The URL can be used to link to this page

Home My WebLink About11-7293IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ROSA MILLER and ROBERT MILLER, Individually and as husband and wife, 112 Fieldstone Drive Carlisle, PA 17015 Plaintiff(s)& Address(es) NO. ?I. 702`7 C/ !W G Tdlr? CIVIL ACTION - LAW GERALDINE SHERIDAN 16 West Main Street Apartment A c New Bloomfield, PA 17068 rnnCo r=i rn r ` - ? O Defendant(s) ; --+?, Address(es) C "j : W 1 - C> r, JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Kindly issue a Writ of Summons against the Defendant, Geraldine Sheridan. The Writ of Summons should be issued and forwarded to the Cumberland County Sheriff for deputized service by the Perry County Sheriff's Office upon Geraldine Sheridan, 16 West Main Street, Apartment A, New Bloomfield, Pennsylvania, 17068. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Fran s J. L ert , IV, Esquire I.D. o. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Date: 2011 Attorneys for Plaintiffs 0 q0j. oo py kl? C* Sq s-8q 477633-1 D -f#F'- o16 7 13 METZGER, WICKERSHAM, P.C. By: Francis J. Lafferty, IV, Esquire Attorney I.D. No. 84009 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 ROSA MILLER and, ROBERT MILLER, Individually and as husband and wife, Plaintiffs vs. Attorneys for Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. f?- 7?q3 CIVIL ACTION - LAW GERALDINE SHERIDAN, Defendant JURY TRIAL DEMANDED WRIT OF SUMMONS TO: Geraldine Sheridan 16 West Main Street Apartment A New Bloomfield, PA 17068 You are hereby notified that Plaintiffs, Rosa Miller and Robert Miller, have commenced an action against you. Daterr 11 , 2011 Prothonotary DBJtYd D. we?? 477633-1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 1 I L ID F Sheriff?tity of 4a+nfirr?? ?!:t j : faJ it `, 1 Jody S Smithr? 30 ?Y3 2: Chief Deputy Richard W Stewart C(}MBERI Ak-D C0,"M Solicitor 0;; 77 ?:? wRF 7 E t-1 N S Y L*VA'111! I A Rosa Miller (et al.) Case Number vs. 2011-7293 Geraldine Sheridan SHERIFF'S RETURN OF SERVICE 09/21/2011 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: Geraldine Sheridan, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Perry County, Pennsylvania to serve the within Writ of Summons according to law. 09/26/2011 12:48 PM - Perry County Return: And now September 26, 2011 at 1248 hours I, Carl E. Nace, Sheriff of Perry County, Pennsylvania, do hereby certify and return that I served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Geraldine Sheridan by making known unto herself personally, at The Perry County Sheriffs Office, P.O. Box 6, Courthouse, New Bloomfield, Pennsylvania 17068 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 September 28, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF c cou.-?;Suitn Srenff. Te!eoseft. inc. 6 ,6 LU i t t A,????tta?.t2LA ?9 ,Coup,T111ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROSA MILLER and ROBERT MILLER, Individually and as Husband and Wife, Plaintiffs V. GERALDINE SHERIDAN, Defendant NO 11-7293 JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of George H. Eager of the Law Firm of Eager, Stengel, Quinn & Sofilka as attorney of record on behalf of the Defendant in the above captioned action. EAGER, STENGEL, QUINN & SOFILKA DATE: ?O BY: George H. Eaefer; E Attorney for Defe a I.D. No. 27740 1347 Fruitville ike Lancaster, PA 17601 (717) 290-7971 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for Entry of Appearance upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Francis J. Lafferty, IV, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 EAGER, STENGEL, QUINN & SOFILKA DATE: ho BY: George H. Eag squire Attorney for endant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 ;r r? ' fir n 3,' JI is-7 2CI I OCT -7 PM 2: C7 "UMBERLAND COU4 1.:., PENNSYLVANIA ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROSA MILLER and ROBERT MILLER, Individually and as Husband and Wife, Plaintiffs NO 11-7293 V. GERALDINE SHERIDAN, JURY TRIAL DEMANDED Defendant PRAECIPE FOR RULE TO FILE COMPLAINT TO: David D. Buell, Prothonotary, Cumberland County Courthouse, One Courthouse Square Carlisle, PA 17013-3387 Please enter a Rule upon the Plaintiff to file a Complaint in the above captioned matter within twenty (20) days of the Rule or suffer a judgment of non pros. EAGER, STENGEL, QUINN & SOFILKA DATE: Lo & I 1 AND NOW, this 7 day of above dir6ded. BY: George H. E r, Esquire Attorney fo efendant I.D. No. 27740 1347 Fruitvilte Pike Lancaster, PA 17601 (717) 290-7971 0&- , 20 //, a Rule has been entered upon the Plaintiff as CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for a Rule to File a Complaint upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Francis J. Lafferty, IV, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 DATE: M/0(' ))/ BY: EAGER, STENGEL, QUINN & SOFILKA George H. Eager squire Attorney for De ndant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 k ? METZGER, WICKERSHAM, P.C. By: Zachary D. Campbell, Esquire Attorney I.D. No. 93177 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiffs Rosa Miller and Robert Miller ROSA MILLER and, IN THE COURT OF COMMON PLEAS OF ROBERT MILLER, Individually CUMBERLAND COUNTY, PENNSYLVANI A and as husband and wife, . Plaintiffs NO.2011-7293' m vs. ; tea CIVIL ACTION - LAW = ?• -= GERALDINE SHERIDAN ? , - Cz Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND TO: Defendant, Geraldine Sheridan YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within Twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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. Cumberland County Lawyer Referral Service 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 479545-1 AVISO USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion dentro de veinte (20) dias a partir de la fecha en que recibio la demanda y el aviso. Usted debe presentar comparecencia esrita en persona o po abogado y presentar en la Corte por escrito sus defensas o sus objeciones a las demandas en su contra. Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte puede decidir en su contra sin mas aviso o notificacion por cualquier dinero reclamado en la demanda o por cualquier dinero reclamado en la demanda o po cualquier otra queja o compensacion reclamados por el Demandante. USTED PUEDE PERDER DINERO, O PROPIEDADES U OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI USTED NO TIENE O NO CONOCE UN ABODAGO, VAYA O LLAME A LA OFICINA EN LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 479545-1 METZGER, WICKERSHAM, P.C. By: Zachary D. Campbell, Esquire Attorney I.D. No. 93177 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiffs Rosa Miller and Robert Miller ROSA MILLER and, ROBERT MILLER, Individually and as husband and wife, Plaintiffs VS. GERALDINE SHERIDAN, : Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2011-7293 CIVIL ACTION - LAW JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiffs, Rosa Miller and Robert Miller, by and through their attorneys, Metzger, Wickersham, Knauss & Erb, and respectfully represents the following: FACTS APPLICABLE TO ALL COUNTS 1. Plaintiffs, Rosa Miller and Robert Miller, are adult individuals residing at 112 Fieldstone Drive, Carlisle, Cumberland County, Pennsylvania, 17015. 2. Defendant, Geraldine Sheridan is an adult individual who was last known to reside at 16 West Main Street, Apartment A, New Bloomfield, Perry County, Pennsylvania, 17068. 3. The facts and circumstances hereinafter set forth occurred on October 15, 2009, at or about 8:30 A.M. on or near Hollow Brook Road in Middlesex Township, Cumberland County, Pennsylvania. 4. At the aforesaid time and place, Plaintiff, Rosa Miller, was the owner and 479545-1 operator of a 2008 Dodge Grand Caravan bearing Pennsylvania License Plate No. EKX5529. 5. At the aforesaid time and place, Defendant, Geraldine Sheridan was the operator of a 2000 Pontiac Grand Am bearing Pennsylvania License Plate No. FLE8139. 6. At the aforesaid time and place, the vehicle driven by Plaintiff, Rosa Miller, was traveling north on Hollow Brook Road, in Middlesex Township, Cumberland County, Pennsylvania. 7. At the aforesaid time and place, the Defendant, Geraldine Sheridan, was traveling south on Hollow Brook Road, in Middlesex Township, Cumberland County, Pennsylvania. 8. At the aforesaid time and place, the Defendant, Geraldine Sheridan, attempted to travel around a right hand curve, crossed over the double-yellow line, striking the front of Plaintiff's vehicle. 9. Because of the careless actions of the Defendant, Geraldine Sheridan, a violent collision occurred between the two vehicles. 10. Defendant, Geraldine Sheridan, was subsequently cited and plead guilty to disobeying traffic control devices. 11. Defendant owed a duty to Plaintiff, Rosa Miller, and other lawful users of the roadways in the Commonwealth of Pennsylvania to operate the vehicle she was driving in such a way as not to cause harm or damage to said other persons and to the Plaintiff in particular. COUNTI ROSA MILLER v. GERALDINE SHERIDAN 12. Paragraphs 1 through 11 of Plaintiffs' Complaint are incorporated herein by reference as if fully set forth. 479545-1 13. The aforesaid collision was the direct and proximate result of the negligence of the Defendant, Geraldine Sheridan, in operating the 2000 Pontiac Grand Am in a careless and negligent manner as follows: a. In failing to keep proper lookout for other vehicles lawfully operating on Hollow Brook Road; b. In failing to remain within her lane of travel on Hollow Brook Road; c. In failing to operate said vehicle at a speed that would allow her to stop her vehicle before hitting Plaintiff's vehicle; d. In failing to operate her vehicle in such a manner as to allow her attention to be diverted from road conditions ahead of her, thereby causing the collision; e. In failing to have her vehicle under proper and adequate control under the then existing circumstances; f. In failing to maintain a proper lookout for other vehicles or changing road or weather conditions; g. In failing to apply her brakes in sufficient time to prevent the collision; h. In failing to use due care and caution or reasonable judgment under the existing road conditions. i. Failing to obey traffic control devices in violation of 75 Pa. C.S.A. §3111 and applicable law; j. Failing to keep eyes on the roadway; k. Failing to slow or stop the vehicle she was operating so as to avoid a collision; 1. In operating the vehicle at an excessive rate of speed under the circumstances in violation of 75 Pa. C.S.A. §3361 and applicable law; m. Operating her vehicle in careless disregard for the safety of persons and/or property in violation of 75 Pa. C.S.A. §3714 and applicable law; n. Operating her vehicle in reckless disregard for the safety of persons and/or property in violation of 75 Pa. C.S.A. §3736 and applicable law; o. In failing to give warning to Plaintiff, Rosa Miller, of her impending collision with Plaintiff's vehicle; 479545-1 P. In failing to keep alert and maintain a proper lookout for the presence of other motor vehicles on the streets and highways; q. In failing to familiarize herself with the roadways and her surroundings; r. In not paying attention to her surroundings; s. In failing to keep his vehicle under proper and adequate control so as not to expose other users to an unreasonable risk of harm; and t. Colliding with Plaintiffs vehicle. 14. As a direct and proximate result of the collision and the negligent and careless conduct of Defendant, Plaintiff, Rosa Miller, sustained and in the future may sustain, serious and debilitating injuries, some of which are or may be permanent, and/or an aggravation and/or exacerbation of pre-existing conditions, and which include, but are not limited to, the following: a. Concussion; b. Left arm contusions/abrasions; c. Right knee pain/injury; d. Left shoulder pain/injury; e. Back pain/injury; f. Right leg pain/injury; g. Nose pain/injury; h. Head pain; i. Migraines; j. Blurry vision; k. Panic attacks; 1. Anxiety; m. Difficulty sleeping; n. Memory loss; 15. As a direct and proximate result of the aforesaid collision, negligence and carelessness of Defendant, Geraldine Sheridan, Plaintiff, Rosa Miller, has undergone and in the future will undergo physical pain, mental anguish, discomfort, inconvenience, distress, embarrassment and humiliation, past, present and future loss of her ability to enjoy the pleasures of life and limitations in her pursuit of daily activities. 479545-1 16. As a direct and proximate result of the aforesaid collision, negligence and carelessness of Defendant, Geraldine Sheridan, Plaintiff, Rosa Miller, has and/or may in the future incur expenses for medical treatment and rehabilitation for which damages are claimed. 17. As a direct and proximate result of the aforesaid collision, negligence and carelessness of Defendant, Geraldine Sheridan, Plaintiff, Rosa Miller, has and/or may in the future incur a loss of wages, a loss of earning capacity, loss of household services and other economic damages for which damages are claimed. 18. As a direct and proximate result of the aforesaid collision and the negligence and carelessness of Defendant, Geraldine Sheridan, Plaintiff, Rosa Miller, sustained incidental costs and losses to include, but not limited to, past and future medication costs and medical appliances. 19. Plaintiff, Rosa Miller, was the insured on a policy of insurance issued by Progressive Insurance bearing policy number 17439298-3 which was in effect on the date of the above-referenced collision. Plaintiff selected the full tort option regarding that policy. Therefore, Plaintiff, Rosa Miller, remains eligible to claim compensation for non economic loss and economic loss sustained in this collision pursuant to applicable tort law. WHEREFORE, Plaintiff, Rosa Miller, demands judgment in her favor and against the Defendant, Geraldine Sheridan, for the aforesaid damages, which exceed the limits for compulsory arbitration in Cumberland County, plus interest and/or damages for delay and costs of prosecution. COUNT II ROBERT MILLER v. GERALDINE SHERIDAN 20. Paragraphs 1 through 19 hereof are incorporated herein by reference as if fully set forth. 479545-1 21. During all relevant times Plaintiffs, Rosa Miller and Robert Miller, were husband and wife, and solely as a result of the collision, the aforesaid negligence, carelessness and recklessness of Defendant and as a result of the injuries to Plaintiff, Rosa Miller, the Plaintiff, Robert Miller, has been deprived of the assistance, companionship, consortium and society of his wife and has lost her services to him which may continue indefinitely. WHEREFORE, Plaintiff, Robert Miller, demands judgment in his favor and against Defendant, Geraldine Sheridan, for the aforesaid damages in an amount in excess of the limits of compulsory arbitration in Cumberland County, Pennsylvania plus interest and/or damages for delay and costs for prosecution. Dated: 0 1.2(- (1 Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: ?? s4c6c?2 achary . Campbell, Esquire Atto y 1. D. No. 93177 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiffs 479545-1 VERIFICATION I, Rosa Miller, hereby certify that the following is correct: The facts set forth in the foregoing Complaint are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Complaint is that of counsel and not my own. I have read the Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Complaint is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Dated: 10P U I Rosa Miller 479545-1 VERIFICATION I, Robert Miller, hereby certify that the following is correct: The facts set forth in the foregoing Complaint are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Complaint is that of counsel and not my own. I have read the Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Complaint is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Dated: (--)12101 Robert Miller 479545-1 CERTIFICATE OF SERVICE I, Zachary D. Campbell, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and correct copy of a, Complaint with reference to the foregoing action by certified mail, postage prepaid, this L day of October, 2011 on the following: Geraldine Sheridan, Defendant c/o George H. Eager, Esquire Eager, Stengel, Quinn & Sofilka 1347 Fruitville Pike Lancaster, PA 17601-4001 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. i achary ampbell, Esquire 479545-1 0 FILED-C FFIGE CF T1;'E PR TH0N0,T;Ar 2011 NOV 22 PM 12: 3 7 METZGER, WICKERSHAM, P.C. CUMBERLAND COUNTY By: Zachary D. Campbell, Esquire PENNSYLVANIA Attorney I.D. No. 93177 3211 North Front Street P.O. Box 5300 Attorneys for Plaintiffs Harrisburg, PA 17110-0300 Rosa Miller and Robert Miller (717) 238-8187 ROSA MILLER and, IN THE COURT OF COMMON PLEAS OF ROBERT MILLER, Individually CUMBERLAND COUNTY, PENNSYLVANIA and as husband and wife, Plaintiffs NO. 2011-7293 vs. CIVIL ACTION - LAW GERALDINE SHERIDAN, Defendant JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO DEFENDANT'S ANSWER WITH NEW MATTER 22. Paragraph 22 is an incorporation Paragraph and no reply required. To the extent a reply is required, Defendant's Answer is admitted to the extent that it admits the allegations contained in Plaintiffs' Complaint. Defendant's Answer is denied to the extent that it denies the allegations contained in Plaintiffs' Complaint. 23. The averments contained in paragraph 23 of Defendant's New Matter are denied as conclusions of law to which no reply is required. If a reply is required, the averments are specifically denied and denied pursuant to Pa.R.C.P. No. 1029(e). By way of further reply, the Defendant has failed to identify the defenses allegedly available to her pursuant to the Pennsylvania Motor Vehicle Financial Responsibility Law and, as a result, Plaintiffs cannot more specifically reply to Paragraph 23 of Defendant's New Matter. By way of further reply, Plaintiffs are not barred by any provision of the Pennsylvania Motor Vehicle Financial 482172-1 I Responsibility Law and Defendant is not provided any defenses to any of the claims raised in Plaintiffs' Complaint which is incorporated herein by reference. Strict proof of the same is demanded. 24. Conclusions of law, no reply required. If a reply is required, the averments are specifically denied and denied pursuant to Pa. R.C.P. No. 1029(e). By way of further reply, the civil action was filed against the Defendant prior to the expiration of the applicable statute of limitations. By way of further reply, the accident at issue occurred on October 15, 2009 and the earliest possible statute of limitations expiration would occur on October 15, 2011. The Writ of Summons was filed with the Cumberland County Prothonotary on September 21, 2011 and was served upon the Defendant on September 26, 2011. The Defendant has no good faith basis to raise the statute of limitations defense in this Matter. 25. Conclusions of law, no reply required. If a reply is required, the averments are specifically denied and denied pursuant to Pa.R.C.P. No. 1029(e). By way of further reply, the Plaintiff has alleged in Paragraph 19 of her Complaint that she was covered under a motor vehicle policy issued by Progressive Insurance which provided full tort coverage, allowing Plaintiff to claim compensation for non economic loss, including pain and suffering, and economic loss sustained in the collision pursuant to applicable tort law. 26. Conclusions of law, no reply required. If a reply is required, the averments are specifically denied and denied pursuant to Pa.R.C.P. No. 1029(e). By way of further reply, Defendant has not specified what benefits would be precluded and the specific provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law which would preclude the recovery of such benefits and Plaintiff cannot more specifically reply. Plaintiff agrees that she cannot 482172-1 recover first party medical benefits paid by her automobile insurance but she can recover any amount unpaid and/or in excess. 27. Conclusions of law, no reply required. If a reply is required, the averments are specifically denied and denied pursuant to Pa. R.C.P. No. 1029(e). By way of further reply, it is Defendant's burden of proving such defenses and none of the defenses would apply to this civil action. By way of further reply, the Defendant does not have a good faith basis to raise any of these asserted defenses. WHEREFORE, Plaintiffs, Rosa Miller and Robert Miller, respectfully request that Defendant, Geraldine Sheridan's, New Matter be dismissed and that judgment be entered in their favor and against Defendant as requested in the Complaint filed in this action. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Dated: By: ?Zachar'O. Campbell, Esquire Attorney I.D. No. 93177 3211 North Front Street Harrisburg, PA 17110 (717) 238-8187 (717) 234-9478 (fax) Attorneys for Plaintiffs 21 , 2011 482172-1 VERIFICATION I, Rosa Miller, hereby certify that the following is correct: The facts set forth in the foregoing Reply to New Matter are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Reply to New Matter is that of counsel and not my own. I have read the Reply to New Matter, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Reply to New Matter is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Reply to New Matter are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Dated: IY2,1 Rosa Miller 482172-1 VERIFICATION I, Robert Miller, hereby certify that the following is correct: The facts set forth in the foregoing Reply to New Matter are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Reply to New Matter is that of counsel and not my own. I have read the Reply to New Matter, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Reply to New Matter is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Reply to New Matter are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Dated: / / 21 / // // / obert Miler 482172-1 CERTIFICATE OF SERVICE I, Zachary D. Campbell, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and correct copy of Plaintiffs' Reply to Defendant's Answer And New Matter with reference to the foregoing action by first class mail, postage prepaid, this/,L_ day of 2011, on the following: Defendant Geraldine Sheridan c/o George H. Eager, Esquire Eager, Spinello, Quinn & Stengel 1347 Fruitville Pike Lancaster, PA 17601 ary D. Campbell, Esquire 482172-1 ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROSA MILLER and ROBERT MILLER, Individually and as Husband and Wife, Plaintiffs V. GERALDINE SHERIDAN, Defendant NO 11-7293 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served an original of Defendant's Loss of Consortium Interrogatories Addressed to Plaintiffs upon the person set forth below angHn tle manner indicated: N vi .rri :C" First class mail, postage pre-paid: tv ?; Zachary D. Campbell, Esquire Metzger, Wickersham, Knauss & Erb, P.C. ^ c ?-= 3211 North Front Street N ?._. }:` P.O. Box 5300 Harrisburg, PA 17110-0300 EAGER, SPINELLO, QUINN & STENGEL go ?a DATE: O/A BY: 1347 Frui ille Pike Lancaster, PA 17601 (717) 290-7971 George H. Eager sqi Attorney for D ndant I.D. No. 2 ire 77 0EGINAL ?., 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROSA MILLER and ROBERT MILLER, Individuaky and as Husband and Wife, Plaintiffs NO 11-7293 V. GERALDINE SHERIDAN, Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certifies that: (1) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: / George H. Eager, E ire t Attorney for Defere I.D. No. 27740 1347 Fruitville P Lancaster, PA 17601 (717) 290-7971 PENNSYLVANIA COURT OF COMMON PLEAS 1 COUNTY OF CUMBERLAND Rosa Miller And Robert Miller, Individually and as Husband and Wife, Plaintiffs Court of Common Pleas VS. Geraldine Sheridan, Defendant NO. 2011-7293 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Provider: Record Type: PRISM All available Partners in Women's Health All available Pennsylvania Neurological Associates, Ltd. All available Heritage Diagnostic Center All available Arthritis Center All available Family Eye Care, P.C. All available Susquehanna Valley Surgery Center All available Quantum Imaging All available Holy Spirit Hospital Radiology Holy Spirit Hospital Medical Carlisle Regional Medical Center All available Drayer Physical Therapy All available Good Hope Family Physicians All available Cumberland Valley School District Employment TO: Zachary D. Campbell, Esquire note: please see enclosed list of all other interested counsel Litigation Solutions, LLC ('LSLLC') on behalf of George H. Eager, Esquire intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Date of Issue: 2/1!2012 Litigation Solutions, LLC on behalf of: CC: George H. Eager, Esquire of Eager, Stengel, Quinn & Sofilka - Court of Common George H. Eager, Esquire Pleas Defense If you have any questions regarding this matter, please contact: Litigation Solutions, LLC (412.263.5656) Brentwood Towne Centre 101 Towne Square Way, Suite 251 Pittsburgh, PA 152?7 COUNSEL LISTING FOR ROSA MILLER AND ROBERT MILLER, INDIVIDUALLY AND AS HUSBAND AND WIFE, PLAINTIFFS VS! GERAEDINE SHERIDAN, DEFENDANT County of CUMBERLAND Court of Comrnon Pleas Counsel Firm Counsel Type Campbell, Esquire, Zachary 3211 North Front Street P.O. Box 5300 Harrisburg FA 17110 P: 717-238- Opposing Counsel D. 8187 F:717-234-9478 PIrYF;YL'r:Q Mull M OF (1111 13. MAJ Z' Rosa Miller AND Robert Miller, ?rllr Individually and as Husband and ? - y Wife, Plaintiffs vs. Geraldine Sheridan, Defendant SUBPOENA 14 MODUCE DOCUMNTS OR. TE NGS FOR DISCOVERY PUSUANT TO RULE 400.22 TO: (Nmu of Passut or Entity) Witten twenty (29) days xfter service of this subpoena. you are ordered by the cenrt to pra?auce the fakwing docami uts or WOO: ATTACHED RIDER at 51 Pittsburgh, PA 1522-7 (Addmu) You may dotivcr or mad legible copies of the documaats or pro • to ftV requctdx9 by tW subpoeaa, togother with the certificate of 00iar2Ct° to the party maki at the xddrtss listed &ove, you have thcti;ht to s >z is aclirmce the reasonable cost ofpreganng? topies or producing the Wags sought. ° if you fig to per dum the docu ats or tit required by Ws subAm Vein twenty (20) days afar att service, the patty scrviuz this subposiu my wek a vowt order caaopel'g you to comply with it TIMS SUBPOE A. WAS ISSUED AT THE F.BQUBST OF M FOLLOWD10 PE SOV: NAhm• o u F?aar_ Esquire ADDRUS,-. Pike nn---?'rf19 .}gyp ?PHONE:- C cT"`x x r? .. „ SUPRE M 6IOMT MA ATToRNBY MR: n _ - BY THE CUtJP.T: prothonotary, Civil Division Dab., o -11, seal of the vrt Delsuuty Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Arthritis Center 1845 Center Street Camp Hill PA 17050 Attention: Records Department Subject: Miller, Rosa SS#: 2793 Date of Birth: 08/06/1969 Requested Items: Please remit any and all first consultation reports, office notes, MRI, CT and x-ray films -and reports, test results, physical therapy reports, nurse's notes and doctor' s orders, along with any and all other medical records concerning Plaintiff Rosa Miller from 1/1/2000 to Present. :01v0,'K-14'W- 7l H Or F271"124S L 1tl"rla . Rosa Miller AND Robert Miller, Pik tip Individually and as Husband and Wife, Plaintiffs vs. , Geraldine Sheridan, Defendant SUBPOENA TO PRODUCE DOCU NTS OR TRMGS FOR AISCCOMY PURSUAM TO RULE 4009,22 TO: enter (Nam of Pmotc or En Sty) Wi&k iftnty (20) day.- after service of this v6poenz, you are ord"ad by the court to product tha W(owiog dommmtt of tbinga: E ATTACHED RIDER auite, 251 Pittsburgh, PA 15227 8t (Addr+essj You may deliver or mail legible ropier of the docatsata or pro?ds tk9ngs tegtte?ed 4.y this xuEpaeru<, to$etlu?c with tba certi5ca0t of ?, to the parry mal:iz?g ti1161 watt a# the address listed AWVe- You have the right to mk in adva=e the raasoaable cost of prep azv 1?,k6e copies or producing the tbsags sought: ! If You W to prodwA tits d0ewn nts Of tbinP fequivW by this subp? within twenty (20) days &far .its service, the patty mvin this subposua may'suk a court order connpel-g you tre conVjy with it M SUBPOENA WAS ISS i AT THE REQUEST OF TEES FOLLOW DIG PFRSCAJ: r o„ no u Rarrcr_ Esquire Mbffl- TELVEOM: a n 0 7 1. SUPUMB COURT V # A,Tol Y w POP- 1-4 40, Q BY THE CrJURT: \j ! i? 3 Ptoftnotam Civil Division v. Date: I 'P'o /I.,) Pf the Coat may r Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Carlisle Regional Medical Center 361 Alexander Spring Road Carlisle PA 17015 Attention: Records Department Subject: Miller, Rosa SS#: 2793 Date of Birth: 08/06/1969 Requested Items: Please remit Pertinent file including, but not limited to: (1) admission and discharge information (2) consultation reports (3) history and physical examinations (4) operative and pathology reports (5) emergency/outpatient records (6) rehabilitation medicine (PT, OT, speech) (7) MRI, CT and x-rte records and films on Plaintiff; also to be included are pain clinic records and mental health records from 1/1/2000 to Present. J , Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Cumberland Valley School District 6746 Carlisle Pike Mechanicsburg PA 17050 Attention: Human Resources Department Subject: Miller, Rosa SS#:2793 Date of Birth: 08/06/1969 Requested Items: Please remit Application for employment, pre-employment physical, date employment began, workers' compensation claims and medical reports, performance evaluations, year end payroll records for each year of employment, disciplinary notices, leave of absent dates and reason for leave and date of termination on Plaintiff from 11112000 to Present. •..:°.?lYtl?t?•2eV?''„«A1.. ? 1? ?.Jr i???'??? `r L s. ?.Ys1?Lta ('"'O Irr. or" Rosa Miller AND Robert Miller, X422. Individually and as Husband and Wife, Plaintiffs vs. Geraldine Sheridan, Defendant SUBPOENA TO PRODUCE DOCUMNTS OR. TRM(;S FOR DISCOVERY PURSUANT To RLgX 4009.22 TO: ,.po t°'.f:.c31 ThPrajo v ..w. ?............?. . (Nam ofPaton or Entity) WiWo twenty (20) dar after service of that tubpoana, You are ordered by the court to produce the followiAg docwmts or things: EE ATTACHED RIDER Way, cite 251 Pittsburgh, PA 15227 It . , (Address) You may Wiver or wAA legihk copies of the domm;euts or prod•?ge', things requosted by this suhpoetvt, togethat with the cergeste of tomphauee, to the, putt r=hnS quest at the address listed above. You have the right to seek is advance the reasonable cost of preparing a copies or producing the things sought ?? If you fag to piodum the doe mints or things nquiM by this suhpl?aa wift twetY (20) dayr ai tar its service, tha party servit this subpoena rrtay seelk a court order covrpicUpg you to couply with it TIMS SUBPOENA WAS LSSM AT THM REQUEST OF nM FOLLOWING PEMIT: NAME: c1rr7? _?? RA a Pr Esquire ADDIMS: "REM ODURT ID 0 AMMW F'DR: BY THE ODURT: Prothonotary, Civt1 DMSioa Date: ?a Seal of the Court p? Rider to?Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Drayer Physical Therapy 3 Jennifer Court Suite A Carlisle PA 17015 Attention: Records Department Subject: Miller, Rosa SS#:2793 Date of Birth: 08/06/1969 Requested Items: Please remit any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor's orders, along with any and all other medical records concerning Plaintiff Rosa Miller from 1/1/2000 to Present. Rosa Miller AND Robert Miller, Fae 11'. Individually and as Husband and n - 4 -7 ?Q Wife, Plaintiffs vs. ; Geraldine Sheridan, Defendant SUBPO.RK& TO PRODUCE DOCUMENTS OR THMGS FOR DISCOVERY PURSUANT TU RULE 4009,22 . '°Q: -hQn (z r i Ct (14am 00mu or Batity} Within, MtrAy (20) days after servict of this subpoena, -you are ordered by the court to pro?iuec the folLowia$ docurceatx or things: TTACHED RIDER It '- ."' waw__ _ ?,i;-te 251 Pittsburgh, PA 15227 (Address) You may detiver or nub 4116 copies of the documem or pradt O*qs requester) by this sul+poma, togat3aer with the certificate of see, to the party mnlcin? ti ' ai the address listed .quW above. You bim the right to seek in advance U rananable cost of preparing, copies or producing the thins sougbt r f if you 20 to prodwe tbt documents or thus required by this su'bpliema wift two* (20) days after.itt service, tk patty =vial this subpoena =y :tek a C.6vrt order aorapelbng you tri cataply wia it THIS SUBPOMrA WAS MOM AT TRHPAUEST OF THE FOLLt7WRT a PERSOR, HANS: "quire ADDRBSS° _ _ ,zz , e 1 -7 if () I 'IET I$Cn't8: _ -7 1 AT .L Vaell ii L POP BY Tn MURT. Protboaatary, `jy'j Divisiott .w Diu, Sw of ft Gout gouty, •:?IvQri:'..r?v?e't'?..?,i, a H r.?r P??dS? ?,.'; 6?fta=. Rosa Mil.ier AND Robert Miller, Individually and as Husband and Wife, Plaintiffs vs. Geraldine Sheridan, Defendant SUBPORNk TO PRODUCE DOCUMNTS OR. TRWGS FOR DISCOVER. PURSUANT To RULE 4009,22 TO: (Nmo of Pallor` or Entity) Vrttbim twenty (207) dayr after tervica of this subpoem, you are ore3ared by the roiart to produce ttte faHoWing d CUmetttl or +things: F F u nr_ncJZ SRF ATTACHED RIDER It n 25.1 Pittsburgh, PA 15227 Address) you may deliver or =a legible copies of tba dccummu or pro .. d&ts regaaded by this tubpoags„ togedw wi& tba certificate of compliance, to the party m?lciag tl uest at the address hsted eve Y ve t2te right to teak is advance the teaxanable cost of prepacopies or praducimg the :o I if yota .fail to produce tha driamtoutt or things required by this subpbsaa v iitlain twaty (20) days, after .its servim, the panty xeavin this subpoena may seek a cnurt order cotupal g you to comply with it TIM SUBPO A WAS ISSN AT THE R.BQT:ILST OF THE FOLL OW11T 3 PERSON: HAMS.-----?re???e Fesquire ADDBMS - , E. ,_e ?TELEP80N8: SU Fina C`A[T?T' w o ATT RNW P®R - - - - - BY THE C LMT. Protlaanotaty, t.''nl Divittau r??te: ?a la ? 4L - 1 of the Cavrt1-" fleputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Family Eye Care, P.C. 5012 Carlisle Pike Mechanicsburg PA 717-763-2020 Attention: Records Department Subject: Miller, Rosa SS#: 2793 Date of Birth: 08/06/1969 Requested Items: Please remit any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor's orders, along with any and all other medical records concerning Plaintiff Rosa Miller from 11112000 to Present. CoU3!M, 10F CTAI-MERZ.Ad z; Rosa Miller AND Robert Miller, :ueltt. Individually and as Husband and ?.Ll,L1,2?.?•.... Wife, Plaintiffs vs. Geraldine Sheridan, Defendant SUBPOENA TO PRODUCE DOCUM N TS OR TEIGS FOR DISCOWRY PUItMC3ANT TO RULE 4009.22 '` c i an s (14vm of Paton or Eudty?) W-I&k twenty (20) days after scrvica of Gis subpoena, you are ordered by the court to prate the follooritsg doe cots ar tbinp: a e EASE SEE ATTACHED RIDER At nj TnwnP Snuare Wav,_ Suite 251 Pittsburgh, PA 1522 (AAdit:g) . ` thugs requested by tlcis You my deliver or imil Imble copies of the doewnew or pro t suf?poaa, together roc+itl? fhe cerdfieata of cotliance, to the ptrtY ig tlu ai the addxzss lic#ed above. You ha-,,es the to seek in advance 1he reasonable cost f prcpanng` copies or Mducing the adup soug,2it If you fail to pmduea dt dom=ents at thiiags mgquirW by this subpba na witWa twenty (20) days after ats service, the party UP W this subporzta uny Seek a tort order compelog you to comply with it TMS SUBPQERA WAS USM AT THE PIQUEST OF THE FOL LOVMT y PE.R. OV: Esquire aIMMS• n ,g,a' 4 t?,a i 1„ e t LEFHt?hTE: ?7 , - n - SUPREM COM ED g -7 -7 4 f) ATTOMEY PM. EY THE ODWT: Pmthaaotary, ()VviDivision Date. Sea n of tiu Caurt, kider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Good Hope Family Physicians 1830 Good Hope Road Enola PA 17025 Attention: Records Department Subject: Miller, Rosa SS# : 2793 Date of Birth: 08/06/1.969 Requested Items: Please remit any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor I s orders, along with any and all other medical records concerning Plaintiff Rosa Miller from 1/1/2000 to Present. Jlvfh1.',??'yN*V,TL i H OF Px?I1RId."a,? L? :5 f'a'te Rosa Miller AND Robert Miller, -pd9-r--??? Individually and as Husband and Wife, Plaintiffs vs. , Geraldine Sheridan, Defendant SUBPOENA TO PRODUCE DOCUM NTS OR TMGS FOR DISCOVERY PURSUANT TO RME 4¢04,22 TO: 2i agnQat-i c; r (Nam of P=a a or Eality) -- Widda twenty (2T) days after sm vk6 of this subpoena, you are ordered by the court to produce the Mowing ddaua2aats of things. PTEASE SEE ATTACHED RIDER At , n, m,...,r- c r„aYP Wav. _sui_te 251 Pittsburgh, PA 15227 You may deliver or snail legible copies of the locum ats or prodgj • things requcsted by this ;vlgotna, toga~tdae r with tine ctztificatt of to the party making flu at the address listed ahove. You have the right to seek in advance the reasonable cost of preparsag; copies or producing the dams sought: f If you fan? to pt*daua t1* documents or things vcquired by this subptum witbin twenty (20) days aijer its service, the putty serving dais subpoena may seek a court order coagwj iug you t?comply with it THIS SLIBPMFA WAS ISSUED AT THE F.EQUEST OF TEES FOLLOWIttta PERSIDIT: ?•IAME: C Qr,rgc, U _ FanPr, Esquire SU ima COURT ID # n n AMRMY FOR: BY THE ODURT. Prothonotary, Civa Division Dde, JEL seal f the court D ?, Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Heritage Diagnostic Center 3 Walnut Street Suite 100 Lemoyne PA 17043 Attention: Records Department Subject: Miller, Rosa SS#:2793 Date of Birth: 08/06/1969 Requested Items: Please remit any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor's orders, along with any and all other medical records concerning Plaintiff Rosa Miller from 11112000 to Present. . `. iS rfi.lk?rtIV''Fr ?YJ ?1..? ". C (.')i1Iri': t.1F Cbl'2E L,I-,I Z; Rosa Miller AND Robert Miller, Put lit.. Individually and as Husband and Wife, Plaintiffs VS. Geraldine Sheridan, Defendant SUBPOENA TO MODUCE DOCUMENTS OR THNGS FOR, DISCOVERY PURSUANT TO RU'I,E 400.22 'I'CS= _,....?. ? e . (Nam ofPersou or Entity) Widia twenty (20) days after service of this subpoena, you are ordcied by fle court to prcduce: the following docurnettts at thiags: PLERSESEE AT"TACHED RIDER at , n, m c.rr v grmAre Wav,_ _Suite 251 Pittsburgh, PA 15227 (Address) You may detivtr or mail legible copies of the documents or profit things reque,°tad by this subpoena, together with the certiEcate of colx*&I re, to the party making tlul '' qQuad at the address listed *bye. tou have the right to sack its advance the reasonable cost of preparingtthe copies Dr producing the things aeught. If you fail to produce the docummIs or d dzp required by this subp a within twenty (20) days after its service, the party'sesviag this sutporea MY seek a rrtrrt order' camped you to covey with it TMS SUBPOWA WAS I.q UED AT THE REQUEST OF THE FOLLOWDIG PERSON: Esquire ADDRESS. , --2 Ati U-a -- _s,l 7-0 .p; k e "REM COURT Ili # An-ORM FOIU ___z BY T"" CrjURT: Prothonotary, nh7 Division Daft:-- seal d -the D eputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Holy Spirit Hospital 503 North 21st Street Camp Hill PA 17011 Attention: Radiology Films Library Subject: Miller, Rosa SS#: 2793 Date of Birth: 08/06/1969 Requested Items: Please remit: Complete copy of any and all diagnostic films, film lists and film reports from 1/1/2000 to present, including X-Rays, MRI, and CT scans. w= Ivfl-11W?I i. x (,ti PE NS Y 3.4 : t r C. "D U rl, :.)F t'M"sER%.&.1rF Rosa Miller AND Individually and Wife, Plaintiffs Robert Miller,„ *ir as Husband and `ur °. n1 - ?`.....??...w vs. Geraldine Sheridan, Defendant SUBPOENA TO PRODUCE DOCUMNTS OR. TAGS FOR DISCOVERY PURSUANT TO PVLE 4009,22 TO; ical (NxmofPerson or Eatity) Wsthiutmuty (20) days after service of Ibis subpom, you are ordered by the court to produce the following documents at things: : t S SEE ATTACHED RIDER at '1 01 T?s?nP '!Q3jAre Inlay quite 251 Pittsburgh, PA 15227 M (Addrtss) You may deliver ar Wail leg:'blo copies of the documents or proch thugs requestad by thus 240aaa, togethu with the certificate of MMPW=, to die party making t4 : *ett at tha addCrass listed above, You have the tight to =k in advance W reasaaable last of prepare copies or producing the things sought. If you fail to pwdue the dommuts or thiWtequired by this summa within twenty (20) days after its sm ice, &a party urvingg this subpoena may aetk a court order campr4mg you to comply with it THIS SUBPOWA WAS ISSUES AT THE PIQUEST OF THE FOLLOW111(3 FFMOJI: squire ADDRBSS: ;;44 PY ; 1-.'. Pi ke DA 1'7 Fn l_ t TEVEC3NE -, ? -2 CLQ 7 2 -7.1 SUPREME COURT ID 0 ArrMMY FC)R BY THE COURT: Proftnotery; c'ivi'l Division Date: S l Of the Court p'-puty Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Holy Spirit Hospital 503 North 21st Street Camp Hill PA 17011 Attention: Medical Records Correspondence Subject: Miller, Rosa SS#: 2793 Date of Birth: 08/06/1969 Requested Items: Please remit Pertinent file including, but not limited to: (1) admission and discharge information (2) consultation reports (3) history and physical examinations (4) operative and pathology reports (5) emergency/outpatient records (6) rehabilitation medicine (PT, OT, speech) (7) MRI, CT and x-ray records and films on Plaintiff; also to be included are pain clinic records and mental health records from 11112000 to Present. Rosa Miller AND Robert Miller, Individually and as Husband and k -•-- Wife, Plaintiffs VS. Geraldine .Sheridan, Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THMGS FOR DISCOVIRY PURSUANT TO RULE 4009.22 nTnk (Name of Parson or Entity) WiWu ftenty (20) da r. after setviee of this' subpoaas, you are ordered by the r curt to prochm the fallowing doceuattentt ar things: - s ATTACHED RIDER at (zavarP-_7jtasz___Silito 251Pittsburgh, PA 15227 -- - _- z - - - (Addms) You may delivet or mail kVb),e copies of the documeatc or pr All thugs requested by this s ibpoc=4 togetha with &a califcate of compHsnce, to the party making tTx?r quest at the address listed sbova. You bats the right to seek in advance the reasonable mst of preparm" copra or prod== the ftitgs sought If you fail to produce tba dommeaW or tbivp rcqusred by tlxis subpl?ma within twenty (20) days ai r its sexvice, the petty mviq d is subpoena may seek a court or&r c=Vcj ug you to coadtaly with it n O SUBPOEMA WAS ISSUED AT'TFM P IQ EST OF THE FOLLOWD TO PERxSOfir: NAME: qu i r e .ADDRESS: - 11 R--a? e I ;Rom. S. CCOVKi .W # -,a- 7 7 A?n? ATIOPNBY FUR BY Tn COt1It,'T: Q L? ?? Frotl:onotaty, Civil Division Drte: ? ? / ? --- S 1 of tbi court f}? i'tider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Partners in Women's Health 5 Brookwood Avenue Carlisle PA 17015 Attention: Records Department Subject: Miller, Rosa SS#:2793 Date of Birth: 08/06/1.969 Requested Items: Please remit any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor' s orders, along with any and all other medical records concerning Plaintiff Rosa Miller from 1/1/2000 to Present. 'v' 1iY1?.: ti`s O GM`Ct'{r i.-.t".Q- C•Oi rr. t t ? J?+ K3 ?l f Rosa Miller AND Robert Miller, l??. Individually and as Husband and Wife, Plaintiffs vs. , Geraldine Sheridan, Defendant SUBPORHA TO PRODUCE 1DOCU NTS OR TZ NGS FOR DISCOVERY PURSUANT TO RULE 400,22 Try; ical Associates, Ltd- (14=* of Pertou or Evtity) W j" t%mnty (20) d&yt after seavita of thin Mbporna, you art ordered by the court to proewm, the following doC9t1mutt or things: P E SE SEE ATTACHED RIDER at , nl 1T'nwnP_Srr11ar . Wave Suite 251 Pittsburgh, PA 15227 (Addrtss) You may deliver or MW legible copies of du docuaoents or pro thiaga requester by this subpoena, togetlur VA the cerliScsce of comp ance. to the pauty making thi n ' urxt at the address !dated shove. You !nave the right to seek is advance the reasonable cost of preparing a copies or producing the things sought if you h9 to produce tltt documcats or thiny,s ftquired by this sabpbi n& vvitbiA twenty (20) days after its saviee, tie putt-smviag this subpoena may seek a cayzt order compelOg you to comply with it. IMS SUBPO A WAS MUM AT'TMIQUEST OF TEES FOLLOWUM PERS?.?#?: 14ltME; no u _ EQaz, , Esquire ADDMS: --) n -7_-ems„ 1 P- P; k e TE UXONE: -7 1 -7 - StUPRRE? COU1TR°T FD g ?-7-7 a n l'kLlVFI?py a .C[,?,R4. Tlo f.an c r? ___.__ BY THE COLR.T: r? b? l.? Prothonotary, rival Division ge l- of dme Covit D Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Pennsylvania Neurological Associates, Ltd. 110 Lowther Street Lemoyne PA 17043 Attention: Records Department Subject: Miller, Rosa SS#: 2793 Date of Birth: 08/06/19E>9 Requested Items: Please remit any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor's orders, along with any and all other medical records concerning Plaintiff Rosa Miller from 1/1/2000 to Present. `??, Rosa Miller AND Robert Miller, Individually and as Husband and ---?••--?----- Wife, Plaintiffs vs. Geraldine Sheridan, Defendant SUBP+DRNA TO PRODUCE DOCUIXNTS OR. THINGS FOR DISCOVFRY PUBSUAN'T` TO RULE 4€ 09.22 TO: (Noma of Person or Entity) zFdidtin: twisty (20) dry: after service of this subpoma, you are ordered by the court to produce the fofl,owing d .ts at things: ZT,FLSE SEE ATTACHED RIDER It -I n l T__nA SrT„ara Way, suite 251 Pittsburgh, PA 1522`7 (Address) You may deliver or mail le-gible copies of the documcnta or prodqtb:iags requested by this n*poezv, togetbat with the certificate of compliance, to tha party making tb# ' at the address listed above. You have the right to sack in advance the reasonable cost of preparuigj a copies or producing the &ins9 sr If you fug to produce the &P=t?ta or thiW-requimd by this subp4m witbia twenty (20) dsys agar its servite, tlu party serving this subpoena may leak a cat.It order eompel#ng you tto'couvly with it TMS SUBPOM4A WAS ISSM AT THE PIQUEST OF THE FOLLOWING PJEESON: 1i,4?u1E: no a P.anPr,_ Esquire ADDRESS: ; } . , p e r nn 7_'7 r,01 - - MOM: SUPREME COURT ID 0 -7A n ATTI)7RNBY FUIt BY THE couRT Pmdmotaty, e`661 Division Date: ?)o Ll sear of the vet De puty Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: PRISM 175 Lancaster Boulevard Mechanicsburg PA 17055 Attention: Records Department Subject: Miller, Rosa SS#: 2793 Date of Birth: 08/06/1969 Requested Items: Please remit any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse's notes and doctor's orders, along with any and all other medical records concerning Plaintiff Rosa Miller from 11112000 to Present. w ??ltil?rf ?2?W,'x.?,L ? ? ?,?? PB'rr•fS'? ?.1'.??I'tr Rosa Miller_ AND Robert Miller, Individually and as Husband and Wife, Plaintiffs vs. Geraldine Sheridan, Defendant SU$P WA. TO MODUCE DOCUMENTS OR TH NGS FOR DISCOVXRY PURSUANT TO RULE 400.22 Nam of Person or Entity) Within twenty (20) day. after service of thin subpoenas, you are ordered by the court to produce the Mowing doeu=mts or things: LEASE SEE ATTACHED RIDER It Suite 251 Pittsburgh, PA 1522 ]Q1 way, (Address) YOU may deliver or avail 1e91bis copies of the documew or prgd things reue^tzd by tltit mbpoena, togethaa with the eery cats ofcaompDm, to the party taakinsr fb ;+ uc s q estedxs lifted the addre above. You have the right to sale in advance the reasaoable cost of prep ariag'tbe copies or producing the sought `y If you fat to produce tha doauments or d" p fequzred by this subPi 902 within twenty (20) days after ltt taviee, tha patty •s VW this su'bPOena trey seek a court order coarlulW, 1 you to comply with it T= SUBPO&-rA WAS MMM AT THE RIQUEST OF THE FOLLOWDIr-i PERSON: t*1A1 (P L - -T4- -F-a a,?U , E s qu i r e A)DIMS: t,; la L; ke T t'PY ]7 Z1 76n1 3- TP.LEFl?t71?E: ? ? 7 - ? a a- ? 9? SUPREME HURT 1D # 7 a n ATE FOR: w,.?.:_p ^. ?-..-. BY THE ODURT, -blwr -EUsL? P'rotbonotary, f"ivft Division Date: S "I a€ tha cenrt Deputy 4 Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Quantum Imaging 629-D Lowther Road Lewisberry PA 17339 Attention: Records Department Subject: Miller, Rosa SS#:2793 Date of Birth: 08/06/1969 Requested Items: Please remit any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurses notes and doctor's orders, along with any and all other medical records concerning Plaintiff Rosa Miller from 1/1/2000 to Present. •°;.?I?l?Y1?: Tr'y'?,%, a ? ?.?? PGCTtda^? L4 .4?'7`??, Rosa Miller AND Robert Miller, Individually and as Husband and t-72P3. Wife, Plaintiffs vs. Geraldine Sheridan, Defendant SUBPOENA. TO PRODUCE DOCUMENTS OR. TRWGS FOR DISCOVERY PURSUANT TO RULE 400.22 TO: Surgery Center 043x3 of Person or fintity) Withk twenty (20) days after service of thin subpoana, you are ordered by the court to produce the following docu uuta or things: j a Mr?rrr?YwY+rr ?. _ - LEASE SEE ATTACHED RIDER atjni Tnwne, cjQ"-r av, Suite 251 Pittsburgh, PA 1522 i (Address) -- - - You may deliver or mail legible copies of the documents or prodg' th** reques'tod 4y this mbpoena, togethat with the =ti'ficate of cam4lia=4 to the party audcing tl '. quest at the address Usted altnve. You have the right to seek is advance the reasonable tart of prep:riug?c copies or producing the things sough if you fQ to pwduca the documuts or tlsisiga segtsired by this subphew writhia twenty (20) days aRet its swict, tba party -serving this subpoena way ml* a alum order compeU'g you to comply with it TWS SUBPOMA WAS ISSUED AT TE P.&QUEST OF THE FOLLOWING PMON: t•I.kum: r P ta__ Fdae_r, Esquire ADD-?Mg: l '? A.'7 1-tr,i I I c, rr .__?JS_e AT1*01U1P7EY POP EY THE Cr MT: R22 Pwftnotary, Civil Division Date: l U l ,.? ?, P j -- l of the tourt Deputy Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Susquehanna Valley Surgery Center 4310 Londonderry Road Suite 1 Harrisburg PA 17109 Attention: Records Department Subject: Miller, Rosa SS#: 2793 Date of Birth: 08/06/1969 Requested Items: Please remit any and all first consultation reports, office notes, MRI, CT and x-ray films and reports, test results, physical therapy reports, nurse s notes and doctor's orders, along with any and all other medical records concerning Plaintiff Rosa Miller from 11112000 to Present. CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Francis J. Lafferty, IV, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 EAGER, STENGEL, QUINN & SOFILKA DATE: BY: George H. Eager, Esc Attorney for Defend I.D. No. 27740 1347 Fruitville P' e Lancaster, PA 17601 (717) 290-7971 METZGER, WICKERSHAM, P.C. By: Zachary D. Campbell, Esquire Attorney I.D. No. 93177 3211 North Front Street P.O. Box 5300 Attorneys for Plaintiffs Harrisburg, PA 17110-0300 Rosa Miller and Robert Miller (717) 238-8187 ROSA MILLER and, • IN THE COURT OF COMMON PLEAS OF ROBERT MILLER, Individually • CUMBERLAND COUNTY, PENNSYLVANIA and as husband and wife, • Plaintiffs • NO. 2011-7293 vs. • m o • CIVIL ACTION - LAW GERALDINE SHERIDAN, • `, • Defendant • JURY TRIAL DEMANDED (-) ' i f- N PRAECIPE TO SETTLE, DISCONTINUE AND END - °r TO THE PROTHONOTARY: Kindly mark the above captioned matter settled, discontinued and ended. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Zac . Campbell, Esquire I.D. No. 97133 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Date: 11:1 11? )2013 Attorneys for Plaintiff 536685-1 CERTIFICATE OF SERVICE I, Zachary D. Campbell, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a true and correct copy of a Praecipe to Settle, Discontinue and End with reference to the foregoing action by first class mail, postage prepaid, this V414 day of OCT- ,2012 on the following: Ms. Geraldine Sheridan c/o George H. Eager, Esquire Eager, Spinello, Quinn& Stengel 1347 Fruitville Pike Lancaster, PA 17601 METZGER, WICKERSHAM, KNAUSS &ERB, P.C. By: I► - ry .. Campbell, Esquire 536685-1