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HomeMy WebLinkAbout11-3436IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. //- 3'l3CP LINDA ETTINGER 19 Bungalo Road Enola, PA 17025 No"/ Civil Action - Law JURY TRIAL DEMANDED RICHARD FULLER 19 Bungalo Road versus Enola, PA 17025 PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please issue writ of summons in the above-captioned action. X Writ of Summons shall be issued and forwarded TIMOTHY A. SHOLLENBERGER, ESQUIRE Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, Pennsylvania 17025 (717) 728-3200 WRIT OF SUMMONS c ° C. _n _.rn _V - m v O© D <6 a a 'O = o?n on _ C N .-.{rT7 TO THE ABOVE NAMED DEFENDANT(S): RICHARD FULLER YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. /^\ Date: e-ll L-j/ f l by lerk of Oburts - Civil Division Deputy ( ) Check here if reverse is issued for additional information C' l?.tf /C?3?P Date: 3 t O HONOTAR 2aI1 F R I i AM 10"' '' BERLAND COUNTY -UM P,ENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA ETTINGER, CIVIL DIVISION Plaintiff, NO. 11-3436 V. PRAECIPE FOR APPEARANCE RICHARD FULLER, Defendant. (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #18523 t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA ETTINGER, CIVIL DIVISION Plaintiff, v. NO. 11-3436 RICHARD FULLER, (Jury Trial Demanded) Defendant. PRAECIPE FOR APPEARANCE TO: THE PROTHONOTARY Kindly enter the Appearance of the undersigned, Kevin D. Rauch, Esquire, of the law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., on behalf of the Defendant, Richard Fuller, in the above case. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: P(IT B2a?lrf"i, Esquire nsel for Defendant I CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR APPEARANCE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 7th day of April, 2011. Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, L.L.P. 225 Millennium Way Enola, PA 17025 (Attorney for Plaintiff) SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: v)KD. R&uch, Esquire unsel for Defendant 70-0 'Flux ill ? AFB 11 A?'? 1Q? 4 3 I~'l;MBc3YilV.ANi ?tY PEN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA ETTINGER, CIVIL DIVISION Plaintiff, NO. 11-3436 V. PRAECIPE FOR RULE TO FILE RICHARD FULLER, COMPLAINT Defendant. (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #18523 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA ETTINGER, CIVIL DIVISION Plaintiff, V. NO. 11-3436 RICHARD FULLER, (Jury Trial Demanded) Defendant. PRAECIPE FOR RULE TO FILE COMPLAINT TO: The Prothonotary Kindly rule the Plaintiff, Linda Ettinger, to file a Complaint in Civil Action within twenty (20) days. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: Nfi'D. Rauch, Esquire unsel for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA ETTINGER, CIVIL DIVISION Plaintiff, V. NO. 11-3436 RICHARD FULLER, (Jury Trial Demanded) Defendant. RULE AND NOW, this -, day of `1Pr+( , 2011, upon consideration of Defendant's Praecipe for Rule to File a Complaint, a Rule is hereby granted upon Plaintiff to file a Complaint within twenty (20) days of service, or suffer judgment Non Pros. Rule issued this ?? day ofY i ( , 2011. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 7t" day of April, 2011. Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, L.L.P. 225 Millennium Way Enola, PA 17025 (Attorney for Plaintiff) SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, P.C. By: in D. Rauch, Esquire nsel for Defendant SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff LINDA ETTINGER, Plaintiff 'FILEO-OFFICE OF THE PROTHO,JNOT!?R?, 2011 APR 21 PM 12: 07 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.1 RICHARD FULLER, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED ACCEPTANCE OF SERVICE I, Richard Fuller, accept service of Plaintiffs Writ of S ons, on my own behalf. Dat Richard SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff LINDA ETTINGER, Plaintiff V. RICHARD FULLER, Defendant '10 - ai Y"tir . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3436 CIVIL ACTION - LAW COMPLAINT AND NOW, comes the Plaintiff, Linda Ettinger, by and through her attorneys, SHOLLENBERGER & JANUZZI, LLP, and respectfully represents the following: 1 2 3 4 Plaintiff, Linda Ettinger, is an adult individual who currently resides at 109 Bungalow Road, Enola, Cumberland County, Pennsylvania. Defendant, Richard Fuller, is an adult individual whose last known address is 109 Bungalow Road, Enola, Cumberland County, Pennsylvania. The facts and circumstances hereinafter set forth took place on September 11, 2009, at or about 7:26 p.m. at 109 Bungalow Road in Enola, Pennsylvania. At the aforesaid time and place, Plaintiff, Linda Ettinger, was in her living room of her home with her seven year old son, Shane. 5. At the aforesaid time and place, Defendant, Richard Fuller, was the owner and operator of a 1990 Chevrolet F150 pick up truck bearing Pennsylvania registration YXA9297. 6. At the aforesaid time and place, Defendant, Richard Fuller, was traveling South on Bungalow Road in Enola, Pennsylvania and drove the aforesaid Chevrolet F150 pick up truck into the front of the house owned by Linda Ettinger located at 109 Bungalow Road., where upon Plaintiff, Linda Ettinger, twisted to her right to pick up her 40-45 pound son and, unable to steady herself, fell over the dog cage located next to the sofa. 7. As a result of the aforesaid incident, Plaintiff, Linda Ettinger, has suffered serious and permanent injuries, including but not limited to the following: a. Benign hypertension; b. Headaches; C. Myofascial pain syndrome; d. Cervical subluxation; e. Thoracic subluxation; f. Lumbar/lumbosacral subluxation; g. Severe strain and sprain of the muscles, tendons, ligaments and other connective tissues at or abut the cervical spine; h. Severe strain and sprain of the muscles, tendons, ligaments and other connective tissues at or abut the thoracic spine; i. Severe strain and sprain of the muscles, tendons, ligaments and other connective tissues at or abut the lumbar spine; j. Exacerbation of right trapezial symptoms; k. Cervical dystonia; I. Post traumatic depression; M. Post traumatic anxiety; n. Aggravation of degenerative disc disease of the cervical spine with bulging discs at C5-6 and C6-7; o. Cervical radiculopathy; and p. Cervicalgia. 8. The aforesaid collision was the direct and proximate result of the negligence of Defendant, Richard Fuller, in operating the Chevrolet F150 in a careless, reckless, and negligent manner as follows: a. Driving, operating or being in actual physical control of the movement of a motor vehicle after imbibing a sufficient amount of alcohol such that he/she was rendered incapable of safely driving, operating or being in actual physical control of a motor vehicle in violation of Section 3802 (a)(1) of the PA Motor Vehicle Code; b. Driving, operating or being in actual physical control of the movement of a vehicle after imbibing a sufficient amount of alcohol such that the alcohol concentration in the Defendant's blood or breath was at least 0.16% or higher within two hours after the Defendant drove, operated or was in actual physical control of the movement of the vehicle in violation of Section 3802 (c) of the Pennsylvania Motor Vehicle Code. C. In failing to have his/her vehicle under proper and adequate control; d. In failing to apply the brakes in time to avoid driving into the side of the Plaintiff's home; and e. In operating the vehicle while under the influence of intoxicating liquor. 9. As a direct and proximate result of the aforesaid injuries, Plaintiff, Linda Ettinger, has undergone and in the future will undergo great pain and suffering for which damages are claimed. 10. As a further result of the aforesaid injuries, Plaintiff, Linda Ettinger, has suffered and may continue to suffer a loss of earnings for which damages are claimed. 11. As a further result of the aforesaid injuries, Plaintiff, Linda Ettinger, has and/or may in the future incur a loss of earning capacity for which damages are claimed. 12. As a further result of the aforesaid injuries, Plaintiff, Linda Ettinger, has sustained scarring and disfigurement for which damages are claimed. 13. As a further result of the aforesaid injuries, Plaintiff, Linda Ettinger, has sustained a permanent diminution in her ability to enjoy life and life's pleasures for which damages are claimed. 14. As a further result of this collision, Plaintiff, Linda Ettinger, has and/or may incur reasonable and necessary medical rehabilitative costs and expenses in excess of the amounts paid or payable pursuant to Subchapter B of the Pennsylvania Motor Vehicle Financial Responsibility Law, Workers' Compensation or any program, group contact, or other arrangement for payment of benefits as defined in 75 Pa. C.S.A. Section 1719. 15. As a further result of the aforesaid injuries, Plaintiff, Linda Ettinger, has incurred or may hereinafter incur financial expenses and losses which exceed sums recoverable under the limitations and exclusions of the Pennsylvania Motor Vehicle Financial Responsibility Law for which damages are claimed. 16. Defendant, Richard Fuller, was convicted for driving under the influence of alcohol in this collision. Therefore, Plaintiff, Linda Ettinger, remains eligible to claim compensation for non economic loss and economic loss sustained in this collision pursuant to applicable tort law. 17. Plaintiff, Linda Ettinger, was occupying her home at the time of the collision and therefore remains eligible to claim compensation for non economic loss and economic loss sustained in this collision pursuant to applicable tort law. WHEREFORE, Plaintiff, Linda Ettinger, demands judgment against Defendant, Richard Fuller, for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. Respectfully submitted, Shollenberger & Januzzi, LLP SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 for Nlaintitt LINDA ETTINGER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. RICHARD FULLER, Defendant NO. 11-3436 CIVIL ACTION - LAW CERTIFICATE OF SERVICE AND NOW, this V y of May, 2011, 1 hereby certify that I have served the foregoing Complaint on the following, via U.S. Mail: Kevin Rauch Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 SHOL B U I, LLP By: e e, s . i X431 tornW.: 4 D -0F F Iirc >).. r FIE PROTHONOTARY 2011 JUL 13 AM 10: 40 rUtlBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA ETTINGER, Plaintiff, V. CIVIL DIVISION NO. 11-3436 RICHARD FULLER, Defendant. ANSWER AND NEW MATTER (Jury Trial Demanded) TO: Plaintiff You are hereby notified to file a written Response to the enclosed Answer and New Matter within twenty (20) days From service hereof or a judgment May be entered-against you. &Jrn ers, McDoY nell, Hudock, Guth de & Skeel, P.C. Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, P.C. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #18523 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA ETTINGER, CIVIL DIVISION Plaintiff, V. NO. 11-3436 RICHARD FULLER, (Jury Trial Demanded) Defendant. ANSWER AND NEW MATTER AND NOW, comes the Defendant, Richard Fuller, by and through his counsel, Summers, McDonnell, Hudock, Guthrie & Skeel, P.C., and Kevin D. Rauch, Esquire, and files the following Answer and New Matter and in support thereof avers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. After reasonable investigation, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 5. Admitted. 6. Admitted in part, denied in part. It is admitted that the Defendant drove his vehicle into the front of the Plaintiff's house. The remainder of the allegations in paragraph 6 are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. By way of further answer, the Defendant has insufficient information as to the truth or falsity of said averments, therefore said averments are denied and strict proof thereof is demanded at the time of trial. 7. Paragraph 7 and all of its subparts state legal conclusions to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 8. Paragraph 8 and all of its subparts state legal conclusions to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 9. Paragraph 9 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 10. Paragraph 10 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 11. Paragraph 11 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 12. Paragraph 12 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 13. Paragraph 13 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 14. Paragraph 14 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 15. Paragraph 15 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 16. Paragraph 16 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. 17. Paragraph 17 states a legal conclusion to which no response is required. To the extent, however, that a response is deemed necessary, said averments are denied generally pursuant to Pa.R.C.P. 1029(d) and (e). Strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Richard Fuller, respectfully requests this Honorable Court enter judgment in his favor and against the Plaintiff with costs and prejudice imposed. NEW MATTER 18. The motor vehicle accident in controversy is subject to the Pennsylvania Motor Vehicle Financial Responsibility Law and this Defendant asserts, as affirmative defenses, all rights, privileges and/or immunities accruing pursuant to said statute. 19. Some and/or all of Plaintiffs claims for damages are items of economic detriment which are or could be compensable pursuant to either the Pennsylvania Motor Vehicle Financial Responsibility Law and/or other collateral sources and same may not be duplicated in the present lawsuit. WHEREFORE, Defendant, Richard Fuller, respectfully requests this Honorable Court enter judgment in his favor and against the Plaintiff with costs and prejudice imposed. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE &*jgk-,P?C. By: Ke 'n D`Rauch, Es wire Cou sel for Defendant VERIFICATION Defendant verifies that he is the Defendant in the foregoing action; that the foregoing ANSWER AND NEW MATTER is based upon information which he has furnished to his counsel and information which has been gathered by his counsel in the preparation of the lawsuit. The language of the ANSWER AND NEW MATTER is that of counsel and not of the Defendant. Defendant has read the ANSWER AND NEW MATTER and to the extent that the ANSWER AND NEW MATTER is based upon information which he has given to his counsel, it is true and correct to the best of his knowledge, information and belief. To the extent that the content of the ANSWER AND NEW MATTER is that of counsel, he has relied upon counsel in making this Affidavit. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: '70- // ?r- Ri6ardFull6r/ #18523 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing ANSWER AND NEW MATTER has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 12th day of July, 2011. Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, L.L.P. 225 Millennium Way Enola, PA 17025 (Attorney for Plaintiff) SUMMERS, McDONNELL, HUDOCK, GUTHRIE & WEEL, F-C. B By: rOQ- F uch, Esquire nsel for Defendant I- c > C ,, c SHOLLENBERGER & JANUZZI LLP = , 2225 Millennium Way -" M Enola, Pennsylvania 17025 Cam--, ?Q Telephone Number: (717) 728-3200 cD Fax Number: (717) 728-3400 > c= ; Attorneys for Plaintiff LINDA ETTINGER, Plaintiff V. RICHARD FULLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3436 CIVIL ACTION - LAW PLAINVF'S REPLY TO NEW WAITER OF. FONDANT RICHARD FULLER AND NOW COMES THE PLAINTIFF, Linda Ettinger, by and through her attorney, SHOLLENBERGER AND JANUZZI, LLP, and files this Reply to New Matter of Defendant Richard Fuller (hereinafter "Defendant"), and, in support thereof, respectfully represents the following: 18. The averment contained in Paragraph 18 is a conclusion of law to which no answer is required. To the extent an answer is required, same is denied pursuant to Pa. R.C.P. 1029(e). 19. The averment contained in Paragraph 19 is a conclusion of law to which no answer is required. To the extent an answer is required, same is denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, the Plaintiff respectfully requests that the Defendant's New Matter be dismissed and judgment entered in favor of the Plaintiff as a matter of law. Respectfully Submitted, SHOLLENBERGER & JANUZZI, LLP Attor707z2z" By: T A. hollen erger Attorney I . D. 34343 Date: ?,Q? l y a? II SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff LINDA ETTINGER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. RICHARD FULLER, Defendant NO. 11-3436 CIVIL ACTION - LAW CERTIFICATE OF SERVICE AND NOW this day of July, 2011, 1 hereby certify that I have served the foregoing Plaintiff's Reply to New Matter of Defendant on the following by forwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to: Kevin Rauch Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 By: SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 tjt, , 1. iiAU717 PM 12: PENNSYI.VANIA Httorne s for Plaintiff LINDA ETTINGER, Plaintiff V. RICHARD FULLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3436 CIVIL ACTION - LAW CERTIFICATE OF SERVICE AND NOW, this YA day of August, 2011, 1 hereby certify that I have served the foregoing Plaintiff's Answers to Defendant's Interrogatories- Set I on the following, via U.S. Mail: Kevin Rauch Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 SHOLygNBERGER & JANUZZI, LLP By: `' c?aM I (l?v Otott othy A. Shollenberger, Esq. rn ey ID: 34343 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 2 11 AUG 17 PM 12; ; PENNSYLVAI'1 r?uurrie 5 Tor riamUTr LINDA ETTINGER, Plaintiff V. RICHARD FULLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3436 CIVIL ACTION - LAW CERTIFICATE OF SERVICE AND NOW, this Vday of August, 2011, 1 hereby certify that I have served the foregoing Plaintiff's Response to Defendant's Request for Production of Documents on the following, via U.S. Mail: Kevin Rauch Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 SHOLVI?NBERGER & JANUZZI, LLP T othy A. Shollenberger, Esq. Attorney ID: 34343 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff LINDA ETTINGER, Plaintiff V. RICHARD FULLER, Defendant f ?tJ ff,? /: T, f f . ??LI/ANIA`J IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3436 CIVIL ACTION - LAW CERTIFICATE OF SERVICE And now, this -LMay of November, 2011, 1 hereby certify that a copy of the foregoing Request for Production of Documents have been served upon the following, via U.S. Certified Restricted Delivery Mail: Kevin Rauch, Esq. Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 SHOLLENBERJ?;ER & JANUZZI, LLP Tirxioth# A/,ShQWe' nb er SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff LINDA ETTINGER, Plaintiff V. RICHARD FULLER, Defendant i I'rE 11 P1P3L1 4oU8 I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3436 CIVIL ACTION - LAW CERTIFICATE OF SERVICE And now, this day of November, 2011, 1 hereby certify that a copy of the foregoing Interrogatories have been served upon the following, via U.S. Certified Restricted Delivery Mail: Kevin Rauch, Esq. Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 SHOLLENBERGER & JANUZZI, LLP By: l'ovrrn'ey Ile erger, Esq. ID#34343 31 SHOLLENBERGER & JANUZZI, LLP 2225 MILLENNIUM WAY ! ENOLA, PA 17025 (717) 728-3200 ! FAX (717) 728-3400 C'7 C r.,a ca ? SHOLLENBERGER & JANUZZI LLP zrrn ? rn- , r co 2225 Millennium Way u . ,rrnn o Enola, Pennsylvania 17025 rn a Telephone Number: (717) 728-3200 v o- Fax Number: (717) 728-3400 ... C) rn A ttorneys for Plaintiff c-n LINDA ETTINGER, Plaintiff V. RICHARD FULLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3436 CIVIL ACTION - LAW CERTIFICATE OF SERVICE AND NOW this lb day of February, 2012, 1 hereby certify that I have served the updated medical records from OIP as Supplemental Responses to Request for Production of Documents and Interrogatories on the following by forwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to: Kevin Rauch Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff LINDA ETTINGER, Plaintiff V. RICHARD FULLER, Defendant . l hir?FROTHONOir', % 21U 12 TSAR 13 PH 2: 23 UMBERLAND COUNT"' PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3436 CIVIL ACTION - LAW CERTIFICATE OF SERVICE AND NOW this day of March, 2012, 1 hereby certify that I have served the updated medical records from Good Hope Family Physicians as Supplemental Responses to Request for Production of Documents and Interrogatories on the following by forwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to: Alicia Genther, Esq. Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 S B, SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff LINDA ETTINGER, Plaintiff V. RICHARD FULLER, Defendant "U-i IBERLAND COUid `'E INSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3436 CIVIL ACTION - LAW CERTIFICATE OF SERVICE AND NOW this 13+,day of April, 2012, 1 hereby certify that I have served the updated medical records from East Pennsboro Ambulance Service as Supplemental Responses to Request for Production of Documents and Interrogatories on the following by forwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to: Alicia Genther, Esq. Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 SHOLL BE ER & JANUZZI, LLP By: Wol 4 43 9 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff LINDA ETTINGER, Plaintiff V. RICHARD FULLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3436 CIVIL ACTION - LAW CERTIFICATE OF SERVICE kk AND NOW this _ day of June, 2012, 1 hereby certify that I have served the updated medical records from Rite Aid Pharmacies as Supplemental Responses to Request for Production of Documents and Interrogatories on the following by forwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to Alicia Genther, Esq. Summers, McDonnell, Hudock, Guthrie & Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 SHOLLENBERGER & JANUZZI, LLP 2013 NO 2� 2225 Millennium Way CUIk1; PH �' 1 o Enola, PA 17025 Telephone Number: 717 728-3200 P $AL A WIA Fax Number: {717} 728-3400 Attomeys for Plaintiff LINDA ETTINGER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 11-3436 RICHARD FULLER, Defendant CIVIL ACTION — LAW AND NOW, this ` day of March, 2013, 1 hereby certify that I have served the foregoing Plaintiff's Answers to Defendant's Supplemental Interrogatories on the following, via U.S. Mail: Kevin Rauch Summers, McDonnell, Hudock, Guthrie &Skeel, P.C. 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 SHOLL ANUZZI, LLP By- 2(o 0�,, �Ie?e$�e q. omey 16. 343 2014 ,UN CUNBERL °FN!S Y� AIS'/COUy,;.4, E IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA ETTINGER, CIVIL DIVISION Plaintiff, E: RICHARD FULLER, Defendant. #18523 NO. 11-3436 NOTICE OF DEATH OF A PARTY (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK & GUTHRIE, P.C. Firm #911 945 East Park Drive, Suite 201 Harrisburg, PA 17111 (717) 901-5916 IN THE'COURT OF COMMON PLEAS OF CUMBERLAND. COUNTY, PENNSYLVANIA LINDA ETTINGER, CIVIL DIVISION Plaint ff, RICHARD FULLER, Defendant. NO. 11-3436 (Jury Trial Demanded) NOTICE OF DEATH OF A PARTY TO: PROTHONOTARY The death of Richard Fuller, a party to the above action, during the pendency of this action is !noted upon the record.. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK & GUTHRIE, P.C.' B in D. Rauch, Esquire Counsel for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Notice of Death has been mailed by U.S. Mail to counsel of record via first class mail, postage pre -paid, this 16th day of June, 2014. Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, L.L.P. 225 Millennium Way Enola, PA 17025 (Attorney for Plaintiff) SUMMERS, McDONNELL, HUDOCK & GUTHRIE, P.C. Key' D. Rauch, Esquire Counsel for Defendant SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff LINDA ETTINGER, Plaintiff v. RICHARD FULLER, Defendant • ; 7j1.7,,sA rift 57 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-3436 CIVIL ACTION — LAW PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above -captioned matter "settled, discontinued and ended." Date: 12 42. /Li Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP .thy . Sho erger, squire ounsel for Plaintiff Attorney I.D. #34343