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Home My WebLink About04-3779 !I I ANGlNO & ROVNER, P.c. David L. Lutz, Esquire Attorney ID#: 35956 4503 North Front Street Harrisburg, PA 17110-1708 (717) 238.6791 FAX (717) 238-5610 Attorneys for Plaintiff(s) E.mail: dlutz@angino~rovner>com BEVERLY McPHERSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. CIVIL ACTION - LAW NO. (jt.{- i1lq ~ JURY TRIAL DEMANDED JOAN DUNCAN ADAMS, Defendant NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER. ORIGINAL 275350.11DLLIMTG II IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street, Carlisle, PA 17013 TELEPHONE 717-249-3166 A VISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se persentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dfas despues de la notificacion de esta Demanda y A visa radicando personalmente 0 por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a , las demandas presentadas aqui en contra suya. Se Ie advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda 0 cualquier otra reclamacion 0 remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Used puede perder dinero 0 propiedad u olros derechos importantes para used. USTED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. Cumberland County Bar Association 32 South Bedford Street, Carlisle, P A 17103 TELEFONO 717-249-3166 275350. 1 \DLLIMTG BEVERLY McPHERSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. CIVIL ACTION - LAW JOAN DUNCAN ADAMS, Defendant NO. '0 t.t - J 1'1 1 JURY TRIAL DEMANDED COMPLAINT I. Plaintiff Beverly McPherson, citizen of the Commonwealth of Pennsylvania, resides in Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant Joan Duncan Adams is an adult individual, citizen of the Commonwealth of Pennsylvania, who resides at 339 West North Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The facts and occurrences hereinafter related took place on or about October 21, 2002, at approximately 4:30 p.m. at the Gettysburg exit of State Route 581 in Camp Hill, Cumberland County, Pennsylvania. 4. At that time and place, Plaintiff Beverly McPherson was operating her motor vehicle, a 2001 Saturn, exiting State Route 581 at the Gettysburg exit, preparing to enter onto State Route 15 South. 5. At the same time, Defendant Joan Duncan Adams was operating a 2002 Nissan behind Ms. McPherson's vehicle. 6. Defendant Joan Duncan Adams permitted the front of her vehicle to collide with the rear of Ms. McPherson's vehicle. 7. The foregoing accident and all of the irUuries and damages set forth hereinafter sustained by Plaintiff Beverly McPherson are the direct and proximate result of the negligent, 275350.1IDLLIMTG careless, wanton, and reckless manner in which Defendant Joan Duncan Adams operated her motor vehicle as follows: a) failure to have her vehicle under such control as to be able to stop within the assured clear distance ahead; b) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; c) failure to apply her brakes in sufficient time to avoid striking the rear of Ms. McPherson's vehicle; and d) driving her vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 8. Plaintiff Beverly McPherson sustained painful and severe injuries, which include but are not limited to right thoracic pain, myofascial pain, right shoulder tendonitis with rotator cuff impingement, right shoulder capsulitis, and disc herniation at T7-8. 9. By reason of the aforesaid injuries sustained by Plaintiff Beverly McPherson, she was forced to incur liability for medical treatment, medications, chiropractic therapy, and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefor. 10. Because of the nature of her injuries, Plaintiff Beverly McPherson has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefor. 11. As a result of the aforementioned injuries, Plaintiff Beverly McPherson has undergone and in the future may undergo physical and mental suffering, inconvenience in 275350.lIDLLIMTG 2 carrying out her daily activities, loss of life's pleasure and enjoyment, and claim is made therefor. 12. As a result of the aforesaid injuries, Plaintiff Beverly McPherson has been and in the future may be subject to humiliation and embarrassment, and claim is made therefor. 13. As a result of the aforementioned iI1iuries, Plaintiff Beverly McPherson has sustained work loss, loss of opportunity, and a permanent diminution of her earning power and capacity, and claim is made therefor. 14. Plaintiff Beverly McPherson continues to be plagued by persistent pain and limitation and, therefor, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefor. WHEREFORE, Plaintiff Beverly McPherson demands judgment against Defendant Joan Duncan Adams in an amount in excess of Twenty-five Thousand Dollars ($25,000.00), exclusive of interest and costs and in excess of any jurisdiction amount requiring compulsory arbitration. 1 1--\ t"-\ Date: .- . ) \/ 'I ANGINa & ROVNER, P.C. ~L.u J.D. No. 35956 4503 N. Front Street Harrisburg, P A 17110 (717) 238-6791 Attorney for Plaintiff 275350.1IDLLIMTG 3 VERIFICATION I, Beverly McPherson, Plaintiff, have read the foregoing COMPLAINT and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. WITNESS: ~6" q~ Dated: .5 ~7 - (jIf. ;~rs~~ 275350.IIDLLIMTG ~~ ~ q ~ '-.J" ~. c.() U'\ ~ , CX\ r-->' \..;'-' LJ--. CJ . \ c/'. (" - ~J ~ cY UI \.S. (J '-^ ('. . (0 ,..., ':..1 C -II --~ .L,'.. r-o {"'\ L,.'; SHERIFF'S RETURN - REGULAR CASE NO: 2004-03779 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCPHERSON BEVERLY VS ADAMS JOAN DUNCAN SGT. BARRY HORN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ADAMS JOAN DUNCAN the DEFENDANT , at 1542:00 HOURS, on the 5th day of August 2004 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to JOAN ADAMS a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 .00 .00 10.00 .00 28.00 .~>A?~~ R. Thomas Kline Sworn and Subscribed to before 08/06/2004 ANGINO & ROVNE~ By: me this /..u.-- day of xl,JM..f,,~~ ..4JOtf A. D . Ck~teno~' ~ Deput~ Sheriff ~ . Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire 1.0. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com (717) 761-4550 Attorney for Defendant BEVERLY McPHERSON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 04-3779 CIVIL v. JOAN DUNCAN ADAMS, Defendant : JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Plaintiff and her counsel, YOU ARE HEREBY notified to plead to the within New Matter of Defendant within twenty (20) days. JOHNSON, DUFFIE, STEWART & WEIDNER Jeff son J. S pman, Esquire 1.0.#:51785 P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Defendant Telephone: 717-761-4540 ~~I~:1 4/;,/1 {)4 Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com (717) 761-4550 Attorney for Defendant JOAN DUNCAN ADAMS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-3779 CIVIL JURY TRIAL DEMANDED BEVERLY McPHERSON, Plaintiff v. DEFENDANT'S ANSWER AND NEW MATTER TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Joan Duncan Adams, by and through her counsel, Jefferson J. Shipman, Esquire, and files the following Answer and New Matter: 1. Admitted upon information and belief. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted only that there was contact between the front of the Adams vehicle and the rear of the McPherson vehicle. 7. Denied. The averments contained in Paragraph 7 and subparagraphs (a) through (d) 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. To the contrary, Ms. Adams did have her vehicle under adequate and proper control and did not violate the Assured Clear Distance Ahead Rule; (b) Denied. To the contrary, Ms. Adams did keep alert and maintain a proper watch for the presence of other motor vehicles on the highway; (c) Denied. To the contrary, Ms. Adams did operate her vehicle in a safe and appropriate manner, but was given insufficient time to avoid making contact with the rear of the Plaintiff's vehicle due to Plaintiff's actions; and (d) Denied. To the contrary, Ms. Adams did drive her vehicle in a careful and prudent manner and in compliance with all Sections of the Pennsylvania Motor Vehicle Code. 8. Denied. After reasonable investigation, Ms. Adams is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 8, relating to Plaintiff's alleged injuries, and the same are therefore denied and strict proof demanded at the time of trial. 9. Denied. After reasonable investigation, Ms. Adams is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 9, relating to Plaintiff's alleged medical treatment, and the same are therefore denied and strict proof demanded at the time of trial. 10. Denied. After reasonable investigation, Ms. Adams is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 10, relating to Plaintiff's alleged expenses, and the same are therefore denied and strict proof demanded at the time of trial. 11. Denied. After reasonable investigation, Ms. Adams is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 11, relating to Plaintiff's alleged physical and mental suffering, and the same are therefore denied and strict proof demanded at the time of trial. 12. Denied. After reasonable investigation, Ms. Adams is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 12, relating to Plaintiff's allegedly being subject to humiliation and embarrassment, and the same are therefore denied and strict proof demanded at the time of trial. 13. Denied. After reasonable investigation, Ms. Adams is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 13, relating to Plaintiff's alleged loss of earnings and earning power and capacity, and the same are therefore denied and strict proof demanded at the time of trial. 14. Denied. After reasonable investigation, Ms. Adams is without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 14, relating to Plaintiff's alleged injuries, and the same are therefore denied and strict proof demanded at the time of trial. WHEREFORE, the Defendant, Joan Duncan Adams, respectfully requests that judgment be entered in her favor and that Plaintiff's Complaint be dismissed with prejudice. NEW MATTER By way of additional answer and reply, Defendant interposes the following New Matter: 15. That the Plaintiff's alleged cause of action may be barred in whole or in part by the Pennsylvania Financial Responsibility Law and by the Limited Tort Option. 16. That the Plaintiff's alleged cause of action may be barred in whole or in part by the Pennsylvania Comparative Negligence Act and by the doctrine of contributory negligence. 17. That if it should be found that there was any negligence on the part of the Defendant, Joan Duncan Adams, which negligence is specifically denied, any such negligence was not a factual cause and/or legal cause of the Plaintiffs harm. 18. That the Plaintiffs alleged cause of action may have been caused in whole or in part by the negligence and/or carelessness of third parties or entities not presently involved in this action. 19. That the Plaintiff may have failed to mitigate her damages. WHEREFORE, the Defendant, Joan Duncan Adams, respectfully requests that judgment be entered in her favor and that Plaintiff's Complaint be dismissed with prejudice. Respectfully submitted, JOHNS?N, DUFFIE, STEWART & WEIDNER Jeff rson J. Shipm ,Esquire I.D. : 51785 P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: ils@jdsw.com Attorneys for Defendant Telephone: 717-761-4540 VERIFICATION I, Joan Duncan Adams, have read the foregoing and hereby affirm that it is true and correct to the best of my personal knowledge, or information and belief. This Verification and statement is made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities; I verify that all the statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa. C.S. ~4804. e~~ DATE: 1-/ "/-011 :235309.1 227253-1 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, at Lemoyne, Pennsylvania, on ~~f David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110-1708 Attorneys for Plaintiff JOHNSON, DUFFIE, STEWART & WEIDNER ./ e erson J. Shi an, Esquire 1.0.#:51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Defendant "'-,) <:'_':1 "') -0.:.. ':") j'/i -;') f,) ".) r-,_, C; ~ c) ~.,., :-:1 iG,.._. F] II ANGINO & ROVNER, P.c. David L. Lutz, Esquire Attorney ID#: 35956 4503 North Front Street Harrisburg, P A 17110-1708 (717) 238.6791 FAX (717) 238.5610 Attorneys for Plaintiff(s) E-mail: dlutz@angino-rovner.com BEVERLY McPHERSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. CIVIL ACTION - LAW NO. 04-3779 Civil JOAN DUNCAN ADAMS, Defendant JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER 15. through 19. All of the Defendant's New Matter, paragraphs 15 through 19, set forth conclusions oflaw to which no response is necessary. The factual allegations contained in the Plaintiff s Complaint are incorporated herein by reference. 284666 II WHEREFORE, the Plaintiff respectfully requests that the Defendant's New Matter be dismissed. ANGINO & ROVNER, P.C. ~~ J.D. No. 35956 4503 N. Front Street Harrisburg, PA l71I0 (717) 238-6791 Attorney DJr Plaintiff Date: q -<r i -D~ , 284666 II ,. CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.C., do hereby certifY that I am this day serving a true and correct copy of the PLAINTIFF'S REPLY TO DEFENDANT'S NEW MAITER upon all counsel of record via postage prepaid first class United States mail addressed as follows: Jeff Shipman, Esquire 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorney for Defendant !~J Dated: q, ) ~ " t1 284666 l:raets (") c: <:. "1:)0:; t!)C~i "!;;.;( t6 ~r~' -%.,.: r:;C) ~--\ "'""ii"t...,: ~,-, I, 5"'. c z ~ .. ...., = = .s:- C/> ~ N -J 9n :::2.-n fi'~ 1\9 00 :.:;:l-r, ~;:o ~.,..C) /-1'" c,?, ~,> ''0 :.::c "" ::s:: ~:? c::> w Johnson. Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com Attorneys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY McPHERSON, v. NO. 04-3779 JOAN DUNCAN ADAMS, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 TO: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiffs 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 lest 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; the twenty day waiting period for objections was waived; (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. JOHNSON, DUFFIE, STEWART & WEIDNER By: (" . Jeffe,tson . Shipman, Esquire Atto',ey I.D. No. 517.85 301 Market Street . P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Date: /1/ j;) / Di-j CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, ro, -tltl first class, postage prepaid, at Lemoyne, Pennsylvania, on the / d day of N () V {> rY1 b \: Y ,2004 addressed as follows: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 JOHN7UFFIE, STEWART & WEIDNER. By: Jette 50n J. Shipman, Esquire Attorney 1.0. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Johnson. Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. 0, Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com Attorneys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY McPHERSON, v. NO. 04-3779 JOAN DUNCAN ADAMS, 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: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiffs PLEASE TAKE NOTICE that Defendant intends to serve nine subpoenas identical to the ones that are 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. JOHN? DUFFIE, STEWART & WEIDNER, By: ~ JeffJ'son J. Shipman, Esquire Attolney I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Date: iii;) 11J4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, certified, postage prepaid, at Lemoyne, Pennsylvania, on the ~/1 C'l day of No Ie ,"V1 ~ (I ,2004 addressed as follows: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 JOH( , DUFFIE, STEWART & WEIDN:R By: J~erson J. Shipman, Esquire Attorney 1.0. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Beverly McPherson, Plaintiff vs. File No. 04-3779 Joan Duncan Adams, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Conner. Rich. Kearnev & Tochia Associates (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. correspondence, reports and diaQnostic test results pertainina to Beverly McPherson SSN: 191-42-7653 DOB: 5n151 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: Jefferson J. Shipman, Esquire 301 Market Street Lemoyne. PA 17043 717-761-4540 51785 Defendant TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: BY THE COURT: l;:/ prC~d~r;,tirir~/ a~e P.~~/J~J\r- ' c: Deputy <-........ DATE: ON- ;2. PI ;; 6()L1 Seal of the Court (Eft. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Beverly McPherson, Plaintiff vs, File No. 04-3779 Joan Duncan Adams, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Bennese Chiropractic (Name of Person or Entity) Within twenty (20) days after serviae of th1s subpoena, you are ordered by the court to produce the following documents or things: any and all medical records. correspondence. reports and diaanostic test results oertainina to Beverlv McPherson SSN: 191-42-7653 DOB: 5nt51 at Johnson. Duffie. Stewart & Weidner. 301 Market Street. P.O, Box 109. Lemovne. 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: Jefferson J. Shipman. Esauire 301 Market Street lemovne. PA 17043 7'17-761-4540 51785 Defendant TELEPHONE: SUPREME COURT 10 #: ATTORNEY FOR: ~rh-O P. r/(~/z~/ Deputy DATE: t)r+ .:JP ;)..oc:r Seal of the Court t (Eft. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Beverly McPherson, Plaintiff vs. File No. 04-3779 Joan Duncan Adams, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Becker Chiropractic (Name of Person or Entity) Within twenty (20) days after servic;e ofthis subpoena, you are ordered by the court to produce the following documents or things: any and all medical records. correspondence. reports and diaQnostic test results pertaininQ to Beverly McPherson SSN: 191-42-7653 DOB: 5n/51 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: Jefferson J. Shipman, Esquire 301 Market Street Lemoyne. PA 17043 717-761-4540 51785 Defendant TELEPHONE: SUPREME COURT ID #: A TIORNEY FOR: BY THE COURT: ~ f)UAj.;) :k. ~ Pro~otary/Clerk, Civil Div sion 0 ~ klA./'JA. p P. ~.fl~r( ~ , L'- DeputY DATE: ()-t- rJ..f :J t"'YY-/ Seal of the Coult -~ f (Eft. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Beverly McPherson, Plaintiff vs. File No. 04-3779 Joan Duncan Adams, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dr. William Shaffer (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. correspondence. reports and diaQnostic test results pertaininQ to Beverly McPherson SSN: 191-42-7653 DOB: 517151 at Johnson, Duffie, Stewart & Weidner, 301 Market Street. P,O. Box 109, Lemovne, 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: Jefferson J. Shipman. Esquire 301 Market Street Lemoyne. PA 17043 717-761-4540 51785 Defendant TELEPHONE: SUPREME COURT 10 #: ATTORNEY FOR: BYTHECOURT: ~ pra~j~~C~DivISion 71 '- ~~P.~~ DATE: {)rf ;:;.,P )...CV'l Seal of the Courtl (Eff. 7(97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Beverly McPherson, Plaintiff vs. File No. 04-3779 Joan Duncan Adams, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Herd-Carver Clinic (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, correspondence. reports and diaQnostic test results pertaininQ to Beverly McPherson SSN: 191-42-7653 DOB: 5/7/51 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: Jefferson J. Shipman, Esquire 301 Market Street Lemoyne, PA 17043 717-761-4540 51785 Defendant TELEPHONE: SUPREME COURT 10 #: ATTORNEY FOR: DATE: D-+ ,-'{/, ;)(X>'j Seal of the Courr BYTHECOURT: ~ pr(ln~~ry~~, !w~~iSion cP ~t:?4-0 P.7J7J;,#'/ffJ " C' Deputy (Eft. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Beverly McPherson, Plaintiff vs. File No, 04-3779 Joan Duncan Adams. Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Tristan Associates (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, correspondence. reports and diaQnostic test results pertaininQ to Beverlv McPherson SSN: 191-42-7653 DOB: 5/7/51 at Johnson. Duffie, Stewart & Weidner, 301 Market Street. P.O, Box 109. Lemovne. 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: TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: Jefferson J. Shipman, Esquire 301 Market Street Lemovne. PA 17043 717-761-4540 51785 Defendant NAME: ADDRESS: BYTHECOURT: ~ (J"A~ >k. r: . Prothonotary/Clerk, Civil Div ion 0 ~~~J?~AJ / C Deputy "-- DATE: rY-f..J P )tYi-( Seal of the cou~ (Eft. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Beverly McPherson, Plaintiff vs. File No, 04-3779 Joan Duncan Adams, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: The Intearative Medicine Physician Center, P.C. (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, correspondence, reports and diaonostic test results pertainina to Beverly McPherson SSN: 191-42-7653 DOB: 5nJ51 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: Jefferson J. Shioman. Esquire 301 Market Street Lemoyne. PA 17043 717-761-4540 51785 Defendant TELEPHONE: SUPREME COURT 10 #: ATTORNEY FOR: BY~:;~"k ~ Prothonotary/Clerk, Civil Division ? ~~ [!~/I~IJ ' C) Deputy DATE: ()~ ") P ::J..C>O'-I Seal of the Court f ---- ~ ( (Eff 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Beverly McPherson, Plaintiff vs. File No. 04-3779 Joan Duncan Adams, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Arlinaton Professional 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, correspondence. reports and diaanostic test results pertainino to Beverlv McPherson SSN: 191-42-7653 DOB: 5/7/51 at Johnson, Duffie, Stewart & Weidner, 301 Market Street. P,O, Box 109, Lemovne, 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: Jefferson J. Shipman, Esquire 301 Market Street Lemovne, PA 17043 717-761-4540 51785 Defendant TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: BY~~::_)12 ,JfZ Prothonotary/Clerk, Civil DiViSiOlf ~ ~~P~J?~/ / (: r: Deputy DATE: I:r-t :2P ~COi Seal of the Court I (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Beverly McPherson, Plaintiff vs. File No. 04-3779 Joan Duncan Adams, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 TO: Allstate Insurance Company (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 records, correspondence, reports and medical records reaardinQ Claim No. 155419951001 OIL: 8/31/01. Claim No. 155427557601, OIL: 12/05/01, Claim No. 155448549801, OIL: 10/21/02 pertainina to Beverly McPherson SSN: 191-42-7653 DOB: 5/7/51 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: Jefferson J. Shipman, Esauire 301 Market Street lemoyne, PA 17043 717-761-4540 51785 Defendant TELEPHONE: SUPREME COURT 10 #: ATTORNEY FOR: BYTHECOURT: ~ P~:o:!i-i~i~i~lon C .'------~a,_.f Y. 7fq-::;:cr- DATE: /):;j->> ;J.coy Seal of the couft (Eft. 7/97) c ~ r-:.I CO':) 0 , c ;. " .,',. -n r , --I -,- i~~;:g iT"' U) C--J r ",) -n i'j~'~ -,~. ".j;. C.) ( l,n .~:! :j ~I:"lo- '- ..,..., ("Ii :.< Johnson. Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com Attorneys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY McPHERSON, v. NO. 04-3779 JOAN DUNCAN ADAMS, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OIF A SUBPOENA PURSUANT TO RULE 4009.22 TO: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiffs 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 lest 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; the twenty day waiting period for objections was waived; (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. JOHNSON, DUFFIE, STEWART & WEIDNER By: ~ Je rson J' Shipman, Esquire. · Arney 1.[1. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Date: t'";)/,a'1/61 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, M first class, postage prepaid, at Lemoyne, Pennsylvania, on the d q day of ~cern6rr , 2004 addressed as follows: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 JOHNSON, DUFFIE, STEWART & WEIDNER . By: Jeffe on J. Shipman, Esquire Atto ey 1.0. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Te~phone(717)7614540 Attorneys for Defendant Johnson. Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jjs@jdsw.com Attomeys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BEVERLY McPHERSON, v. NO. 04-3779 JOAN DUNCAN ADAMS, 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: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 Attorneys for Plaintiffs PLEASE TAKE NOTICE that Defendant intends to serve four subpoenas identical to the ones that are attached to this notice. You halve 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. JOHNSON, DUFFIE, STEWART & WEIDNER By: ' . ... ~ AO. A~:. ~ . Je rso J.~S~ Arney 1.0. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Defendant Date: I;;.J I ~IIJ 1.../ CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the samE~ in the United States Mail, certified, postage prepaid, at Lemoyne, Pennsylvania, ~n the II.JJ fA day of j)~cefY\ bey ,2004 addressed as follows: David L. Lutz, Esquire Angino & Rovner, P.C. 4503 North Front Street Harrisburg, PA 17110 JOHNSON, DUFFIE, STEWART Be WEIDNER By: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Beverly McPherson, Plaintiff vs. File NO.04-3779 Joan Duncan Adams, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Nationwide Insurance Company (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 insurance records. correspondence, reports, medical records reaardina claim # 5837 B 448 917 08179101 FPG and any other claims pertaininQ to BeverlY McPherson SSN: 191-42-7653 DOB: 5/7/51 at Johnson. Duffie. Stewart & Weidner, 301 Market Street. Lemovne, 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: Jefferson J. Shipman, Esauire 301 Market Street Lemovne, PA 17043 717-761-4540 51785 Defendant TELEPHONE: SUPREME COURT ID #: ATTORNEY FOR: BYe:~ ) 72 .~ Prothonotary/Clerk, Civil Division 0 ~ ~o..~ e 7zC./M.("J,r- Deputy .~ DATE: . )E.c 1 S" ~y Seal of the Court (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Beverly McPherson, Plaintiff vs. File No.04-3779 Joan Duncan Adams, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR. THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dr. James I. McMillen (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you am ordered by the court to produce the following documents or things: any and all medical records. correspondence. reports and diaonostic test results pertainina to Beverly McPherson SSN: 191-42-7653 DOB: ~im51 at Johnson. Duffie. Stewart & Weidner. 301 Market Street. P.O. Box 1ml. 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 reasonablEl 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 #: A TIORNEY FOR: Jefferson J. Shioman. ESQuire 301 Market Street Lemoyne. PA 17043 717-761-4540 51785 Defendant BY THE COURT: ev7~f - - Prothonotary/Clerk, CiVil Division ~ ~~, P?en? /7'--1~ Depu DATE: J'kr I,~ J.CY:J.f Seal of the C urt (Eft. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Beverly McPherson, Plaintiff vs. File NO.04-3779 Joan Duncan Adams, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dr. Ravi Dukkioati (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you arEl ordered by the court to produce the following documents or things: any and all medical records. corresDondence. reoorts and diaanostic test results oertainina to Beverly McPherson SSN: 191-42-7653 DOB: Sa/51 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 mnking 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 :;ubpoena 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. Shioman. Esauire 301 Market Street Lemoyne. PA 17043 717-761-4540 51785 Defendant BY THE COUR.T: 0N'lp} ~ Prothonotary/Clerk, Civil DiVision c...... ~ ~ 0 ~Q. 7J;-~./Z/ J t,r-----. Deputy DATE: D~ c, IS :looe; Seal of the Couh (Eff. 7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Beverly McPherson, Plaintiff vs. File NO.04-3779 Joan Duncan Adams, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Pennsvlvania Deoartment of Transoortation (Name of Person or Entity) . Within twenty (20) days after service of this subpoena, you arei ordered by the court to produce the following documents or things: any and all records from 1997 i:hrouQh Januarv 2003 reoardinq accidents oertainina to the Gettvsburg exit of Route 581 east. acces:sina Route 15 south. Camo Hill. Cumberland County at Johnson. Duffie. Stewart & Weidner. 301 Market Street. Lemovne. 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 mSlking 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 ~;ubpoena 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: Jefferson J. Shioman. Esquire 301 Market Street Lemovne. PA 17043 717-761-4540 51785 Defendant TELEPHONE: SUPREME COURT to #: A TIORNEY FOR: BY THE COURT: '-- Ll A..ch-.P.....2. 77;;.,ur..or- Deputy DATE: D~c /~. d..Qd-( Seal of the Cdurt (Eff. 7/97) n":" ( ~ r~-: i.::c o c- -.-...; -' ,....:> C..::;l ("'";, cYi (- ?-;-: o ., -::-.I III f11i"'= -r1m : J '-J roo'T' ~(") ?~-:B .:'70 (jrn ; -J ,J> :0 ~< I L.) ~ _.-. ,.. ...0 U1 tv Beverly McPherson, Plaintiff IN THE COURT OF CmtMON PL;AS OF CL~IBERLAND COUNTY, PENNSYLVM~IA vs. NO. 04-3779 CIVIL u Joan Duncan Adams, Defendant RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the folloving form; PETITION FOR APPOINll1ENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: David L. Lutz, Esquire , counsel fot" the plaintiff~ in the above 1- 2. action (or actions), respectfully represents that: The above-captioned action (or actions) is (arei at issue. The claim of the plaintiff in the action is $ unliquidated The counterclaim of the defendant in the action is damage,S The following attorneys are interested in the case(s) as counselor are other- wise disqualified to sit as arbitrators: David L. Lutz, Esquire, and Jefferson Shipman, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. cc Jeff Shipman, Esquire Re~~llY submit:ed, ~L~~tz, Esquire ORDER OF COURT AND NOW, .;1~~;2t5(. , i:9c2/Jdt/, in consideration of the foregoing petition, ;u..,:d, ~~Sq.,.,i'a:v .1? ~ Esq., and .~ ('Y~ ,Esq., are appointed arbitrators in the above-captioned action (or actions) as prayed for. By the Court, $l~ P. J. .' T 1 G :f:?:: ('-" ra .Cr) #:- --- C> G' ~ ~~ :J --- ~ &-t r- ( i.!" . ..,.., I \~'.' '" ~, # s S : 1 i J, : 'J 2~ Z~ :: ~-:J I;~: 8 3 / c ~ ' '- , I (' "t ~.:~, ~ --' _f...- ~ ~") .en --I r-I-' --. i'ji \."' II i ~ c) .. ~ I'" MO'''.; ~ i .' -' ,~ -- .. ._l'; r.~ BEvi!/il./.y !I1ef'IItf/(Sdl'l r Plaintiff In The Court of Common leas of Cumberland County, Pennsylvania No. - 3779 J?;AA/ /)~Alt 4-" /I/)III#} Defendant Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the onstitution of the United States and the Constitution of this Commonwealth and that we will discharge he duties of 0 with fidelity. 1tj~ Signature /.<'cmt G, e,f'~M,.w Name (Chainnan) SKt(~ ! t$,t.4I~..f. Law Firm tit! V, haul S~ Address tI(~If>V'('f6u~ 4 17()~s City, Zip 11#1. } (J"lfIf .!fe. wFinn I r .l91l1 #/MK€T St: Address IP> Ml#J-/Dl 01ar 191Ta:J,l. Addre s Gt~#Mlf IJ, 171111 City, Zip tl/rtr~ /7"'3 Zip -tl'/()7 Award We, t.l1e undersigned arbitrators, having been duly appointed arid sworn (or af following award: (Note: If damages for delay are awarded, they shall be ed), make the parately stated.) I " t-/-u'(>/ . . Arbitrator, dissents. (In ert name if applicable.) Date of Hearing: 4~tII I'. -;Of)~ Date of Award: Jlt't4L,/" "2(?()~ Notice of Entry of Award Now, the /0 dayof '71t~ ,20t/$ ,at //yt,. ,~.M., eaboveawardwas entered upon the docket and notice thereof given by mail to the parties or their atto eys. Arbitrators' compensation to be paid upon appeal: $ d1'~ .~~ Prothonotary v By: Deputy .' ^I'" 07 ~ - t-.L Ild_~f 1";7 ,jJo/" ~ ~ "t dj ~ aJ" d5 ;4,.3 L'tL --- I,.r \,,) \ 1\ ',] !I I . I ANGINa & ROVNER, P.c. David L. Lutz, Esquire Attorney ID# : 35956 4503 North Front Street Harrisburg, P A 17110.1708 (1i7) 238.6791 FAX (717) 238.5610 Attorneys for Plaintiff(s) EMmail: dlutz@angino-rovncLcom BEVERLY McPHERSON, IN THE COURT OF CO v1MON PLEAS Plaintiff CUMBERLAND COUN rY,PA v. CIVIL ACTION - LAW NO. 04-3779 Civil JOAN DUNCAN ADAMS, Defendant JURY TRIAL DEMANI ED PRAECIPE To the Prothonotary of Cumberland County: Please mark the above-captioned action settled, satisfied, and discor tinued. ANGINO & ROVNER ,P.C. CJ^1\ // DaVId L. Lutz l.D. No. 35956 4503 N. Front Street Harrisburg, P A 17110 (717) 238-6791 - phon (717) 238-5610 - fax /' dlutz@angino-rovner.c m Date: y... li ' U) Attorney for Plaintiff 281311 I ~ CERTIFICATE OF SERVICE I, Mary T. Geraets, an employee of the law firm of Angino & Rovner, P.c., do hereby certify that I am this day serving a true and correct copy of the PRAECI E upon all counsel of record via postage prepaid first class United States mail addressed as follows' Jeff Shipman, Esquire 30 I Market Street P.O. Box 109 Lernoyne, P A 17043-0109 Attorney for Defendant . / , , )\.lLv (, Mary T. Ghaets (~. i , .,,, . 'f U{z[/ . . ~\ Dated: W--.. \. --( 281317 -q(' i1).\..~., ,t,,:",.,_ Z\-. (!I,!,; -5.: :~\; 3. o ~~ r-> = = CJ' ~ ;AJ , Cf' -<l -:.~ ~ ::? 4'\ {'1'C: "t'!';l; -D--r ',~, ,--. \~~ ~\ ~''i~,~~ '~/-( '11. :..c - .' <f\ cJl