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HomeMy WebLinkAbout12-3163 L 1 ^+ LLP SHOLLENBERGER & ANUZZI , ? c4,, 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, Plaintiff V. NICOLE R. SHOWERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW NOTICE 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 entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 REDUCE FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE Q CARLISLE, PA. 17013 t03. r75-PO' At (717) 249-3166 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NICOLE R. SHOWERS, Defendant NO. CIVIL ACTION - LAW NOTICIA LE HAN DEMANDADO A LISTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomaro medidas y puede entrar una orden contra usted sin previo aviso o notoficacaion y por cualquier queja o alivio que es pedido en la peticion do demanda. usted puede perder dinero o sus propiededas o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI LISTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACI6N SOBRE LAS AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CORGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Lawyer Referral and Information Service CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA. 17013 (717) 249-3166 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, Plaintiff V. NICOLE R. SHOWERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW COMPLAINT AND NOW, comes the Plaintiff, Phillip Kiehl, by and through his attorneys, SHOLLENBERGER & JANUZZI, LLP, and respectfully represents the following: 1. Plaintiff, Phillip Kiehl, is an adult individual who currently resides at 289 Redwood Lane, Carlisle, Cumberland County, Pennsylvania 2. Defendant, Nicole R. Showers, is an adult individual whose last known address is 390 Middle Road, Aspers, Adams County, Pennsylvania 3. The facts and circumstances hereinafter set forth took place on November 11, 2010, at or about 4:37 p.m. on the exit ramp from State Highway 34, Exit 47A to State Highway 81 South. 4. At the aforesaid time and place, Plaintiff, Phillip Kiehl, was operator of a 1997 Harley Davidson FLSTC, bearing Pennsylvania Registration WHB58. 5. At the aforesaid time and place, Defendant, Nicole R. Showers, was the owner and operator of a 2000 Subaru Legacy, bearing Pennsylvania Registration FRK3070. 6. At the aforesaid time and place, Plaintiff, was stopped on the exit ramp from State Highway 81 South at Exit 47A attempting to merge onto State Highway 34 South in the aforesaid 1997 Harley Davidson FLSTC in Carlisle Borough, Cumberland County, Pennsylvania. 7. At the aforesaid time and place, Defendant, Nicole R. Showers, was traveling directly behind Plaintiff, Phillip Kiehl, also attempting to merge onto State Highway 34 South, and failing to stop, struck the motorcycle from behind causing Plaintiff, Phillip Kiehl to be thrown from the motorcycle. 8. As a result of the aforesaid incident, Plaintiff, Phillip Kiehl, has suffered serious and permanent injuries, including but not limited to the following: a. Right knee avulsion fracture; b. Severe strain and sprain of the muscles, tendons, ligaments and other connective tissues at or about the cervical spine; C. Severe strain and sprain of the muscles, tendons, ligaments and other connective tissues at or about the lumbar spine; d. Various contusions and abrasions including but not limited to the low back, mid back and right knee; e. Chest wall injury; f. Peripheral annular tears with broad based left central protrusions in the discs noted at the L5-S1 and L4-L5 levels; g. Herniated discs at the L5-S1 and L4-L5 levels; h. Aggravation of preexisting degenerative disc disease and/or spondylosis of the lumbar spine; and Aggravation of preexisting patellofemoral degenerative joint disease of the right knee. 9. The aforesaid collision was the direct and proximate result of the negligence of Defendant, Nicole R. Showers, in operating the 2000 Subaru Legacy in a careless, reckless, and negligent manner as follows: a. Driving at a speed greater than was reasonable and prudent under the conditions and having regard to the actual and potential hazards then existing and/or at a speed greater than would have permitted her to bring her vehicle to a stop within the assured clear distance ahead in violation of Section 3361 of the PA Motor Vehicle Code; b. In failing to have her vehicle under proper and adequate control; C. In failing to apply the brakes in time to avoid the collision; d. In failing to observe Plaintiff's vehicle on the highway; e. In failing to operate her vehicle in accordance with existing traffic conditions and traffic controls; f. In permitting or allowing the vehicle to strike and collide with the rear of the vehicle operated by the plaintiff; g. In failing to drive at a speed and in the manner that would allow defendant to stop within the assured clear distance ahead; and h. In failing to keep a reasonable look-out for other vehicles lawfully on the road. 10. As a direct and proximate result of the aforesaid injuries, Plaintiff, Phillip Kiehl, has undergone and in the future will undergo great pain and suffering for which damages are claimed. 11. As a further result of the aforesaid injuries, Plaintiff, Phillip Kiehl, has suffered and may continue to suffer a loss of earnings for which damages are claimed. 12. As a further result of the aforesaid injuries, Plaintiff, Phillip Kiehl, has and/or may in the future incur a loss of earning capacity for which damages are claimed. 13. As a further result of the aforesaid injuries, Plaintiff, Phillip Kiehl, has sustained a permanent diminution in his ability to enjoy life and life's pleasures for which damages are claimed. 14. As a further result of this collision, Plaintiff, Phillip Kiehl, 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, Phillip Kiehl, 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. Plaintiff, Phillip Kiehl, was occupying a motorcycle at the time of the collision, which is not a private passenger motor vehicle. Therefore, Plaintiff, Phillip Kiehl, remains eligible to claim compensation for non-economic loss and economic loss sustained in this collision pursuant to applicable tort law. WHEREFORE, Plaintiff, Phillip Kiehl, demands judgment against Defendant, Nicole R. Showers, for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. Date: 05, 15 1 2 Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP Attc By: ' Z 1 VERIFICATION hereby acknowledge that I am a Plaintiff in this action and that I have read the and that the facts stated herein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. 01 Sign e Date: X5:6- l2 G:\GLOBAL\WPDATA\DOCS\INITIAL CONSULT DOCS (SETUPS)\Verification.wpd SHOLLENBERGER 8 JANUZZI, LLP 2225 Millennium Way, Enola, PA 17025 (717) 728-3200 ! FAX (717) 728-3200 A. % k aL.v c1 I ig iij cu11 Mj -o AM 11: : JOHNSON, DUFFIE, STEWART & WEIDNER By: Jefferson J. Shipman p! IBERLAND COU* i I.D. No. 51785 pENINSY12VA IA, 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jjs@jdsw.com PHILLIP KIEHL, V. NICOLE R. SHOWERS, Defendant Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 12-3163 Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned on behalf of the Defendant in the above-captioned matter. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER J s n J. Shi an, Esquire Attorney I.D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Date: June , 2012 Counsel for Defendant 498863 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Praecipe for Entry of Appearance has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on June ?5, 2012: Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 JOHNSON, DUFFIE, STEWART & WEIDNER B Uon J. Ship an JOHNSON, DUFFIE, STEWART & WEIDNER By: Jefferson J. Shipman I. D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jjs@jdsw.com PHILLIP KIEHL, V. Plaintiff NICOLE R. SHOWERS, Defendant NO. 12-3163 Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Phillip Kiehl c/o Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 AND NOW, this day of June, 2012, you are hereby notified to plead responsively within twenty (20) days of the date of service hereof, or judgment may be entered against you. NIA Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHNSON, DUFFIE, STEWART & WEIDNER By r n J. Shipm n Attorneys for Defendant JOHNSON, DUFFIE, STEWART & WEIDNER By: Jefferson J. Shipman I . D. No. 51785 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jjs@jdsw.com PHILLIP KIEHL, V. Plaintiff NICOLE R. SHOWERS, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANT, NICOLE R. SHOWERS, TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Nicole R. Showers, by and through her counsel, Jefferson J. Shipman and Johnson, Duffie, Stewart & Weidner, and files the following Answer and New Matter to Plaintiffs Complaint: 1. Admitted upon information and belief. 2. Admitted. 3. Admitted. 4. Admitted upon information and belief. Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-3163 Civil Term 5. Admitted. 6. Admitted in part, denied in part. It is admitted that the Plaintiff was on the exit ramp from 81 South to 34 South. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 6, and the same are therefore denied. 7. Admitted in part, denied in part. It is admitted only that Ms. Showers was traveling and also attempting to merge onto 34 South and that there was a collision with the Plaintiffs motorcycle. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 7, and the same are therefore denied. 8. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 8, and subparagraphs (a) through (i), and the same are therefore denied and strict proof is demanded at the time of trial. 9. Denied. The averments contained in paragraph 9 and subparagraphs (a) through (h), are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. (a) Denied. It is specifically denied that Ms. Showers was traveling at a speed greater than what was reasonable and prudent under the conditions and having regard to the actual potential hazards then existing and/or at a speed that would have permitted her to bring her vehicle to a stop within the assured clear distance ahead, allegedly in violation of Section 3361 of the Pennsylvania Motor Vehicle Code; (b) Denied. It is specifically denied that Ms. Showers failed to have her vehicle under proper and adequate control; (c) Denied. It is specifically denied that Ms. Showers failed to apply the brakes in time to avoid the collision; (d) Denied. It is specifically denied that Ms. Showers was negligent in allegedly failing to observe the Plaintiffs vehicle; (e) Denied. It is specifically denied that Ms. Showers failed to operate her vehicle in accordance with existing traffic conditions and controls; (f) Denied. It is specifically denied that Ms. Showers was negligent in allegedly permitting or allowing the vehicle to strike and collide with the rear of the Plaintiffs vehicle; (g) Denied. It is specifically denied that Ms. Showers failed to drive at a speed and in a manner that would allow her to stop within the assured clear distance ahead; and (h) Denied. It is specifically denied that Ms. Showers failed to keep a reasonable look-out. 10. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 10, and the same are therefore denied and strict proof is demanded at the time of trial. 11. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 11, and the same are therefore denied and strict proof is demanded at the time of trial. 12. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 12, and the same are therefore denied and strict proof is demanded at the time of trial. 13. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 13, and the same are therefore denied and strict proof is demanded at the time of trial. 14. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 14, and the same are therefore denied and strict proof is demanded at the time of trial. 15. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 15, and the same are therefore denied and strict proof is demanded at the time of trial. 16. Denied. After reasonable investigation, the answering Defendant is without sufficient knowledge or information to form a belief as to the truth of the averments contained in paragraph 16, and the same are therefore denied and strict proof is demanded at the time of trial. WHEREFORE, the Defendant, Nicole R. Showers, respectfully requests that judgment be entered in her favor and that Plaintiffs Complaint be dismissed with prejudice. NEW MATTER 17. That Plaintiff fails to state a cause of action for which relief may be granted. 18. That Plaintiff's alleged cause of action may be barred by the Pennsylvania Motor Vehicle Financial Responsibility Law. 19. That Plaintiffs alleged cause of action may be barred by the Pennsylvania Comparative Negligence Act and the Assumption of Risk Doctrine. 20. That Plaintiffs alleged cause of action may have been caused by third parties or entities not presently involved in this action. 21. That Plaintiffs alleged cause of action may be barred by a sudden emergency and intervening superseding cause. 22. That if it should be found that there was any negligence on the part of Ms. Showers, which is denied, then in that event, any such negligence was not a factual cause of the happening of the accident nor Plaintiffs alleged injuries. 23. That Plaintiffs alleged injuries may have been pre-existing. 24. That Plaintiff may have failed to mitigate his alleged injuries. WHEREFORE, the Defendant, Nicole R. Showers, respectfully requests that judgment be entered in her favor and that Plaintiffs Complaint be dismissed with prejudice. Date: June / 2012 499175 Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By:( ers h J. Ship an, Esquire orney I.D. No. 51785 01 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Counsel for Defendant VERIFICATION The undersigned verifies that the facts set forth in the foregoing document are true and correct to the best of her knowledge, information and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsifications to authorities. Nicol R. Show s Dated: G :499190 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Answer and New Matter of Defendant has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on June _a_, 2012: Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 JOHNSON, DUFFIE, STEWART & WEIDNER By: Jeff o J. Shipma SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff PHILLIP KIEHL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NICOLE R. SHOWERS, Defendant NO. 12-3163 CIVIL ACTION - LAW PLAINTIFF'S REPLY TO NEW MATTER OF DEFENDANT NICOLE R. SHOWERS AND NOW COMES THE PLAINTIFF, Phillip Kiehl, by and through his attorney, SHOLLENBERGER AND JANUZZI, LLP, files his this Reply to New Matter of Defendants Nicole R. Showers (hereinafter "Defendant(s)"), and, in support thereof, respectfully represents the following: Paragraphs 1 through 16 of Plaintiff's Complaint are incorporated herein by reference as if set forth in full. 17. The averment set forth in Paragraph 17 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). 18. The averment set forth 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 set forth 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). 20. The averment set forth in Paragraph 20 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). 21. The averment set forth in Paragraph 21 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). 22. The averment set forth in Paragraph 22 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). 23. The averment set forth in Paragraph 23 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). 24. The averment set forth in Paragraph 24 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, Date: 61 vs 1v- SHOLLENBERGER & JANUZZI, LLP SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-3163 NICOLE R. SHOWERS, Defendant CIVIL ACTION - LAW CERTIFICATE OF SERVICE And now, this e day of June, 2012, 1 hereby certify that a copy of the foregoing Plaintiff's Reply to Defendant, Nicole R. Shower's New Matter has been served upon the following, via U.S. Mail: Jefferson Shipman, Esq. Johnson, Duffie, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 S By: SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff PHILLIP KIEHL, Plaintiff V. NICOLE R. SHOWERS, Defendant r 1 EO-OFFICF i JJE PROTHONOTAR', 2011 JUN 28 AM 1 I: 59 GSYLVATY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-3163 CIVIL ACTION - LAW CERTIFICATE OF SERVICE .?h And now, this day of June, 2012, 1 hereby certify that a copy of the foregoing Interrogatories have been served upon the following, via U.S. Certified Restricted Delivery Mail: Jefferson Shipman, Esq. Johnson, Duffie, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 31 SHOLLENBERGER & JANUZZI, LLP 2225 MILLENNIUM WAY ! ENOLA, PA 17025 (717) 728-3200 ! FAX(717)728-3400 SHOLLENBERGER & JANUZZI, LLP SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, Plaintiff V. NICOLE R. SHOWERS, Defendant "It i~1-0F F'i L F TE PROTl"IOFAR`Y 2aj7 JUN 28 AM II= 58 % LLVAI TY f Y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-3163 CIVIL ACTION - LAW CERTIFICATE OF SERVICE And now, this 2-U day of June, 2012, 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: Jefferson Shipman, Esq. Johnson, Duffie, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 SHOLLENBER6ER & JANUZZI, LLP ID#34343 ' SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 0 '00,1n of 4 ?uu6??,??? 112 JUL -3 AM 8-, 24 0,U PE N4SYLVAN A I Phillip Kiehl vs. Nicole R. Showers Case Number 2012-3163 SHERIFF'S RETURN OF SERVICE 05/21/2012 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: Nicole R. Showers, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Adams County, Pennsylvania to serve the within Complaint and Notice according to law. 05/25/2012 05:45 PM - Adams County Return: And now May 25, 2012 at 1745 hours I, James W. Muller, Sheriff of Adams County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Nicole R. Showers by making known unto Brad Showers, Husband of Defendant at 390 Middle Road, Aspers, Pennsylvania 17034 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.45 June 29, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF DATE RECEIVED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COURTHOUSE, GETTYSBURG, PA 17325 UATE PHMI=ZStiEU INSTRUCTIONS: See "INSTRUCTIONS FOR SERVICE OF PROCESS BY SHERIFF SERVICE THE SHERIFF" on the reverse of the lest (No. 5) copy of this form. Please PROCESS RECEIPT, and AFFIDAVIT OF RETURN type or print legibly, insuring readability of all copies. Do not detach any copies. ACSO ENV.# 1. P+INTIFF/S/ 2. COURT NUMBER 2012-3163 Civil Term 3. DEFENDANTS/ 4. TYPE OF WRIT OR COMPLAINT: N.?e.okQ IZ. JhQW(Lr-s CuMp\r>ctt,? -Civ(1aC i0 SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO SERVICE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED OR SOLD. 6. ADDRESS (Street or RFD, Apartment No., City, Boro, Twp., State and ZIP CODE) AT 31:A,Z) C'c 6ke_ ROCA, ?g?cLCS , Pta 1,-7 0'%,-l 7. INDICATE UNUSUAL SERVICE: X PERSONAL O PERSON IN CHARGE O DEPUTIZE ? CERT. MAIL O REGISTERED MAIL ? POSTED O OTHER Now, I, SHERIFF OF ADAMS COUNTY, PA., do hereby deputize the Sheriff of County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintiff. SHERIFF OF ADAMS COUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN-Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof. 9. SIGNATURE of ATTORNEY or other ORIGINATOR requesting service on behalf ot: 10. TELEPHONE NUMBER 11. DATE PLAINTIFF -1 r7 -? O"32 00 cJ? /( 2 ? DEFENDANT Or/1VL WGL.Vrr rVn WO& Vr Jntvnirr VI\L1 - LJV 1Vv1 VVn11IQ 0GLVn IF110 L119C 12. 1 acknowledge receipt of the writ SIGNATURE of Authorized ACSD Deputy or Clerk and Title 13. Date Received 14. Expiration Kib$rKgdate or complaint as indicated atove. 5/22/2012 ,TUNE 15, 2012 15. 1 hereby CERTIFY and RETURN that I K have personally served, ? have served person in charge, ? have legal evidence of service as shown in "Remarks" (on reverse) ? have posted the above described property with the writ or complaint described on the individual, company, corporation, etc., at the address shown above or on the individual, company, corporation, etc., at the address inserted below by handinglor Posting a TRUE and ATTESTED COPY therof. 16. O 1 hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc., named above. (See remarks below) 17. Name and title of individual served 16. A person of suitable age and discretion Read Order BRAD SHOWERS (SP(USE TO NICOLE R. SHOWERS) auresiding o defendant's usual 0 19. Address of where served (complete only if different than shown above) (Street or RFD, Apartment No., City, Boro, Two., 20. Date of Service 21. Time State and ZIP CODE) 5/25/12 5:45 PM 22. ATTEMPTS Date Mlles Dep.int. Date Mlles Dep.int. Date Miles Dep.lnt. Date Miles Dep.lnt. Date Miles D ip.lnt. 23. Advance Costs 24. 25. 26. 27. Total Costs "COST DUE OR REFUND 150.00 RRAW. 7951 29.70 PD. 6 26/1 $120.30 r-k# 29333 so AFFIRMED and subscribed to before me this day of _ ey (mm . Sheriff) ' t or Type) Shane Shultz D a 1`/24/12 _ Signature Of Sheriff Date 5 24 12 Prolhonotwy1t>eptay0N0ary Public, SHERIFF OF ADAMS COUNTY - MY COMMISSION EXPIRES I ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE OF AUTHORIZED ISSUING AUTHORITY AND TITLE. 39. Date Received PROTHONOTARY SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, Plaintiff V. NICOLE R. SHOWERS, Defendant Or THE FILED-OFFICE r 1012 JUL 12 PM 2: 03 CUMIERLAND COUNTY PENNS YLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-3163 CIVIL ACTION - LAW 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 Rule 4009.22, Plaintiff 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 (20) days prior 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: joky I0,2c>?2 Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: thy A h enb g , Esq. Attorney I. D. # 34343 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, Plaintiff IN THE COURT OF COMMON CUMBERLAND COUNTY, PENNSYLVANIA V. NICOLE R. SHOWERS, Defendant NO. 12-3163 CIVIL ACTION - LAW CERTIFICATE OF SERVICE And now, this day of , 2012, 1 hereby certify that a copy of the foregoing Certificate Prerequisi had been served upon the following, via First-Class Mail: Jefferson Shipman, Esq. Johnson, Duffie, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 SHOLLENBERGER & JANUZZI, LLP By: 3 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, Plaintiff V. NICOLE R. SHOWERS, Defendant IN THE COURT OF COMMON P CUMBERLAND COUNTY, PENNSYLVANIA NO. -12-3163 CIVIL ACTION - LAW NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 PLEASE TAKE NOTICE that Plaintiff intends to serve a subpoena identical the one attached to this notice. You have 20 days from the date listed below in file on record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. SHOLLENBERGER & JANUZZI, LLP By: er to Date:-?-o SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, Plaintiff IN THE COURT OF COMMON PL CUMBERLAND COUNTY, PENNSYLVANIA V. NICOLE R. SHOWERS, Defendant NO. 12-3163 CIVIL ACTION - LAW CERTIFICATE OF SERVICE And now, this day of 2012, 1 hereby certify that a copy of the foregoing Notice of Intent to Service Subpoena has been served upon the following, via First-Class Mail: Jefferson Shipman, Esq. Johnson, Duffie, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 SHOLLENBERGER & JANUZZI, LLP By: 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Phillip Kiehl Plaintiff File No. 12-3163 vs. Nicole R. Showers Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: YRC Worldwide, Inc. (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 W-2's, Wage Stubs, Payroll Records, Employee Manual, Personnel file, Job Description and Attendance Records at 100 Roadway Drive Carlisle, PA 17013 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Timothy A. Shollenberger ADDRESS: 2225 Millennium Way Enola, PA 17025 TELEPHONE: 717-728-3200 SUPREME COURT ID # 34343 ATTORNEY FOR: Plaintiff Date: It A Sea of the Court BY THE COURT: Prothonotary Ci ' Division Deputy SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attornevs for Plaintiff PHILLIP KIEHL, Plaintiff V. NICOLE R. SHOWERS, Defendant IN THE COURT OF COMMON CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-3163 CIVIL ACTION - LAW CERTIFICATE OF SERVICE And now, this Mday of July, 2012, 1 hereby certify that a copy of the foregoing Plaintiff's Response to Defendant's Request for Production of Documents have been served upon the following, via U.S. First Class Mail: Jefferson Shipman, Esq. Johnson, Duffie, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 t= ELE0-CF l= iC T I HE 2012 JUL 20 PM 1: 31 GUMBERLANO COl. N'lFf PENNSYLVANIA SHOLLEIRGER & JANUZZI, LLP By: AdaMT ( )14e-- Ti 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 PHILLIP KIEHL, Plaintiff V. NICOLE R. SHOWERS, Defendant 1 N p tOTHMIT 2012 JUL 20 PM 1: 31 OU PENNS LV Y. COUN-i AW A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-3163 CIVIL ACTION - LAW CERTIFICATE OF SERVICE And now, this ! l? . day of June, 2012, 1 hereby certify that a copy of the foregoing Interrogatories have been served upon the following, via U.S. First Class M, Jefferson Shipman, Esq. Johnson, Duffie, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 SHOLLEN ERGER & JANUZZI, LLP Timothy A. Shollenberger, Esq. Attorney I D#34343 13 SHOLLENBERGER 8 JANUZZI, LLP 2225 MILLENNIUM WAY ! ENOLA, PA 17025 (717) 728-3200 ! FAX (717) 728-3400 , JOHNSON, DUFFIE, STEWART & WEIDNER By: Wade D. Manley, Esquire I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 WDM@jdsw.com PHILLIP KIEHL, v. 13 2 61sT 16 l I . ?III BERLAND COUN PENNSYLVANIA Attorneys for Defendant Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-3163 Civil Term CIVIL ACTION - LAW NICOLE R. SHOWERS, Defendant JURY TRIAL DEMANDED PRAECIPE TO SUBSTITUTE APPEARANCE TO THE PROTHONOTARY: Please substitute the appearance of Wade D. Manley, Esquire, of Johnson, Duffie, Stewart & Weidner, P.C., as counsel for the Defendant in the above-captioned matter. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER wl?j?f By: Date: October /? , 2012 519482 Wade D. Manley, Esquire Attorney I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Counsel for Defendant CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing. Praecipe to Substitute Appearance has been duly served upon the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Lemoyne, Pennsylvania, on October 14' , 2012: Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 JOHNSON, DUFFIE, STEWART & WEIDNER By: O?+.t Wade D. M nley c� 13 MAR 18 PM 1: 22 UIMBP NLAND COUNTY PDgNSYLVANIA JOHNSON, DUFFIE,STEWART&WEIDNER Attorneys for Defendant By:Wade D. Manley, Esquire I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717)761-4540 wdm @jdsw.com PHILLIP KIEHL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-3163 Civil Term NICOLE R. SHOWERS, CIVIL ACTION — LAW Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: 1) A Notice of Intent to serve the subpoenas, with a copy of the subpoenas attached thereto, was mailed or delivered to each party at least 20 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) PLAINTIFF'S COUNSEL HAS WAIVED THE 20 DAYS and in addition the 20 days have passed; and 4) The subpoenas to be served are identical to the subpoenas attached to the Notice of Intent. By: A l W . Manley, E quire Attorney I.D. No. 87 44 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorney for Defendant DATE: 3/15/2013 546293 JOHNSON, DUFFIE,STEWART&WEIDNER Attorneys for Defendant By:Wade D. Manley, Esquire I.D. No.87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717)7614540 wdm @jdsw.com PHILLIP KIEHL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-3163 Civil Term NICOLE R. SHOWERS, CIVIL ACTION — LAW Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE ! PAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Phillip Kiehl C/O Timothy A. Shollenberger, Esquire Shollenberger& Januzzi, LLP 2225 Millennium Way Enola, PA 17025 PLEASE TAKE NOTICE that Defendant, Nicole R. Showers, intends to serve two (2) 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 on record and serve upon the undersigned objections to the subpoenas. If no objections are made, the subpoenas may be served. JOHNSON DUFFIEJ,�STEWART&WEIDNER By: Wade D. Manley, Esquire Attorney I.D. No. 87244 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorney for Defendant Date: February 22, 2013 542028 22740-2964 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PHILLIP KIEHL Plaintiff File No.12-3163 Civil Term VS. NICOLE R. SHOWERS Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: H Spirit Hospital ATTN: Medical Records, 503 N. 21st Street, Camp Hill, PA 17011 (Name of Person or Entity) . Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all medical records, medical reports, office notes,physical therapy records, correspondence,hospital records,test reports, and any other records pertaining to any evaluation,care or treatment rendered to Phillip Kiehl; DOB: 8/23/1966; SS#: xxx-xx-5956 from 1996 to present at Johnson, Duffie, Stewart, & Weidner, 301 Market St, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance,to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20)days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME• Fade D.Manley,Esquire ADDRESS: Sat market stre t P.O.Box 109 Lemoyne,PA 17043 TELEPHONE: (717)761-4540 SUPREME COURT ID#sn44 ATTORNEY FOR: Defendant BY THE COURT: Prothonotary,Civil Division Date: � t 1, Seal of the Court Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PHILLIP KIEHL Plaintiff File No.12-3163 Civil Term VS. NICOLE R.SHOWERS Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Holy Spirit Hospital ATTN: Radiology,503 N. 21st Street, Camp Hill,PA 17011 (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all radiology reports and radiology CD's/films pertaining to any evaluation, care or treatment rendered to Phillip Kiehl;DOB: 8/23/1966 ; SS#: xxx-xx-5956 from 1996 to present at Johnson, Duffie,,,Stewart, & Weidner, 301 Market St, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate of compliance,to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty(20)days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: wade D.Manley,Esquire ADDRESS: ,o1.ma&-etst;=t P.O.Box 109 Lemoyne,PA 17043 TELEPHONE: (717)7614540 SUPREME COURT ID#87244 ATTORNEY FOR: Defendant BY THE COURT: Prot onotary,Civil Division Date: SeaAl of th-Court Deputy CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Notice of Intent has been duly served upon the following counsel of record, by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne,, Pennsylvania, on February 22, 2013: Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 JOHNSON, DUFFIE, STEWART &WEIDNER By: Barb Carroll, Paralegal to Wade D. Manley CERTIFICATE OF SERVICE HEREBY CERTIFY that I served a true and correct copy of the foregoing Certificate Prerequisite of Subpoenas upon all parties or counsel of record by depositing a copy of same in the United States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on the 15th day of March, 2013, addressed to the following: Timothy A. Shollenberger, Esquire Shollenberger& Januzzi, LLP 2225 Millennium Way Enola, PA 17025 JOHNSON, DUFFIE, STEWART&WEIDNER By: /V Lindsey P.'Ritchey Litigation Paralegal FILED-O F IC'E 01' THEE PROTHONOTAR'1` SHOLLENBERGER & JANUZZI, LLP _ PP. 1: 42 2225 Millennium Way ��� JUN Enola, Pennsylvania 17025 CUMBERLAND COUNTY Telephone Number: (717) 728-3200 PENNSYLVANIA Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-3163 NICOLE R. SHOWERS, Defendant CIVIL ACTION — LAW CERTIFICATE.OF SERVICE. '. And now, this day of 2013 I hereby certify that a Y Y fY copy of the foregoing Notice of Intel to Service Subpoena has been served upon the following, via First-Class Mail: Wade E. Manley, Esquire Johnson, Duffie, Stewart &Weidner 301 Market Street Lemoyne, PA 17043 SHOLLENBERGER & JANUZZI, LLP By. 6'bfNy A. §hollenbe r, Esq. Attorney ID#34343 2 FILED-UFJC�- OF' ME PRO T HON01AI y SHOLLENBERGER & JANUZZI26MLIN 7 Pr, 2: 5. 2225 Millennium Way Enola, Pennsylvania 17025 CU1 BERLA14D COUJ JTY Telephone Number: (717) 728-3200 PENf4SYLVAN1A Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, V. PENNSYLVANIA NICOLE R. SHOWERS, NO. 12-3163 Defendan CIVIL ACTION — LAW CERTIFICATE PREREQUISITE TO SERVICE.OF A SUBPOENA PURSUANT TO RULE 400.9.22 As a prerequisite to service of a Subpoena for documents and things pursuant to Rule 4009.22, Plaintiff 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 (20) 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) the notice period was waived by opposing counsel as they have no objection to the Subpoena, 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. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: 4111i'11,11111 I1011111 Timothy A. Shollenberger, Esq. Date: V41e 13, 2013 Attorney I.D. # 34343 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attome s for Plaintiff PHILLIP KIEHL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-3163 NICOLE R. SHOWERS, Defendant CIVIL ACTION — LAW NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 f PLEASE TAKE NOTICE that Plaintiff intends to serve a subpoena identical to i the one attached to this notice. You have 20 days from the date listed below in which to file on record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. SHOLLENBERGER & JANUZZI, LLP d' 8y. imothy A. Shollenberger, Esq. Attorney ID#34343 Date: s I COMMONWEALTI-I OF PENNSYLVANIA COUNTY OF CUMBERLAND Phillip Kiehl Plaintiff File No.12-3163 vs. Nicole R.Showers Defendant j i i SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: YRC Worldwide,Inc., 100 Roadway Drive,Carlisle,PA 17013 (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 W-2's, Wage Stubs, Payroll Records,Employee Manuel,Personnel file,Job Description and Attendance Records from 10/12/2012 to the present. at Shollenberger and Januzzi,LT P,2225 Millennium Way,Enola, PA 17025 (Address) You may deliver or mail legible copies of the documents or produce things requested by this isubpoena,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. I THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: i NAME: "timothy A.Shollenberger,Esquire ADDRESS: 2223 Millennium way rnata,PA 17025 TELEPHONE: 717-728-3200 SUPREME COURT ID#34343 j A'1TORNEY FOR: Plaintiff { BY THE COURT: j Prothonotary,Civil Division Date: _ Seat of the Court Deputy i i F;I_E -tF F;t, Isv l�; EI1.0?�;OtdO t��� i SHOLLENBERGER & JANUZZI, LLP ����{ix�� ,� p�j j_ �� 2225 Millennium Way Enola, Pennsylvania 17025 CUMBERLAND COUNTY Telephone Number: (717) 728-3200 PENNSYLVANIA Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-3163 NICOLE R. SHOWERS, Defendant CIVIL ACTION — LAW 1 CERTIFICATE OF SERVICE And now, this 1 day f �S 2013 I hereby y certify that a copy of the foregoing Notice of Inte to Service Subpoena has been served upon the following, via First-Class Mail: Wade E. Manley, Esquire Johnson, Duffle, Stewart &Weidner 301 Market Street Lemoyne, PA 17043 SHOLLENBERGER & JANUZZI, LLP AV, . 9hoilen bert; "r, Esq. Attornby ID#34343 2 ; SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, Pennsylvania 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-3163 NICOLE R. SHOWERS, Defendant CIVIL ACTION = LAW CERTIFICATE OF.SERVICE: And now, this '! da of L ; 2013 Y I hereby certify that a copy of the foregoing Certificate Prerequisite has been served upon the following, via First-Class Mail: Wade E. Manley, Esq. Johnson, Duffie, Stewart &Weidner 301 Market Street Lemoyne, PA 17043 SHOLLENBERGER & JANUZZI, LLP It By: Timothy.A. Shollenberger, Esq. Attorney.,I D#34343 2 FILED-OFFICE r �i 17 I✓RC)NONCTARY 2013 AUG 28 PP #: v2 CUMBERLAND COUNTY PENNSYLVANIA JOHNSON, DUFFIE, STEWART&WEIDNER Attorneys for Defendant By:Wade D. Manley, Esquire I.D. No. 87244 301 Market Street .P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 wdm @jdsw.com PHILLIP KIEHL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V., NO. 12-3163 Civil Term NICOLE R. SHOWERS, CIVIL ACTION — LAW Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: 1) A Notice of Intent to serve the subpoenas, with a copy of the subpoenas attached thereto, was mailed or delivered to each party at least 20 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) PLAINTIFF'S COUNSEL HAS WAIVED THE 20 DAYS; and 4) The subpoenas to be served are identical to the subpoenas attached to the Notice of Intent. By: Wade D. M nley, Esquire Attorney I.D. No. 87244 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorney for Defendant DATE: 8/27/2013 WDM/bac:577083 22740-2964 JOHNSON, DUFFIE, STEWART&WEIDNER Attorneys for Defendant By:Wade D. Manley, Esquire I.D. No. 87244 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717)761-4540 wdm @jdsw.com PHILLIP KIEHL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-3163 Civil Term NICOLE R. SHOWERS, CIVIL ACTION — LAW Defendant JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Phillip Kiehl CIO Timothy A. Shollenberger, Esquire Shollenberger& Januzzi, LLP 2225 Millennium Way Enola, PA 17025 PLEASE TAKE NOTICE that Defendant, Nicole R. Showers, intends to serve eight (8) 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 on record and serve upon the undersigned objections to the subpoenas. If no objections are made, the subpoenas may be served. JOHNSON, DUFFIE, STEWART &WEIDNER By: ade D. Manley, squir Attorney I.D. No. 87244 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorney for Defendant Date: August 19, 2013 575508 22740-2964 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PHILLIP KIEHL Plaintiff File No. 12-3163 Civil Term VS. NICOLE R. SHOWERS Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: PRISM, 175 Lancaster Blvd., PO Box 2028, Mechanicsburg,PA 17055 (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all medical records, including but not limited to medical reports,office notes,physical therapy records,correspondence,x-ray reports and images,MRI reports and images,CT reports and images,hospital records,test reports,and any other records pertaining to any evaluation,care or treatment rendered to Phillip Kiehl;DOB: 8/23/1966; SS#:xxx-xx-5956 from 1996 to present at Johnson, Duff e,_Stewart, & Weidner, 301 Market St, Lemoyne, PA 17043 - (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20)days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: wade D.Manley,Esquire ADDRESS: 301 W ket Street P.O.Box 109 Lemoyne,PA 17043 TELEPHONE: (717)761-4540 SUPREME COURT ID#87244 ATTORNEY FOR: Defendant BY THE COURT: Prothonotary,Civil Division Date: o lS 13 EC746,�qf Sea of the Court . - Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PHILLIP KIEHL Plaintiff File No.12-3163 Civil Term vs. NICOLE R. SHOWERS Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Appalachian Orthopedic Center,LTD, 1 Dunwoody Drive, Carlisle, PA 17015 (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all medical records, including but not limited to medical reports,office notes,physical therapy records,correspondence,x-ray reports and images,MRI reports and images,CT reports and images,hospital records,test reports,and any other records pertaining to any evaluation,care or treatment rendered to Phillip Kiehl;DOB: 8/23/1966; SS#:xxx-xx-5956 from 1996 to present at Johnson, Duffie, Stewart, & Weidner, 301 Market St, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20)days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Wade D.Manley,Esquire ADDRESS: 301 Market Street P.O.Box 109 Lemoyne,PA 17043 TELEPHONE: (717)761-4540 SUPREME COURT ID#_87244 ATTORNEY FOR: Defendant Y THE COU Prothonotary,Civil Division Date: ells //-T Seal of the Co rt C Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PHILLIP KIEHL Plaintiff File No. 12-3163 Civil Term Vs. NICOLE R. SHOWERS Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Regional Medical Center,(MEDCAL RECORDS)361 Alexander Spring Rd.,Carlisle,PA 17015 (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all medical records, including but not limited to medical reports,office notes,physical therapy records,correspondence,x-ray reports and images,MRI reports and images,CT reports and images,hospital records,test reports,and any other records pertaining to any evaluation,care or treatment rendered to Phillip Kiehl;DOB: 8/23/1966; SS#:xxx-xx-5956 from 1996 to present at Johnson, Duffie, Stewart, & Weidner, 301 Market St, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance,to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty(20)days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: wade D.Manley,Esquire ADDRESS: 301 Market Street P.O.Box 109 Lemoyne,PA 17043 TELEPHONE: (717)761.4540 SUPREME COURT ID#87244 ATTORNEY FOR: Defendant Y THE COURI� Prothonotary,Civil Division Date: � �� �� � Seal of the Court Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PHILLIP KIEHL Plaintiff File No. 12-3163 Civil Term vs. NICOLE R. SHOWERS Defendant SUBPOENA TO PRODUCE DOCUMIENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Regional Medical Center,(RADIOLOGY DEPARTMENT)361 Alexander Spring Rd.,Carlisle,PA 17015 (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all medical records,including but not limited to medical reports,office notes,physical therapy records,correspondence, x-ray reports and images,MRI reports and images, CT reports and images,hospital records,test reports,and any other records pertaining to any evaluation,care or treatment rendered to Phillip Kiehl;DOB: 8/23/1966; SS#: xxx-xx-5956 from 1996 to present at Johnson, Duffle, Stewart, & Weidner, 301 Market St, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service,the party serving this subpoenamay seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: wade D.Manley,Esquire ADDRESS: 301 Market Street P.O.Box 109 Lemoyne,PA 17043 TELEPHONE: (717)761-4540 SUPREME COURT ID#87244 ATTORNEY FOR: Defe.dant BY Z COU• - yam Prothonotary,Civil Division Date: Yl n Sea of the Court Deputy COMMONWEALTH OF PENNSYLVANIA. COUNTY OF CUMBERLAND PHILLIP KIEHL Plaintiff File No. 12-3163 Civil Term VS. NICOLE R. SHOWERS Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Cumberland Valley Pain Management, 5 Tyler Court,Carlisle,PA 17013 (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all medical records,including but not limited to medical reports, office notes,physical therapy records,correspondence,x-ray reports and images,MRI reports and images,CT reports and images,hospital records,test reports,and any other records pertaining to any evaluation,care or treatment rendered to Phillip Kiehl;DOB: 8/23/1966; SS#:xxx-xx-5956 from 1996 to present at Johnson, Duffle, Stewart, & Weidner, 301 Market St, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty(20) days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: wade D.Manley,Esquire ADDRESS: 301 Market Street P.O.Box 109 Lemoyne,PA 17043 TELEPHONE: (717)761-4540 SUPREME COURT ID#97244 ATTORNEY FOR: Defendant Y THE COUR . J Prothonotary,Civil Division Date: Seal Of the Court Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PHILLIP KIEHL Plaintiff File No. 12-3163 Civil Term VS. NICOLE R. SHOWERS Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Cumberland Valley Rheumatology,Medical Arts Building,220 Wilson St.,Suite 104,Carlisle,PA 17013 (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all medical records, including but not limited to medical reports,office notes,physical therapy records,correspondence,x-ray reports and images, MRI reports and images,CT reports and images,hospital records,test reports,and any other records pertaining to any evaluation,care or treatment rendered to Phillip Kiehl;DOB: 8/23/1966; SS#: xxx-xx-5956 from 1996 to present at Johnson, Duffie, Stewart, & Weidner, 301 Market St, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena,together with the certificate of compliance,to the party making this request at the address listed above, You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20)days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: wade D.Manley,Esquire ADDRESS: 301 Market Street P.O.Box 109 Lemoyne,PA 17043 TELEPHONE: (717)761-4540 SUPREME COURT ID#87244 ATTORNEY FOR: Defendant - Y THE COURT: Prothonotary,Civil Division Date: J?//S// Seal of he Co rt Deputy z COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PHILLIP KIEHL Plaintiff File No. 12-3163 Civil Term VS. NICOLE R. SHOWERS Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Spring Road Wellness&Chiropractic Center, 1921 Spring Rd.,Carlisle,PA 17013 (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all medical records,including but not limited to medical reports,office notes,physical therapy records,correspondence,x-ray reports and images,MRI reports and images,CT reports and images,hospital records,test reports,and any other records pertaining to any evaluation,care or treatment rendered to Phillip Kiehl;DOB: 8/23/1966; SS#:xxx-xx-5956 from 1996 to present at Johnson, Duffle, Stewart, & Weidner, 301 Market St, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20)days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: wade D.Manley,Esquire ADDRESS: 301 MarketStreet P.O.Box 109 Lemoyne,PA 17043 TELEPHONE: (717)761-4540 SUPREME COURT ID 487244 ATTORNEY FOR: Defendant Y THE COURT: Prothonotary,Civil Division Date: ` Seal o the ourt COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PHILLIP KIEHL Plaintiff File No. 12-3163 Civil Term, VS. NICOLE R. SHOWERS Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Spring Road Family Practice, 1921 Spring Rd., Carlisle,PA 17013 (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: Copies of all medical records, including but not limited to medical reports,office notes,physical therapy records,correspondence,x-ray reports and images,MRI reports and images,CT reports and images,hospital records,test reports,and any other records pertaining to any evaluation, care or treatment rendered to Phillip Kiehl;DOB: 8/23/1966; SS#:xxx-xx-5956 from 1996 to present at Johnson, Duffie, Stewart, & Weidner, 301 Market St, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance,to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty(20) days after its service,the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Wade D.Manley,Esquire ADDRESS: 301 Market Street P.O.Box 109 Lemoyne,PA 17043 TELEPHONE: (717)761-4540 SUPREME COURT ID#87244 ATTORNEY FOR: Defendant THE COURT:--,' / Prothonotary,Civil Division Date: Seal of the ourt L Deputy CERTIFICATE OF SERVICE hereby certify that a copy of the foregoing Notice of Intent to Serve Subpoena has been duly served upon the following counsel of record, by depositing the same in the United States First Class Mail, postage prepaid, in Lemoyne, Pennsylvania, on August 19, 2013: Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 JOHNSON, DUFFIE, STEWART & WEIDNER Barb Carroll, Paralegal to Wade D. Manley CERTIFICATE OF SERVICE HEREBY CERTIFY that I served a true and correct copy of the foregoing Certificate Prerequisite of Subpoenas upon all parties or counsel of record by depositing a copy of same in the United States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on the 27th day of August, 2013, addressed to the following: Timothy A. Shollenberger, Esquire Shollenberger & Januzzi, LLP 2225 Millennium Way Enola, PA 17025 JOHNSON, DUFFIE, STEWART &WEIDNER By: Barb Carroll Paralegal to Wade D. Manley, Esquire SHOLLENBERGER & JANUZZI, LLP s. , .. e ,, 2225 Millennium Way � 1'3 DEC 6 PM 5 3 Enola, Pennsylvania 17025 1",UM8ERLAND Cu"Mi T`f' Telephone Number: (717) 728-3200 PENNSYLVI��I IA Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, IN THE COURT OF COMMON PLEAS Plaintiff CUMMBERLAND COUNTY, PENNSYLVANIA V. NO. 12-3183 NICOLE R. SHOWERS, Defendant CIVIL ACTION — LAW CERTIFICATE OF SERVICE AND NOW this 7V� day of December 2013, 1 hereby certify that a co of the �� Y Y fl/ copy foregoing Request for Admissions have been served upon the following, via U.S. First Class Mail: Wade E. Manley, Esquire Johnson, Duffie, Stewart &Weidner 301 Market Street Lemoyne, PA 17043 SHOLLENBERGER &JANUZZI, LLP By: Tim I! be ger Aft L. r t 7 HE, f I-1640 7Ar ( 2014 APR -2 PH 2: 09 CUMBERLAND COUNTY PENNSYLVANIA Shollenberger & Januzzi, LLP By: Timothy A. Shollenberger, Esquire Attorney I.D. No, 34343 2225 Millennium Way Eno la, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff PHILLIP KIEHL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NICOLE R. SHOWERS, Defendant NO. 12-3163 Civil Term CIVIL ACTION — LAW JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter settled, discontinued and ended. Date: March3 , 2014 :609847 22470-2964 SHOLLEN: E JANUZZI, LLP •'t e er• - , Esquire Attorney I.D. 34343 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Counsel for Plaintiff BY: CERTIFICATE OF SERVICE AND NOW, this Y3tday of March, 2014, the undersigned does hereby certify that he did this date serve a copy of the foregoing Praecipe to Settle, Discontinue and End upon all counsel of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Enola, Pennsylvania, addressed as follows: Wade D. Manley, Esquire Johnson Duffie Stewart & Weidner 301 Market Street P.O. Box 109 Lemoyne, PA 17043 -0109 (Counsel for Defendant) SHOLLENBERGER & JANUZZI, LLP BY: 4/411Ki � � � ` � y AA oll e r g squire