PA 19107 (215)732-1177 fax (215)732-5637 CCLR File No. 14-05434LG/R ************************** ADDENDUM TO SUBPOENA ************************** To: WEST SHORE EMS -CARLISLE - RECORDS DEPT Re: CASEY JOHNSON, A/K/A VOGELSONG ANY AND ALL RECORDS FROM 10/30/1998 -PRESENT, INCLUDING BUT NOT LIMITED TO REPORTS, OFFICE NOTES, CORRESPONDENCE, BILLING RECORDS, HOSPITAL RECORDS, PROGRESS REPORTS, DOCTORS NOTES, CHARTS, SUMMARIES, TEST RESULTS, LAB TESTS, EVALUATIONS, ETC., PERTAINING TO CASEY M. JOHNSON, A/K/A CASEY VOGELSONG. ** CERTIFICATION PAGE MUST BE SIGNED AND DATED **