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HomeMy WebLinkAbout12-4312GEORGE S. MITSIOS, and his wife, THALLIA MITSIOS, . Plaintiffs V. DIANE J. BELICIC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN] 2012 - h?3f? CIVIL TERM JURY TRIAL DEMANDED PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a Writ of Summons against the defendant, DIANE J. BELICIC, and enter my app behalf of the plaintiffs, GEORGE MITSIOS and his wife, THALLIA MITSIOS. Please direct the serve the defendant as follows: Diane J. Belicic 3110 Valley Road Marysville, PA 17053 Date: July 11,20 12 Respectfully submitted, IRWIN & cKNIGHT C. By: Marcus McKnigh III, uire 60 West mfret Stre , Car sle, PA 17013 (717) 249 353 Supre rt I.D. No: 25476 on f to rw C ? 3 Q C7 r; C -K' tV To: DIANE J. BELICIC You are hereby notified that GEORGE MITSIOS and his wife, THALLIA, plaintiffs, have cc an action against you which you are required to defend or a default judgment may be entered against you. PROTHONOTARY By: D PUTY Date: / , 2012 I/ C/ Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor or of tuatb?? ?? tI* OFFICE OF THE $HERIFF 2012 JUL 30 AM 9' 04 CU PENNSYLWAN?TY George Efthymios Mitsios (et al.) C Number vs. 012-4312 Diane J. Belicic SHERIFF'S RETURN O SERVICE 07/12/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made jwin igent sear and inquiry for the within named defendant, to wit: Diane J. Belicic, but was unable to her in his bailiwick. He therefore deputized the Sheriff of Perry County, Pennsylvania to serve theWrit of Summons according to lave. 07/18/2012 12:43 PM - Perry County Return: And now July 18, 2012 at 1243 hours I, Carl E. Nace, S of Per County, Pennsylvania, do hereby certify and return that I served a true copy of the within rit of Summons, upon the within named defendant, to wit: Diane J. Beltcic by making known u o herself personalty, at 3110 Valley Road, Marysville, Pennsylvania 17053 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.45 July 23, 2012 SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILE ©Q I?E ,I' TNT PRpTlOTAR`i (c) CountySuite Sheriff, Teleosoft. Inc. SO ANSWERS, 6Z ??• t4 WON R ANDI George 8 Thallia Mitsios IN THE COURT OF COMMON PLEAS OF THE 41st JUDICIAL. DISTRICT OF PENNSYLVANIA, PERRY COUNTY BRANCH Versus Diane J. Beficic No. 2012-4312 Cumberland Co. SHERIFF'S RETURN And now July 18 , 2012: Served the within name Diane J. Belicic the defendant(s) named herin, personally at her place of residence in Rye Twp- 110 V Road, Marysville, Perry County, PA, on July 18, 2012 at 12:43 o'clock PM by handing to Diane J. Belicic, defendant 1 true and attested copy(ies) of the within Writ of Summons , and made known to her the contents thereof Sworn and subscribed to before me this So answers day of (A e Dep her' Perry Couj 1 HE PROTHONOTAR"f 2013 MAY 13 PM 2� 53 Johnson, Duffie, Stewart & Weidner CUMBERLAND COUNTY By: Julia A. Phillips, Esquire PENNSYLVANIA I.D. No. 307256 Attorneys for Defendant 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jap @jdsw.com GEORGE S. MITSIOS and his wife, IN THE COURT OF COMMON PLEAS OF THALLIA MITSIOS, CUMBERLAND COUNTY, PENNA. Plaintiffs NO. 2012-4312 V. CIVIL ACTION — LAW DIANE J. BELICIC, JURY TRIAL DEMANDED Defendant PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary of Cumberland County: Kindly enter my appearance on behalf of Defendant, Diane J. Belicic, in the above- captioned action. Respectfully submitted, JOHNSON, D F STEWART &WEIDNER By: ul A. P (lips, quire V Marke%,aLre-eV, P O Box 109 Lemoyne, PA 17043 (717) 761-4540 jap @jdsw.com Counsel for Defendant :556427 CERTIFICATE OF SERVICE AND NOW, this day of May, 2013, the undersigned does hereby certify that she did this date serve a copy of the foregoing Praecipe for Entry of Appearance upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Marcus A. McKnight, III, Esquire Irwin & McKnight, P.C. 60 West Pomfret Street Carlisle, PA 17013 Counsel for Plaintiffs JOHNSON, DQ/Ff IE, STEWART &WEIDNER By: ul A. hillips, Esquire 'ILED-O Flue 1i THE I' ROTHONOTARI ' 2013 MAY 13 PM 2: 53 Johnson, Duffie, Stewart & Weidner CUMBERLAND COUNTY By: Julia A. Phillips, Esquire PENNSYLVANIA I.D. No. 307256 Attorneys for Defendant 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jap @jdsw.com GEORGE S. MITSIOS and his wife, IN THE COURT OF COMMON PLEAS OF THALLIA MITSIOS, CUMBERLAND COUNTY, PENNA. Plaintiffs NO. 2012-4312 V. CIVIL ACTION — LAW DIANE J. BELICIC, JURY TRIAL DEMANDED Defendant PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly issue a Rule to the Plaintiffs to file their Complaint with twenty (20) days of the date of service thereof, or suffer judgment of non pros. Respectfully submitted, JOHNSON, D FI EWART &WEIDNER By: - J i A. Phi ips, s uire Al Parket Street, O Box 109 LehYoyne, P 43 (717) 761-4540 jap @jdsw.com Counsel for Defendant :556434 Johnson, Duffie, Stewart & Weidner By: Julia A. Phillips, Esquire I.D. No. 307256 Attorneys for Defendant 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jap @jdsw.com GEORGE S. MITSIOS and his wife, IN THE COURT OF COMMON PLEAS OF THALLIA MITSIOS, CUMBERLAND COUNTY, PENNA. Plaintiffs NO. 2012-4312 V. CIVIL ACTION — LAW DIANE J. BELICIC, JURY TRIAL DEMANDED Defendant RULE TO FILE COMPLAINT AND NOW this day of May, 2013, a Rule is hereby issued to you to file your Complaint in the above-captioned action within twenty (20) days of the date of service hereof, or suffer judgment of non pros. Prothonotary, �Q B y' - CERTIFICATE OF SERVICE AND NOW, this 00 day of May, 2013, the undersigned does hereby certify that she did this date serve a copy of the foregoing Praecipe for Rule to File Complaint upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Marcus A. McKnight, III, Esquire Irwin & McKnight, P.C. 60 West Pomfret Street Carlisle, PA 17013 Counsel for Plaintiffs JOHNSON, DUFFIE, STEWART &WEIDNER By: u a A. hillip squire • `ter .00— P-11 ED-0 3-J C E 2013 MAY 2 ! PM 1: 'J9 Johnson, Duffie, Stewart&Weidner CUMBERLAND COUNTY By: Julia A. Phillips, Esquire PENNSYLVANIA I.D. No. 307256 Attorneys for Defendant 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jap @jdsw.com GEORGE S. MITSIOS and his wife, IN THE COURT OF COMMON PLEAS OF THALLIA MITSIOS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 2012-4312 V. CIVIL ACTION — LAW DIANE J. BELICIC, JURY TRIAL DEMANDED Defendant CERTIFICATE OF SERVICE AND NOW, this 20th day of May, 2013, the undersigned does hereby certify that she did this date serve a true and correct copy of the foregoing Rule to File Complaint upon all counsel of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Marcus A. McKnight, III, Esquire Irwin & McKnight, P.C. 60 West Pomfret Street Carlisle, PA 17013 Counsel for Plaintiffs JOHNSON, DUFFIE, STEWART &WEIDNER BY: . P Ilips 558693 Johnson, Duffle, Stewart & Weidner By: Julia A. Phillips, Esquire I.D. No. 307256 Attorneys for Defendant 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jap @jdsw.com GEORGE S. MITSIOS and his wife, IN THE COURT OF COMMON PLEAS OF THALLIA MITSIOS, CUMBERLAND COUNTY, PENNA. Plaintiffs NO. 2012-4312 V. CIVIL ACTION — LAW DIANE J. BELICIC, JURY TRIAL DEMANDED Defendant RULE TO FILE COMPLAINT AND NOW, this day of May, 2013, a Rule is hereby issued to you to file your Complaint in the above-captioned action within twenty (20) days of the date of service hereof, or suffer judgment of non pros. Prothonotary, By- TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This__[` day of 20./-!f Prothonotary r , TA 20 f 3 JUL 19 PM 2. 12 Johnson, Duffie, Stewart & WeidneTUMSERLAI,40 COUNT'r By: Julia A. Morrison, Esquire P NNsYLVANIA I.D. No. 307256 Attorneys for Defendant, 301 Market Street Diane Belicic P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jap @jdsw.com GEORGE S. MITSIOS and his wife, IN THE COURT OF COMMON PLEAS THALLIA MITSIOS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. 2012-4312 DIANE J. BELICIC, CIVIL ACTION — LAW Defendant JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Plaintiffs, George S. Mitsios and his wife, Thallia Mitsios c/o Marcus A. McKnight, III, Esquire Irwin & McKnight, P.C. 60 West Pomfret Street Carlisle, PA 17013 Counsel for Plaintiffs AND NOW, this 18th day of July, 2013, you are hereby notified to plead responsively within twenty (20) days of the date of service hereof, or judgment may be entered against you. JOHNSON, DUFFIE, STEWART & WEIDNER By: Juli . Morrison, Esquire I.D. o. 307256 301 Market Street, P O Box 109 Lemoyne, PA 17043 (717) 761-4540 jap @jdsw.com Counsel for Defendant Johnson, Duffie, Stewart & Weidner By: Julia A. Morrison, Esquire I.D. No. 307256 Attorneys for Defendant 301 Market Street P. O. Box 109 Lemoyne, PA 17043-0109 (717) 761-4540 jap@jdsw.com GEORGE S. MITSIOS and his wife, IN THE COURT OF COMMON PLEAS OF THALLIA MITSIOS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 2012-4312 V. CIVIL ACTION — LAW DIANE J. BELICIC, JURY TRIAL DEMANDED Defendant ANSWER WITH NEW MATTER OF DEFENDANT, DIANE J. BELICIC, TO PLAINTIFFS' SECOND AMENDED COMPLAINT AND NOW, comes the Defendant, Diane J. Belicic, by and through her attorneys, Johnson, Duffie, Stewart & Weidner, and files this Answer with New Matter to Plaintiffs' Second Amended Complaint and states as follows: 1. It is admitted that the Plaintiffs are who they say there are. After reasonable investigation, Defendant is without sufficient information as to the truth or falsity of said averments. Therefore, said averments are denied and strict proof thereof is demanded at the time of trial. 2. Admitted. 3. Admitted in part, denied in part. It is admitted that on July 16, 2010, George Mitsios was travelling on Pa. Route 944 which is also known as Wertzville Road. After reasonable investigation, the Defendant is without sufficient information as to the truth or falsity of the remainder of the averments of Paragraph 3. Therefore, said averments are denied and strict proof thereof is demanded at the time of trial, 4. Admitted in part, denied in part. It is admitted that a motor vehicle accident occurred between the vehicle driven by the Defendant and that driven by George Mitsios on July 16, 2010, on Route 944. It is denied that the Defendant pressed the accelerator instead of applying the brake. 5. Paragraph 5 sets forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. 6. Paragraph 5 sets forth a legal conclusion to which no response is required. To the extent a response is deemed necessary, said averments are denied and strict proof thereof is demanded at the time of trial. Denied pursuant to Pa. R.C.P. 1028(e). 7. Paragraph 7 and all of its subparts set forth legal conclusions to which no response is required. To the extent a response is deemed necessary, said averments are denied pursuant to Pa. R.C.P. 1029(d) and (e) and strict proof thereof is demanded 2 at the time of trial. Further, it is denied that the Defendant pressed the accelerator instead of applying the brake, 8. Denied. After reasonable investigation, the Defendant is without sufficient information as to the truth or falsity of said averments. Therefore, said averments are denied and strict proof thereof is demanded at the time of trial. By way of further response, the averments of Paragraph 8 set forth legal conclusions to which no response is required. To the extent a response is deemed necessary, said averments are denied pursuant to Pa. R.C.P. 1029(d) and (e) and strict proof thereof is demanded at the time of trial. 9. Denied. After reasonable investigation, the Defendant is without sufficient information as to the truth or falsity of said averments. Therefore, said averments are denied and strict proof thereof is demanded at the time of trial. By way of further response, the averments of Paragraph 9 set forth legal conclusions to which no response is required. To the extent a response is deemed necessary, said averments are denied pursuant to Pa. R.C.P. 1029(d) and (e) and strict proof thereof is demanded at the time of trial. 10. Denied. After reasonable investigation, the Defendant is without sufficient information as to the truth or falsity of said averments. Therefore, said averments are denied and strict proof thereof is demanded at the time of trial. By way of further response, the averments of Paragraph 10 set forth legal conclusions to which no response is required. To the extent a response is deemed necessary, said averments are denied pursuant to Pa. R.C.P. 1029(d) and (e) and strict proof thereof is demanded at the time of trial. 3 11, Denied. After reasonable investigation, the Defendant is without sufficient information as to the truth or falsity of said averments. Therefore, said averments are denied and strict proof thereof is demanded at the time of trial. By way of further response, the averments of Paragraph 11 set forth legal conclusions to which no response is required. To the extent a response is deemed necessary, said averments are denied pursuant to Pa. R.C.P. 1029(d) and (e) and strict proof thereof is demanded at the time of trial. 12. Denied, After reasonable investigation, the Defendant is without sufficient information as to the truth or falsity of said averments. Therefore, said averments are denied and strict proof thereof is demanded at the time of trial. By way of further response, the averments of Paragraph 12 set forth legal conclusions to which no response is required. To the extent a response is deemed necessary, said averments are denied pursuant to Pa. R.C.P. 1029(d) and (e) and strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant, Diane J. Belicic, respectfully requests this Honorable Court enter judgment in her favor and against the Plaintiffs with costs and prejudice imposed. NEW MATTER 13, The Plaintiffs have failed to state a cause of action against the Defendant for which relief may be granted, 14. If it should be found that there is any negligence on the part of the Defendant, which negligence is denied, then in any event, such negligence was not a proximate cause of Plaintiffs' alleged damages. 4 15. The Plaintiffs' claims are barred in whole or in part and/or are limited by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. §1701, et. seq. 16. To the extent that the Plaintiffs have been paid or will be paid for some or all of their alleged damages, then claims for those damages are barred both by the defense of payment and by §1722 of the Pennsylvania Motor Vehicle Financial Responsibility Law. 17. The Plaintiffs' alleged cause of action is barred in whole or in part by the doctrines of comparative negligence and/or contributory negligence as may be applied to the facts disclosed during discovery. 18. Plaintiff's alleged injuries may have been pre-existing to the subject accident. 19. Plaintiff's alleged injuries may have been caused by a subsequent and unrelated accident. 20. Plaintiffs may have failed to mitigate their alleged injuries and damages. 21. Plaintiffs' alleged damages may be barred in whole or in part by their selection of a limited tort option in the motor vehicle insurance coverage. 22. The Defendant did apply her brakes when she noticed the vehicle driven by Mr. Mitsios ahead of her. 23. The Plaintiffs' alleged cause of action may have been caused by other third parties and/or entities that are thus far unidentified and over which the Defendant had no control. 5 WHEREFORE, Defendant, Diane J. Belicic, respectfully requests this Honorable Court enter judgment in her favor and against the Plaintiffs with costs and prejudice imposed. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: Ju is . Morrison, Esquire I.D. No. 307256 301 Market Street, P O Box 109 Lemoyne, PA 17043 (717) 761-4540 jap @jdsw.com Counsel for Defendant Date: July 18, 2013 I i 6 •i VERIFICATION I, Diane J. Belicic, hereby acknowledge that I am the Defendant in this action; that I have read the foregoing Answer to Plaintiffs' Second Amended Complaint with New Matter; and that the facts stated therein 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.A. §4904, relating to unsworn falsification to authorities. L L Diane J. Belicic Dated: -7/ 2013: i CERTIFICATE OF SERVICE AND NOW, this 18t' day of July, 2013, the undersigned does hereby certify that she did this date serve a true and correct copy of the foregoing Answer with New Matter to Plaintiffs' Second Amended Complaint upon all counsel of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Marcus A. McKnight, 111, Esquire Irwin & McKnight, P.C. 60 West Pomfret Street Carlisle, PA 17013 Counsel for Plaintiffs JOHNSON, DUFFLE, STEWART & WEIDNER BY: Julia 4'4Morrison, Esquire Johnson, Duffie, Stewart & Weidner THE PROTHONOTARY By: Julia A. Morrison, Esquire 2011 I.D. No. 307256 Attorneys for Defendant 301 Market Street CUMBERLAND COUNTY P. O. Box 109 PENNSYLVANIA Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jam @jdsw.com GEORGE S. MITSIOS and his wife, IN THE COURT OF COMMON PLEAS OF THALLIA MITSIOS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 2012-4312 V. CIVIL ACTION — LAW DIANE J. BELICIC, JURY TRIAL DEMANDED Defendant CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.2 TO: George S. Mitsios and Thallia Mitsios c/o Marcus A. McKnight, III, Esquire Irwin & McKnight, P.C. 60 West Pomfret Street Carlisle, PA 17013 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant hereby certifies that: (1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas attached thereto, was mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoenas were sought to be served; (2) A copy of the Notice of Intent including the proposed subpoenas, is attached to this Certificate; (3) No objection to the subpoenas has been received; and r } (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. Respectfully submitted, JOHNSON, DUFFIE, STEWART &WEIDNER By: WW92�n Jul' A. Morrison, Esquire . I. No. 307256 301 Market Street, P O Box 109 Lemoyne, PA 17043 (717) 761-4540 jam @jdsw.com Counsel for Defendant Date: September 18, 2013 Johnson, Duffle, Stewart & Weidner By: Julia A. Morrison, Esquire I.D. No. 307256 Attorneys for Defendant 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jam @jdsw.com GEORGE S. MITSIOS and his wife, IN THE COURT OF COMMON PLEAS OF THALLIA MITSIOS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 2012-4312 V. CIVIL ACTION — LAW. DIANE J. BELICIC, JURY TRIAL DEMANDED Defendant NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: George S. Mitsios & Thallia Mitsios c/o Marcus A. McKnight, III, Esquire Irwin & McKnight, P.C. 60 West Pomfret Street Carlisle, PA 17013 PLEASE TAKE NOTICE that Defendant intends to serve four (4) subpoenas identical to the ones attached to this notice. You have twenty (20) days from the date listed below in which to file of records and serve upon the undersigned objections to the subpoenas. If no objections are made; the subpoenas may be served. Respectfully submitted, JOHNSON, DUFFIE, STEWART &WEIDNER By: JLA A. Morrison, Esquire I.D. o. 307256 301 Market Street, P O Box 109 Lemoyne, PA 17043 (717) 761-4540 jam @jdsw.com Counsel for Defendant Date: August -, 2013 c. S COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GEORGE S. MITSIOS and his wife, THALLIA MITSIOS, Plaintiffs NO. 2012-4312 V Masland Associates 220 Wilson Street DIANE J. BELICIC, Carlisle, PA 17013 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Masland Associates (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Copy of the entire medical file to include, but not limited to, all incoming/outgoing correspondence, clinic notes, chart notes, computer documents, testing, diagnostic films forms and any other documents contained in the medical file of George S Mitsios DOB: 0610511968, SSN: 099-76-3433 from 07/16/2005 to the present. at Johnson Duffie Stewart&Weidner, 301 Market Street P.O. Box 109, Lemoyne, PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Julia A. Morrison, Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID#: 307256 ATTORNEY FOR: Defendants BY THE COU ir.1h!` o1ary1CIerk, Civil Division Deputy DATE: Seal 6f the Court (Eff.7/97) d' I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GEORGE S.. MITSIOS and his wife, THALLIA MITSIOS, Plaintiffs : NO. 2012-4312 V. Carlisle Regional Medical Center 361 Alexander Spring Road DIANE J. BELICIC, Carlisle, PA 17015 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Regional Medical Center (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Copy of the entire medical file to include, but not limited to, all incoming/outgoing correspondence, clinic notes, chart notes, computer documents, testing, diagnostic films, forms and any other documents contained in the medical file of George S. Mitsios DOB: 0610511968, SSN: 099-76-3433 from 07/16/2005 to the present. at Johnson, Duffie, Stewart&Weidner, 301 Market Street, P.O. Box 109, Lemoyne, PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Julia A. Morrison, Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID#: 307256 ATTORNEY FOR: Defendants BY THE COURT: Prothonotary/Clerk, Civil Division Deputy DATE: V le5 )11T Seal 6f the Court (Eff.7/97) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GEORGE S. MITSIOS and his wife, THALLIA MITSIOS, Plaintiffs NO. 2012-4312 V. Drayer Physical Therapy Institute 3 Jennifer Court, Suite A DIANE J. BELICIC, Carlisle, PA 17015 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Draver Physical Therapy Institute (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Copy of the entire medical file to include, but not limited to, all incomingloutgoing correspondence, clinic notes, chart notes, computer documents, testing, diagnostic films, forms and any other documents contained in the medical file of George S. Mitsios DOB: 0610511968, SM 099-76-3433 from 07116/2005 to the present. at Johnson, Duffle, Stewart&Weidner, 301 Market Street, P.Q. Box 1�9. Lemovne, PA 17043. You may deliver or mail legible copies of the documents dir 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 reasona le 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: Julia A. Morrison, Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 TELEPHONE: 717-761-4540 SUPREME COURT ID#: 307256 ATTORNEY FOR: Defendants BY THE COURT: Prothonotary/Clerk, Civil Division Deputy DATE: Seal of the Court (Eff.7/97) - . ^ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GEORGE S. MFTS|OG and his, VVifa. � TH/\LLL4MITS}OG. � Plaintiffs NO. 2012-4312 V. �r� |n�uxonc�Eh�uo � 1OD Erie Insurance Place DIANE J. BEL| iC. � Erie, pA1853Q- 104 Defendant � SUBPOENA TO PRODUCE DOCUMENTS-OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 ' TO: Erie Insurance Group (Name of Person Entity) Within twenty (20 days after service of this subpoena, you are ordered by the court to produce the following documents benefits _provided by Erie Insurance Group to George S. Mitsios, DOB: 0610511968, SS#: 099-76-3433, includina all memorandareports, statements, medical records, phone messages,-adjuster notes, expert reports and tort election forms. at Johnson, Duffie, Stewart&Weidner, 301 Market Street, P.O. Box 109, Lemoyne, PA 17043. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right toseek in advance the neouo /ab|o cost ofpreparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty C2O) days after its service, the pohyserving this subpoena rnoyseek ocou orderoonnpeU/ngyout000mpl' 'ithit. THIS SUBPOENA WAS ISSUED AJ THE REQUEST OF THE FOLLOWING PERSON: NAME: Julia A. Morrison, Esquire ADDRESS: 301 Market Street Lemoyne, PA 17043 | TELEPHONE: ' SUPREME COURT|D#: ATTORNEY RJR: Defendants BY THE COURT: Civil Division C-~ Deputy ' DATE: Seal of the Court UEff.7/97 ' CERTIFICATE OF SERVICE AND NOW, this day of August, 2013, the undersigned does hereby certify that she did this date serve a true and correct copy of.the foregoing Notice of Intent to Serve Subpoenas upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Marcus A. McKnight, III, Esquire Irwin & McKnight, P.C. 60 West Pomfret Street Carlisle, PA 17013 Counsel for Plaintiffs JOHNSON, DUFFIE, STEWART &WEIDNER BY: Ke ' elson, Paralegal to Julia A. Morrison, Esquire CERTIFICATE OF SERVICE AND NOW, this day of September, 2013, the undersigned does hereby certify that she did this date serve a true and correct copy of the foregoing Certificate Prerequisite for Service Subpoenas upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Marcus A. McKnight, III, Esquire Irwin & McKnight, P.C. 60 West Pomfret Street Carlisle, PA 17013 Counsel for Plaintiffs JOHNSON, DUFFIE, STEWART &WEIDNER BY: Kel ie Nelson, Paralegal to Julia A. Morrison, Esquire Johnson, Duffie, Stewart & Weidner By: Julia A. Morrison, Esquire I.D. No. 307256 301 Market Street P. 0. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 jam@jdsw.com GEORGE S. MITSIOS and his wife, THALLIA MITSIOS, V. DIANE J. BELICIC, Plaintiffs Defendant zoili11417 5 PI 2: 38 L/M8ERI. A ND COU PENNS YL NT b1/4 Attorneys for Defendant, Diane J. Belicic IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. NO. 2012-4312 CIVIL ACTION LAW JURY TRIAL DEMANDED PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance as counsel for Defendant, Diane J. Belicic, in the above-captioned action. JOHNSON, DUFFIE, STEWART & WEIDNER By: Date: February 28, 2014 606271 Julia Morrison, Esquire 301 arket Street, P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 jam@jdsw.coni Johnson, Duffie, Stewart & Weidner By: Karen L. Mascio, Esquire I.D. No. 88848 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043 -0109 (717) 761 -4540 klm @jdsw.com GEORGE S. MITSIOS and his wife, THALLIA MITSIOS, v. DIANE J. BELICIC, Plaintiffs Defendant r'f / p LAND �'Gu r y Attorneys for Defendant, Diane J. Belicic IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. NO. 2012 -4312 CIVIL ACTION — LAW JURY TRIAL DEMANDED PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance as counsel for Defendant, Diane J. Belicic, in the above - captioned action. r(ara Date:.F$eb nary , 2014 606271 JOHNSON, UFFIE, STEWART & WEIDNER By: Karen L. Mascio, Esquire Attorney I.D. No. 88848 301 Market Street, P.O. Box 109 Lemoyne, PA 17043 -0109 Telephone (717) 761 -4540 Email: klm @jdsw.com Attorney for Defendant CERTIFICATE OF SERVICE AND NOW, this S- day of L ftk. , 2014, the undersigned does hereby certify that she did this date serve a copy of the foregoing Praecipe to Withdraw /Enter Appearance upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: Marcus A. McKnight, Ill, Esquire Irwin & McKnight, P.C. 60 West Pomfret Street Carlisle, PA 17013 Counsel for Plaintiffs JOHNSON, DUFFIE, STEWART & WEIDNER BY: 606271 Vukat -ftA"az Connie S. Fr z