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HomeMy WebLinkAbout02-0612IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Civil Action - (X) Law ( ) Equity PETER J. SAKOL, M. D. and CAROLYN M. ANNER, Husband and Wife and CAROLYN M. ANNER, in her own right, 4212 Jonathan Lane Harrisburg PA 17110 Plaintiff(s) & Address(es) versus : GRETA and BRAD OLSEN 54 Cranfield Court Elizabethtown PA 17022 Defendant(s) & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. X Writ of Summons shall be issued and forwarded to ( )Attom,eY (X) Sheriff Carolyn M. Anner, Esq. HANDLER, HENNING & ROSENBERG P.O. Box 1177, Harrisburq, PA 17108 717-238-2000 Names/Address/Telephone No. of Attorney / /gnature Supreme Court ID No, of Attorney 62636 Date: January 29, 2002 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE HEREBY NOTIFIED THAT THE ABOVE NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. Date: Prothonotary ~ Deputy ( ) Check here if reverse is issued for additional information 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants Greta and Brad Olsen PETER J. SAKOL, M.D. ANO CAROLYN M. ANNER, HUSBAND AND WIFE AND CAROLYN M. ANNER, IN HER OWN RIGHT~ (PLAINTIFFS) VS. GRETA AND BRAD OLSEN, (DEFENDANTS) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02 - 612 (CIVIL TERM) CML ACTION- LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendants, Greta and Brad Olsen. Date: February 19. 2002 Respectfully submitted, LAW OFFICF. S OF JACOBS & SABA ~-~irard E. Rickards, EScluLr~ Attorney for Defendants Identification No.58867 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants Greta and Brad Olsen PETER J. SAKOL, M.D. AND CAROLYN M. ANNER, HUSBAND AND WIFE AND CAROLYN M. ANNER, IN HER OWN RIGHT~ (PLAINTIFFS) VS. GRETA AND BRAD OLSEN, (OEr~NDANTS) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02 - 612 (CP,'IL TERM) CIVIL ACTION- LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE G'h-ard E. Rickards, Esquire, hereby certifies that he is the atWmey for the Defendants here'm, and that he caused a true and correct copy of Entry_ of A_ _o?arance to be served by regular first class mail upon: Dated: February_ 19, 2002 Carolyn M. Anner, Esqu'n'e Handler, Henning & Rosenberg P.O. Box 1177 Harrisburg, PA 17108 Girard E. Rickards, Esquire AtWmey for Defendants 01HB-00142 '~ LAW OFIqCES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0985 Attorneys for Defendants Greta and Brad Olsen IN THE COURT OF COMMON PLEAS PETER J. SAKOL, M.D. AND CUMBERLAND COUNTY, PENNSYLVANIA CAROLYN M. ANNER, HUSBAND AND WIFE AND CAROLYN M. ANNER~ IN HER OWN RIGHT~ (PLAINTIFFS) VS. GRETA AND BRAD OLSEN, (DEFENDANTS) No. 02 - 612 (CIVIL TERM) CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO ~ PROTHONOTARY: Please enter a RULE upon plaintiffs to file a Complaint within twenty (20) days hereof or suffer the entry of a Judgment of Non Pros. Date: February_ 19. 2002 Attorney for Defendants RULE TO FILE COMPLAINT AND NOW, this ~l,day of ~-~ _~_~ , 2002 a RULE is hereby entered upon the Plaintiffs to file a Complaint herein within twenty (20) days after service hereof or suffer the entry of a Judgment of Non Pros. P-ROTHON6TAR~:r 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants Greta and Brad Olsen IN THE COURT OF COMMON l~LEAS PETER J. SAKOL, M.D. ANO CC~mZaL~XO Cotr~rrY, PE~r~SYLVA~L~ CAROLYN M. ANNER, HUSBAND AND WIFE AND CAROLYN M. ANNER, IN HER OWN RIGHT~ (PLAINTIFFS) VS. GRETA AND BRAD OLSEN, (D n D TS) No. 02 - 612 (CWIL TERM) CIVIL ACTION- LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of Praecip¢ - Rule to File Comvlaint to be served by regular first class mail upon: Carolyn M. Anner, Esquire Handler, Henning & Rosenberg P.O. Box 1177 Harrisburg, PA 17108 Dated: February 19. 2002 Attorney for Defendants PETER J. SAKOL, M.D. and CAROLYN M. ANNER, Husband and Wife; and CAROLYN M. ANNER in her own right, Plaintiffs Vo GRETA and BRAD OLSEN, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. NO. 02 - 612 Civil Term : CIVIL ACTION - LAW : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE. On this 21st day of February, 2002, I hereby certify that a tree and correct copy of Plaintiffs' Request for Production of Documents and Plaintiffs' First Set of Interrogatories were served upon the following by depositing same in the United States Mail, postage prepaid, regular service, in Harrisburg, Pennsylvania: Girard E. Rickards, Esquire 214 Senate Avenue Suite 503 Camp Hill PA 17011 HANDLER, HENNING & ROSENBERG PETER J. SAKOL, M.D. and CAROLYN M. ANNER, Husband and Wife; and CAROLYN M. ANNER in her own right, Plaintiffs GRETA and BRAD OLSON, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 612 Civil Term : CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED 1N COURT. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice is served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense or objections to the claim set forth against you. You are warned that if you fail to do so the case may proceed without you and judgement may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas signuientes, usted tiene vienta (20) dias de plazo al partir de al fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona a pot abogado y archivar en la corte en forma escrita sus defensas o sus objectiones a las demandas en contra de su persona. Sea avisado que si usted no se fefiende, la corte tomara medidas y puede una orden contra usted sin previo aviso o notificacion y pot cualquier queja o akuvui que es pedido en la peticion de demanda. Usted puedo parder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DIMERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME ?OR TELEPONO A LA OFICINA CUYA DIRECCION SE EMCUENTRA ESCRITA ABAJO PAKA AVERIGUAR DONDE SE PUEDE CONSSGUIA ASISTENCIA LEGAL. COURT ADMINISTRATOR 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 Telephone: (717)240-6200 By ×~// ~ ~ Car oly~l~..~er Esquire ,' I. D/N~r~2636 31~arket St., P O Box 1177 Harrisburg PA 17108-1177 (717) 238-2000 Attorneys for Plaintiff(s) PETER J. SAKOL, M.D. and CAROLYN M. ANNER, Husband and Wife; and CAROLYN M. ANNER in her own right, Plaintiffs V. GRETA and BRAD OLSON, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .- NO. 02 - 612 Civil Term CIVIL ACTION. LAW : : JURY TRIAL DEMANDED COMPLAINT AND NOW, come the Plaintiffs, Peter J. Sakol and Carolyn M. Anner, by and through their attorneys, HANDLER, HENNING, & ROSENBERG, by Carolyn M. Anner, Esq., and makes the within Complaint against the Defendants, Greta and Brad Olson, as follows: 1. Plaintiff, Peter J. Sakol, is an adult individual currently residing at 4212 Jonathan Lane, Harrisburg, Dauphin County, Pennsylvania 17110. 2. Plaintiff, Carolyn M. Anner, is an adult individual currently residing at 4212 Jonathan Lane, Harrisburg, Dauphin County, Pennsylvania 17110. 3. Defendant, Greta Olson , is an adult individual currently residing at 54 Cranfield Court, Elizabethtown, Lancaster County, Pennsylvania 17022. 4. Defendant, Brad Olson, is an adult individual currently residing at 54 Cranfield Court, Elizabethtown, Lancaster County, Pennsylvania 17022. 5. At all times material hereto, Plaintiff, Peter J. Sakol, was the operator of a Chrysler 300M owned by Carolyn M. Anner, that was insured by Nationwide Insurance Company under which motor vehicle insurance policy, Plaintiff=was covered by the Full Tort Option. (hereinafter "Plaintiff's vehicle"). 6. At all times material hereto, Defendant, Bred Olson, was the operator of a vehicle owned by Brad and Greta Olson, (hereinafter "Defendant's vehicle"). 7. On or about, June 4, 2001, Defendant's vehicle was immediately behind Plaintiffs vehicle on Route 283 heading westbound. 8. At approximately that same time and place, Defendant failed to observe Plaintiffs' vehicle when he was looking downward to retrieve his lunch. 9. Defendant's vehicle impacted violently with Plaintiffs vehicle, sending it across traffic where it came to rest in the median. 10. As a direct and proximate result of the negligence and/or recklessness of the Defendant(s), Plaintiffs, sustained extensive injuries as set forth more specifically below. COUNT I PETER J. SAKOL v. BRAD Olson NEGLIGENCE/RECKLESSNESR 11. Paragrephs 1-10 are incorporeted herein as if set forth at length. 12. The occurrence of the aforementioned collision and all the resultant injuries to Plaintiff, Peter J. Sakol, are the direct and proximate result of the negligence, carelessness, and/or recklessness of the Defendant, Brad Olson, generally and more specifically as set forth below: (a) In failing to be reasonably vigilant to observe the roadway and the position of Plaintiffs vehicle; (b) In failing to operete his vehicle in such a manner that would allow him to apply the brekes and stop before striking Plaintiffs vehicle; -2- (c) (d) (e) (f) (g) (h) (i) (J) (k) (i) In failing to operate his vehicle under proper and adequate control so that he could have avoided stdking Plaintiff's vehicle; In following Plaintiff's vehicle more closely than was reasonable and prudent, in violation of 75 Pa. C.S.A. § 3310; In disregarding the speed of vehicles, the condition of the highway, and the traffic upon the highway, in violation of 75 Pa. C.S.A. § 3310; In failing to regulate the speed of his vehicle so as to prevent a rear-end collision; In failing to operate his vehicle at a speed at which he could stop within the assured clear distance ahead, in violation of 75 Pa. C.S.A. § 3361; in failing to maintain proper and adequate observation of the existing traffic conditions; In failing to keep a proper lookout for vehicles lawfully on Route 283 westbound in front him; In failing to exercise reasonable care in the operation and control of his vehicle, in violation of 75 Pa.C.S.A. § 3714; In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have his vehicle under such control that injury to persons or property could be avoided; and In driving his vehicle upon the highway in a manner endangering persons and property and in a manner with careless and reckless disregard to the rights and safety of others when he was intentionally and purposefully -3- looking downward, looking away from the road reaching for his lunch, in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 13. As a direct and proximate result of the negligence of the Defendant, Brad OIson, the Plaintiff, Peter J. Sakol, has suffered extensive and serious personal injuries, including, but not limited to, injuries to his back, knee, neck, leg and shoulder. 14. As a result of the negligence of Defendant, Brad Olson, the Plaintiff, Peter J. Sakol, has suffered economic loss and will in the future continue to suffer economic loss. 15. As a result of the negligence of Defendant, Brad OIson, the Plaintiff, Peter J. Sakol, has suffered great physical pain, discomfort, and mental anguish, and he will continue to endure the same for an indefinite period of time in the future, to his great physical, emotional, and financial detriment and loss. 16. As a result of the negligence of Defendant, Brad OIson, the Plaintiff, Peter J. Sakol, has been compelled, in order to effect a cure for aforesaid injuries, to expend sums of money and will be required to expend monies for the same purposes in the future, to his great detriment and loss. 17. As a result of the negligence of Defendant, Brad OIson, the Plaintiff, Peter J Sakol, has suffered a loss of life's pleasures, and he will continue to suffer the same in the future, to his great detriment and loss. 18. As a result of negligence of Defendant, Brad Olson, the Plaintiff, Peter J. Sakol, has been, and probably will in the future be, hindered from attending to many of his daily duties and responsibilities, to his great detriment, loss, humiliation, and embarrassment. -4- 19. Plaintiff, Peter J. Sakol, believes and, therefore, avers that his injuries are permanent in nature. WHEREFORE, Plaintiff, Peter J. Sakol, seeks damages from Defendant, Brad Olson, in an amount in excess of twenty-five thousand dollars ($25,000.00) exclusive of interest and costs, and demands a trial by jury. COUNT II PETER J. SAKOL v. GRETA Olson NEGLIGENCE 20. ParaGraphs 1-19 are incorporated herein as if set forth at length. 21. Defendant, Greta Olson, was the co-owner of the vehicle which Defendant, Brad Olson, was operating with her permission at the time of the collision. 22. Defendant, Greta Olson, knew, or should have known, that Defendant, Brad Olson, would be operating her vehicle without reasonable care and safety. 23. ^s a direct and proximate result of the negligence of Defendant, Greta Olson, the Plaintiff, Peter J. Sakol, has suffered serious bodily injury as set forth in full herein. 24. ']'he occurrence of the aforementioned collision and all the resultant injuries to Plaintiff, Peter J. Sakol, are the direct and proximate result of the negligence, carelessness, and/or recklessness of the Defendant, Greta Olson, generally and more specifically as set forth below: (a) (b) In negligently entrusting her vehicle to Defendant, Brad Olson; In allowing Defendant, Brad Olson, to fail to be reasonably vigilant to observe the roadway and the position of Plaintiff's vehicle; -5- (c) In allowing Defendant, Brad Olson, to fail to operate the vehicle in such a manner that would allow him to apply the brakes and stop before striking Plaintiff's vehicle; (d) In allowing Defendant, Brad Olson, to fail to operate the vehicle under proper and adequate control so that he could have avoided striking Plaintiff's vehicle; (e) In allowing Defendant, Brad Olson, to follow Plaintiff's vehicle more closely than was reasonable and prudent, in violation of 75 Pa. C.S.^. § 3310; (f) In allowing Defendant, Brad Olson, to disregard the speed of vehicles, the condition of the highway, and the traffic upon the highway, in violation of 75 Pa. C.S.A. § 3310; (g) In allowing Defendant, Brad Olson, to fail to regulate the speed of the vehicle so as to prevent a rear-end collision; (h) In allowing Defendant, Brad Olson, to fail to operate the vehicle at a speed at which he could stop within the assured clear distance ahead because he intentionally was looking downward for his lunch, in violation of 75 Pa. C.S.A. § 3361; (i) In allowing Defendant, Brad OIson, to fail to maintain proper and adequate observation of the existing traffic conditions; (j) In allowing Defendant, Brad Olson, to fail to keep a proper lookout for vehicles lawfully on Route 283 westbound; (k) In allowing Defendant, Brad Olson, to fail to exercise reasonable care in the operation and control of the vehicle, in violation of 75 Pa.C.S.A. § 3714; -6- (I) In allowing Defendant, Brad Olson, to fail to be continuously alert, to fail to perceive any warning of danger that was reasonably likely to exist, and to fail to have the vehicle under such control that injury to persons or property could be avoided by looking downward for his lunch; and (m) In allowing Defendant, Brad Olson, to drive the vehicle upon the highway in a manner endangering persons and property and in a manner with careless disregard to the rights and safety of others by intentionally looking downward for his lunch in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 25. As a direct and proximate result of the negligence of the Defendant, Greta Olson, the Plaintiff, Peter J. Sakol, has suffered extensive and serious personal injuries, including, but not limited to, injuries to his back, knee, neck and shoulder. 26. As a result of the negligence of Defendant, Greta Olson, the Plaintiff, Peter J. Sakol, has suffered economic losses and will in the future continue to suffer economic losses. 27. ,As a result of the negligence of Defendant, Greta Olson, the Plaintiff, Peter J. Sakol, has suffered great physical pain, discomfort, and mental anguish, and he will continue to endure the same for an indefinite period of time in the future, to his great physical, emotional, and financial detriment and loss. 28. ,As a result of the negligence of Defendant, Greta Olson, the Plaintiff, Peter J. Sakol, has been compelled, in order to effect a cure for aforesaid injuries, to expend sums of money and will be required to expend money for the same purposes in the future, to his great detriment and loss. 29. As a result of the negligence of Defendant, Greta Olson, the Plaintiff, Peter J. Sakol, has suffered a loss of life's pleasures, and he will continue to suffer the same in the future, to his great detriment and loss. 30. As a result of negligence of Defendant, Greta Olson, the Plaintiff, Peter J. Sakol, has been, and probably will in the future be, hindered from attending to his daily duties and responsibilities, to his great detriment, loss, humiliation, and embarrassment. 31. Plaintiff, Peter J. Sakol, believes and, therefore, avers that his injuries are permanent in nature. WHEREFORE, Plaintiff, Peter J. Sakol, seeks damages from Defendant, Greta Olson, in an amount in excess of twenty-five thousand dollars ($25,000.00) exclusive of interest and costs, and demands a trial by jury. COUNT III CAROLYN M. ANNER v. BRAD Olson LOSS OF CONSORTIUM 32. Paragraphs 1-31 are incorporated herein as if set forth at length. 33. As a direct and proximate result of the negligence of Defendant, Brad Olson, Plaintiff, Carolyn M. ^nner, has suffered a loss of consortium, society and comfort from her husband, and she may continue to suffer similar loss in the future. 34. As a direct and proximate result of the negligence of Defendant, Brad Olson, Plaintiff, Carolyn M. Anner, has been compelled, in order to effect a cure for her husband's injuries, to expend sums of money, and may be required to expend sums of money for the same purposes in the future, to her great detriment and loss. -8- WHEREFORE, Plaintiff, Carolyn M. Anner, seeks damages from the Defendant, Brad Olson, in an amount in excess of Twenty-Five Thousand Dollars ($25,000.00), exclusive of interest and costs, and demands a trial by jury. COUNT IV CAROLYN M. ANNER v. GRETA Olson LOSS OF CONSORTIUM 35. Paragraphs 1-34 are incorporated herein as if set forth at length. 36. As a direct and proximate result of the negligence of Defendant, Greta Olson, Plaintiff, Carolyn M. Anner, has suffered a loss of consortium, society and comfort from her husband, and she may continue to suffer similar loss in the future. 37. As a direct and proximate result of the negligence of Defendant, Greta Olson, Plaintiff, Carolyn M. Anner, has been compelled, in order to effect a cure for her husband's injuries, to expend sums of monies and may be required to expend large sums of money for the same purposes in the future, to her great detriment and loss. WHEREFORE, Plaintiff, Carolyn M. Anner, seeks damages from the Defendant, Greta Olson, in an amount in excess of Twenty-Five Thousand Dollars ($25,000.00), exclusive of interest and costs, and demands a trial by jury. COUNT IV CAROLYN M. ANNER, in her own riqht v. BRAD Olson and GRETA Olson NEGLIGENCE 38. Paragraphs 1-37 are incorporated herein as if set forth at length. 39. As a direct and proximate result of the negligence of Defendants Brad Olson and Greta Olson, Plaintiff Carolyn M. Anner sustained property damage to her Chrysler 300M. -9- WHEREFORE, Plaintiff Carolyn M. Anner seeks damages for her property from Defendants Brad Olson and Greta Olson. Respectfully Submitted, HANDLER, HENNING & ROSENBERG C~rolyn~l~nner, Esquire Attorney I.D. #62636 1300 Linglestown Road Harrisburg, PA 17110 (717) 238-2000 Attorney for Plaintiffs -10- VERIFICATION We verify that the statements contained in the foregoing Complaint are true and correct to the best of our knowledge, information and belief. We understand that false statements contained therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: Peter ~ 5~k~l PETER J. SAKOL, M.D. and CAROLYN M. ANNER, Husband and Wife; and CAROLYN M. ANNER in her own right, Plaintiffs GRETA and BRAD OLSON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 612 Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE On this 29th day of March, 2002, I hereby certify that a tree and correct copy of Plaintiffs' Complaint was served upon the following by depositing same in the United States Mail, postage prepaid, regular service, in Harrisburg, Pennsylvania: Girard E. Rickards, Esquire 214 Senate Avenue Suite 503 Camp Hill PA 17011 HANDLER, HENNING & ROSENBERG n E. Green, Secretary- SHERIFF'S RETURN - OUT OF COUNTY CAS~ NO: 2002-00612 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SAKOL PETER J MD ET AL VS OLSEN GRETA ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: OLSEN GRETA but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of LANCASTER County, Pennsylvania, to serve the within WRIT OF SUMMONS On March 7th , 2002 , this office was in receipt of the attached return from LANCASTER Sheriff's Costs: Docketing Out of County Surcharge Dep Lancaster Co 18.00 9.00 10.00 43.63 .00 80.63 03/07/2002 So answer: l/-~' __/ y ~. Thomas Kline Sheriff of Cumberland County HANDLER HENNING ROSENBERG Sworn and subscribed to before me this 75 -~ day of~t~-~ ~ 2~ A.D. ~ ! Prothonotarl~ t ' SHERIFF'S RETURN - REGULAR CASE NO: 2002-00612 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SAKOL PETER J MD ET AL VS OLSEN GRETA ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon OLSEN BP~AD the DEFENDANT at TFP DATA SYSTEMS MECHANICSBURG, PA 17055 , at 1425:00 HOURS, on the 8th day of February , 2002 350 OLD SILVER SPRING ROAD by handing to BRAD YOST, SUPERVISOR a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6 00 6 90 00 10 00 00 22 90 Sworn and Subscribed to before me this /3 ~ day of A.D. ' I~oth~nota~- ' So Answers: R. Thomas Kline 03/07/2002 HANDLER HENNING ROSENBERG / ~put~ Sheriff SHERIFF'S OFFIC 50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA 17608-3480 · (717) 299-8200 SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN :~,~,~PLAtNTIFF/S/ 3 DEFEND,~T/S/ 4 COURT NUMBER 02-612 civil TYPE OF WRIT OR COMPLAINT: ~J C '~L~of Sut,t~ns SERVE 5. NAME OF INDIVIDUAL, COMP.~NY, CORPORATION, ETC., TO BE SERVED. 6. ADqRESS (Street or~FD, Apartmgnt No., City, Boro, Twp, Slate and ZIP Code) AT 7. INDICATE UNUSUAL SERVICE:'~%,DEPUTIZE ~ OTHER C~nberland Now, Februa_.-~ 6 20 02 , I, SHERIFF OF~IIR COUNTY, PA., do hereby_.deputize the Sheriff of 1',~ne~.~t-~r County to execute this W.~tff~'~turn thereof..~e~'. 'ng to law This deputation being made at the request and risk of the plaintiff. -~ ~.-.~r~4~-~.~e~"//~. 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Cumberlan~ CUMBERLAND COUNTY Cb~BERLAND COUNTY SHERIFF NOTE ONLY APPLICABLE O.,~I,J~/RIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy shedff levying upon or attaching any property under within writ may leave same/wl'l~ut a w~,c~m a n. in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such dep/~,~he she,,Pff to any plaintiff herein for any loss, destruction or removal of any such property before sheriff's sale thereof. 9. SIGNATURF-,,~rA~y/~ other ORIGINATOR 110. TELEPHONE NUMBER I t 1. DATE 12. BEI~I~ NOTICE OF ~EJ~ICE COPY TO NAME AND ADDRESS,~ELOW: (Thie area n~uat be completed if notice is to be mailed) ,~ 13. I acknowledge receipt of the writ } NAME of Authorized LCSO Deputy or Clerk 14. Date Received ! 5. Expiration/Hearing date orcomplaintasindicatedabove, aL~r~. NALt<~ 73.7-295-3609 ~BR 02-3.3.-2002 03-3.3.-2002 16. I hereby CERTIFY and RETURN that I~j~ave personally served, [] have legal evidence of service as shown in "Remarks", [] have executed as shown in "Remarks", the writ or complaint descTibed on the individual, company, corporation, etc.. at the address sh own above or on the individ ual, company, cor- poration, etc., at the address inserted below by handing a TRUE and ATTESTED COPY thereof. 17. [] I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, elc., named above. (See remarks below) 18 Name and title of individual served (if not shown above) (Relationship to Defendant) 119. [::]No Sen,ioe I See Remm'k~ Below (NO. 30) 20.;,dadtT:r~;fz~phe~:?ed,completeonlyifdi,ferentthanshownabove) StreetorRFD,ApartmentNo..City. Soro. Twp. i ,.OeleofServ,ce 22. T,ma Z _ Z.7. o-r.' ~9, c/ 24. Advance Costs 25. Sewice Costs 26. Nota~ Ce~. 27. Mileage/Postage/N.F. ] 28. Total Costs ~ 29. COST DUE on REFUND S.T.A.: 31. AFFIRMED and subscribed to before me this l ~"~ so ANaWER. 32. Signature of ~ / 35. Signature of.~e~'ff p rD t h o not a r~,/D4~m~'~T~~ MY COMMISSION EXPIRES 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriff's Office 4. BLUE - Shedff's 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant~ Greta and Brad Olsen IN TIIE COURT OF COMMON PLEAS PETER J. SAKOL, M.D. AND CUMBERLAND COUNTY, PENNSYLVANIA CAROLYN M. ANNER, HUSBAND CAROLYN M. ANNER, IN HER OWN RIGHT~ (PLAINTIFFS) VS. GRETA AND BRAD OLSEN~ (DE NDANTS) No. 02- 612 (Ovm T~) CIVIL ACTION- LAW JURY TRIAL DEMANDED NOTICE YOU HAVE BI~I S~ 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 ~ M~tter of Defendants Greta and Brad Olson to Plaintiffs' Complaint and Notice are served by entering a written appeanmce personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the court without further notice for any money claimed in the Answer with New Matter of Defendants Greta and Brad Olson to Plaintiffs' Comolslnt or for any other claim or relief requested by the Plaintiffs. 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 ~ YOU CAN GET LEGAL l-r~.P. CUMBERLAND COUNTY Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 1701.t (717) 249-3166 1-800-990.-9108 WHEREFORE, Defendants Greta and Brad Olsen respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. NEW MATTER 40. The Plaintiffs' claims for wage loss and/or medical expenses are barred, or should be reduced in accordance with § 1722 of the Pennsylvania Motor Vehicle Financial Responsibility Act. 41. The Plaintiffs' claims for non-economic bodily injury damages are barred, or should be reduced in accordance with the limited tort option of the Pennsylvania Motor Vehicle Financial Responsibility Act. 42. Plaintiffs have been paid the sum of $25,947.75 for property damage to the vehicle referred to in the Plaintiffs' Complaint, and a set offin that amount is hereby demanded. 43. The above-referenced payment represented the fair market value of the Plaintiffs' vehicle. WHEREFORE, Defendants Greta and Brad Olsen respectfully request your Honorable Court to dismiss the Plaintiffs' Complaint with prejudice. Date: April 22. 2002 Respectfully submit~l, Attorney for Defendants Identification No. 58867 2 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants Greta and Brad Olsen IN ~ COURT OF COMMON ]~LEAS PETER J. SAKOL~ M.D. AND CUMBERLAND COUNTY, PENNSYLVANIA CAROLYN M. ANNER~ HUSBAND AND WIFE AND CAROLYN M. ANNER, IN HER OWN RIGHT~ (PL^~NTIWS) VS. GRETA AND BRAD OLSEN~ (DEFENDANTS) No. 02 - 612 (CIVIL TERM) CIVIL ACTION - LAW JURY TRIAL DEMANDED VERIFICATION Girard E. Rickards, Esquire, hereby states that he is attorney for Defendants Greta and Brad Olsen in this action, and is authorized to verify that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: April 22. 2002 Girard E. Rickards, Esquire Attorney for Defendants 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0958 Attorneys for Defendants Greta and Brad Olsen ~ TIlE COURT OF COMMON ~LEAS PETER J. SAKOL~ M.D. AND CUMBERLAND COUNTY, PENNSYLVANIA CAROLYN M. ANNER~ HUSBAND AND WIFE AND CAROLYN M. ANNER, IN HER OWN RIGHT~ (PLAINTIFFS) VS. GRETA AND BRAD OLSEN~ (BEI~NDANTS) No. 02- 612 (Civ CIVIL ACTION- LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a tree and correct copy of Answer with New Matter of Defendants Greta and Brad Olson to Plaintiffs' Comolaint to be served by regular first class mail upon: Carolyn M. Anner, Esquire Handler, Hcnning & Rosenberg P.O. Box 1177 Harrisburg, PA 17108 Dated: April 22. 2002 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 50:} Camp Hill, PA 17011 Telephone Number: (717) 7;}1-0988 Attorneys for Defendants Greta and Brad Olsen IN THE COURT OF COMMON PLEAS PETER J. SAKOL~ M.D. AND CUMBERLAND COUNTY, PENNSYLVANIA CAROLYN M. ANNER~ HUSBAND CAROLYN M. ANNER, IN HER OWN RIGHT, 0'LA~NTI~S) VS. GRETA AND BRAD OLSEN, ( m N mTS) No. 02 - 612 (CIVIL TERM) CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO ATTACH VERIFICATION TO THE PROTHONOTARY: Kindly fde the attached Verification to Answer with New Matter of Defendants Greta and Brad Olsen to Plaintiffs' Complaint ~ed with this Court on or about April 23, 2002 in the above referenced matter. Date: April 25. 2002 Respectfully submitted, LAW OFFICES OF JACOBS & SABA Attorney for Defendants Identification No.58867 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants Greta and Brad Olsen IN THE COURT OF COMMON PLEAS PETER J. SAKOL~ M.D. AND CUMBERLAND COUNTY, PENNSYLVANIA CAROLYN M. ANNER, HUSBAND AND WIFE AND CAROLYN M. ANNER, IN HER OWN RIGHT~ (PLAINTIFFS) VS. GRETA AND BRAD OLSON, (DEFENDANTS) No. 02 - 612 (CIWL T~RM) CIVIL ACTION- LAW JURY TRIAL DEMANDED VERIFICATION We, Greta Olson and Brad Olson, verify that the statements made in the foregoing Answer with N~w M~-er of Defepdant~ Greta and Brad Olson to Plaintiffs' Comolaint are true and correct to the best of our knowledge, information and belief. We understand that false statements herein are made subject to the penalties of Pa.C.S.A. §4904, relating to unswom falsification to authorities. Dated: Dated: breta~O~'sson f D~fendant Brad Olson, Defendant 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants Greta and Brad OIsen IN THE COURT OF COMMON PLEAS PETER J. SAKOL, M.D. ANO CtrM~Em~A~r~ COUNTY, PENNSYLVANIA CAROLYN M. ANN-ER, HUSBAND AND WIFE AND CAROLYN M. ANNER, IN HER OWN RIGHT~ (PLAINTIFFS) VS. GRETA AND BRAO OLSEN, (DEFENDANTS) No. 02 - 612 (CWIL TERM) CIVIL ACTION- LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Riekards, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of Praecioe to Attach Verification to be served by regular first chss mail upon: Carolyn M. Anner, Esquire Handler, Henning & Rosenberg P.O. Box 1177 Harrisburg, PA 17108 Dated: April 25. 2002 Attorney for Defendants PETER J. SAKOL, M.D. : and CAROLYN M. : ANNER, Husband and : Wife, and CAROLYN : M. ANNER, in her own : right, Plaintiffs GRETA and BRAD OLSEN, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-612 CIVIL TERM ORDER OF COURT AND NOW, this 29th day of April, 2002, upon consideration of Plaintiffs' Motion To Compel Answers to Plaintiffs' Interrogatories, a Rule is hereby issued upon Defendants to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. Carolyn M. Anner, Esq. 1300 Linglestown Road Harrisburg, PA 17110 Attorney for Plaintiffs Gerard E. Rickards, Esq. 214 Senate Avenue Suite 503 Camp Hill, PA 17011 Attorney for Defendants BY THE COURT, JTesley Oler, ~ J. :rc PETER J. SAKOL, M.D. and CAROLYN M. ANNER, Husband and Wife; and CAROLYN M. ANNER in her own right, Plaintiffs V. GRETA and BRAD OLSON, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ._ NO. 02 - 612 Civil Term : CIVIL ACTION - LAW : JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO NEW MATTER OF DEFENDANTS AND NOW come the Plaintiffs, Peter J. Sakol, M.D. and Carolyn M. Anner, by and through their attorney, Carolyn M. Anner, and make the following Reply to New Matter: 40. Denied. Thc av¢i~ent of this paragraph is a conclusion of law to which no response is necessary; however, ifa response is deemed necessary, said averment is denied and proof demanded at trial. 41. Denied. Claimant has a full tort option as pleaded in the complaint and is, therefore, not barred or reduced in accordance with the Pennsylvania Motor Vehicle Financial Responsibility Act. 42. Denied. Plaintiff received no such payment. 43. Denied. The alleged payment in the amount so stated in the New Matter does not, in fact, represent fair market value of the plaintiff's vehicle. Date: Respectfully submitted, HANDLER, HENNING & ROSENBERG quire I. D. No..'7:~62636 1300 Linglestown Road Hardsburg PA 17110 (717) 238-2000 Attorneys for Plaintiffs PETER J. SAKOL, M.D. and CAROLYN M. ANNER, Husband and Wife; and CAROLYN M. ANNER in her own right, Plaintiffs V. GRETA and BRAD OLSON, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 612 Civil Term : CIVIL ACTION - LAW : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE On this 1 st day of May, 2002, I hereby certify that a tree and correct copy of Plaintiffs' Reply to New Matter of Defendants was served upon the following by depositing same in the United States Mail, postage prepaid, regular service, in Harrisburg, Pennsylvania: Girard E. Rickards, Esquire 214 Senate Avenue Suite 503 Camp Hill PA 17011 HANDLER, HENNING & ROSENBERG By /'~ean E. Green, Secretary VERIFICATION CAROLYN M. ANNER, ESQUIRE, states that she is the attorney for the party filing the foregoing document; that she makes this affidavit as an attorney, because the party she represents lacks sufficient knowledge or info,relation upon which to make a verification and/or because she has greater personal knowledge of the information and belief than that of the party for whom she makes this affidavit; and that she has sufficient knowledge or information and belief, based upon her investigation of thc matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa C.S. §4904 relating to unsworn falsification to authorities. ~a~;i~Esquire pETER J. sAKOL, M.D. and cAROLYN M. ANNER, husband and wife, and cAROLYN M. ANNER, in her own right, Plaintiffs Vo GRE?A AND BRAD oLsEN, : IN THE coURT OF COMMON pLEAS · cuMBERLAND coUNTY, pENNA. : NO. 02-612 [Civil Term) : : ; : cIVIL ACTION ' LAW : : Defendants : JURY TRIAL DEMANDED TO THE pROTHONOTARY: Please enter the appearance of Gerard C. Kramer, Esquire, and scHMIDT, RONCA & KRAMER, p.C. as attorneys of record for the Plaintiffs in the above- captioned action. BY _-~-T~.ff~ Kramer, Esquir ,(~erara~ No 44715 / Attorney t. · · Harrisburg, PA 17101 (717/232-6300 SCHMIDT, RoNCA &; KRAMER, p.C. TO THE pROTHONOTARY: Please withdraw the appearance of Carolyn M. Anner, Esquire and HANDLER, HENNING & RosENBERG, as attorney of record for the plaintiffs ByPIAND p. O. Box 1177 HarrisburG, PA 17108 {717) 238-3000 PETER J. SAKOL, M.D. and CAROLYN M. ANNER, husband and wife, and CAROLYN M. ANNER, in her own right, Plaintiffs GRETA AND BRAD OLSEN, Defendants · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNA. NO. 0:2-612 (Civil Term) CIVIL ACTION - LAW JURY TRIAL DEMANDED MOTION FOR PROTECTIVE ORDER AND NOW, comes the Plaintiffs, Peter J. Sakol, M.D. and Carolyn M. Anner, husband and wife, and Carolyn M. Anner, in her own right, by and through their attorneys, SCHMIDT, RONCA & KRAMER, P.C., and. respectfully moves the Court as follows: 1. The above-captioned matter is a personal injury case resulting from an automobile accident, which occurred on June 4, 2001. 2. The Plaintiff, Peter d. Sakol, M.D., suffered injuries, to his neck, back and knee as a result of the accident. 3. The Plaintiff, Peter d. Sakol, M.D., filed a Complaint in the Court of Common Pleas of Cumberland County. 4. The Plaintiff, Peter J. Sakol, M.D., is a physician licensed to practice medicine in the Commonwealth of Pennsylvania. 5. The Plaintiff, Peter J. Sakol, M.D., pled in the Complaint that he has suffered a loss of earning capacity. 6. Discovery is being exchanged between the parties. 7. The Defendant has requested salary, wage, and employment information concerning Dr. Sakol and his practice. 8. The Plaintiff, Peter J. Sakol, M.D., is curr,sntly in private practice and has contracts to do Medicare Fraud Reviews. 9. The Plaintiff, Peter d. Sakol, M.D., is previiously an employee of Premier Eye Group. 10. The documents that the Plaintiff, Peter d. Sakol, M.D., currently has that would be responsive to the discovery requests include income tax schedules, W-2s, an Arbitration Award, and contracts of employment:. 11. The Plaintiff, Peter J. Sakol, M.D., is willing to produce these documents, but requests that they be kept confidential except as necessary to prepare a defense in this case. 12. The Plaintiff, Peter d. Sakol, M.D., has produced some of these documents with a requested stipulation, which is attached as Exhibit "A.' 13. The Defendants, Greta and Brad Olsen, have not agreed to the confidentiality request. 14. The Plaintiff, Peter ,J. Sakol, M.D., brings this Motion for Protective Order under Rule 4012(a)(9) indicating that these documents include commercial information, which should be kept confidential. 15. The Plaintiff, Peter J. Sakol, M.D., is willling to allow Defendants' counsel to examine the documents, have their exper~Ls examine the documents, and request that the information not be used in any other litigation or for any other purpose without written consent of the Plaintiff, Peter J. Sakol, M.D. WHEREFORE, the Plaintiffs respectfully request this Honorable Court to enter an Order allowing the Defendants' counsel and experts to examine the documents and that Defendants' counsel is not to use this information in any other litigation or for any other purposes without written consent of the Plaintiffs. Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. ,/Gerard C. Kramer J Attorney at Law Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 23~.).-6300 Attorney for Plaintiffs 209 State Street 717 232 6300 ~ Sch.mi~dt~ R~]ca &' tQamer PC Harrisburg Pennsylvana 17101 Fax'7171232 6467 U i~'JURY [.Av~;E R S www. srklaw, com Via Facsimile OnlY February 6, 2003 Girard Rickards, Esquire JACOBS & SABA 214 Senate Avenue Ste. 503 Camp Hill, PA 17011 Re: Peter J. Sakol, M.D. and Carolyn M. Anner, husband and wife v. Greta and Brad Olsen No. 02-612 (Civil Term), Cumberland County Dear Jerry: Enclosed please find the income information regarding Peter Sakol. As we had previously discussed, I did not provide the information until we made a determination that he has suffered. A loss of earning capacity. I believe the medicals support a claim for loss of earning capacity. I am therefore producing documentation concerning his income. ' I am making this disclosure and noting that this is confidential material and there should be no further disclosure without written consent, disclosure should be limited to defense personnel including experts necessary to complete the Defendant's investigation and preparation of the defense. If this is not agreeable, I would appreciate it if you return the documents to me immediately. Very truly yours, SCHMIDT, RONCA & KRAMER, P.C. Gerard C. Kramer Attorney at Law GCK/ det Enclosure . (A c � . 2A�. ..3 wto e f t WWI wp! Hem | Ic ■ @■ , ■ , k H �, Q tvk�\ ���k r CL ` 2 2 ¢ p| i 10�w{ 9 � � ro22{ ~ | �C p � ! \ ƒ { o 4 0 / , ;! § § pa - ( ! | ' < | � �• • ■ ■ ©o § 5 _ } \ ¢ 7 7 jq �M a �� `� gym- ' m ; ■ � p ; a ! 2tj ma in Pi 7 § \ m bi tij 2 k ƒ \ * - Zj . 7 � 06 ) % { - qoQ § \ w m ® � § . ! , f o Lo,0 2 2 ƒ . ■ F emm9 / / x/ A b [ { § | c § 3 \ @ !� � /. i 3 � j } ■ - 2° @ . �� If 2W3 $/I■ 10 ■ - � £ ■ ■ RHO a ■■ a o� �� �� ~ � 2 . ! } ' ■ �w■� ƒ * *� o,Iq � �� \ i • # p� 2 HqH. -4| t ■■ , ■ { 3 St&� | qW q� ■ ■■ | a s r pal ro� § I ; I ■ �� %2k a ! -1R ( \2�[ a ri CL em e■Q- £ PO n E ~ I g ` �■ | | ! ( § ! | FF �� � /\Q� k�k �� C e ■ �; ) . ) ; �\ ■ g ! - ■ , § !. ■) C:l w � k ; I � ■ Ln n �CL \ ss Schedule C Profit or Loss from Business OMB Na 1545-0074 (Form 1040) (Sole Proprietorship) 2000 Depedmenl a IfM rreesury 'Partnerships,joint ventures,etc,must ills Form 1065 or Form 1085•B. mtemrd Revenue servke (99) 'Attach to Form 1040 or Form 1041. ► See Instructions,for schedule C(Form 1040). 09 Name d Proprietor soda{security Number(sSN) Peter J Sakol A NWIPsl easiness«PrdessiM bdudhq Product«Sefvlm(see lmin dlom) _ _B_�nter.C9danm.lmwdlorn--. . AMAMI- C Business Name.I No Separate BLWr*se Name.Leave B nk D Empwyer a Number(EIN}n Any f,..eueineas Address��sure«room no.) ..►4212-Jonathan Lane . :. . ...:. _.:.....:: _--.,_....,_.: ......_._..... CO.TOMOrPost ale.&ZIPCode ------------------- Harrisbur PA 17110 F Accounting method: (1) X Cash (2) UAo=aI (3) Other(specify) ► ___________ G Did you materially participate'in the operation of this business during 2000?If'No,'see Instructions for limit on losses _. . E-Yss No H t u started or acquired this business during 2000,check here . ►� Income 1 Gross receipts or safes.Ca dlon,If this Income was reported to you on Form W-2 and the 'Statutory employee'box on that form was checked,see the Instructions and check here. . . . . . . . . .. ►0 1 2 Returns and allowanc ea . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . .. . . . . . . . . 2 3 Subtract fine 2 from tine 1. . . . . . . . . . . .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . 3 4 Cost of goods sold(from line 42 on page 2). .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 5 Gross prollt.Subtract line 4 from line 3 5 6 Other Income,Including federal and state gasoline or fuel tax credit or refund. . . . . . . . . . . . . . . . . . . . .. . . 6 7 Gross Income.Add lines 5 and 6 0. 7 E)C enSGS.Enter a ses for business use of your home only on Ins 30. 8 Advertising. . . . . . . . . . . . . . 8 19 Pension and proft-sharing plans. . . .. . . 19 9 Bad debts from sales or 20 Rent or lease(see Instructions): services(see Instructions) . . . . . 9 a Vehicles,machinery,and equipment.. . . 20a 10 Car and thick expenses(see ins"). . . 10 b Other business property. . .. . . . . . . . . 20b 11 Commissions and fees . . . . . .. 11 21 Repairs and maintenance. . . . . . . . . . . 21 12 Depletion. . . . . . . . . . . . . . . . 12 22 Supplies(rat Included In Part Iln. . . . . . . 22 13 Depreciatlon and Section 23 Taxes and licenses. . . . . .. . . . . . . . . 23 179 expense deduction 24 Travel,meals,and entertainment: (not included in Part III) (see Instructions). . 13 a Travel . . . . . . . . . . . . . . . . . . . .. . ... . . 24a 14 Employee benefit programs b Meals and (other than on line 19). . . . . . . 14 entertainment. . . . ible 15 Insurance(other than health) . .. 15 c Enter nondeduct amount Included on line 16 Interest: 24b(see Instructions). . . a Mortgage(paid to banks,etc) . . . . . . lea d Subtract line 24c from line 24b. . . . .. .. 24d bother. .. . . rr. . . . . . . . . . 16b 25 Utilities. . .. . . . . . . . . . . . . . . . .. .. 25 17 Legal$professional services. . . 17 26 Wages(less employment credits) . . . . . . 2e • 18 Office a . . . . . . . . . . . . 18 J 127 Other expenses from line 48 on . . . . . . 27 28 Total expenses before expenses for business use of home.Add lines 8 through 27 In columns . . . . . . . . . . . ► 28 29 Tentative profit(loss).Subtract line 28 from line 7. . .. . . . . . . . . . . . . . . . . . . . . . . . . . . 29 30 Expenses for business use of your home.Attach Form 8828 . . . . . . . . . . . . . . . . . I . . . . . . . . . . . . . . .. 30 31 Not praM or(loss).Subtract line 30 from line 29. •If a profit,enter on Form 1040,line 12,and also on Schedule SE,line 2(statutory employees,see Instructions).Estates and trusts,enter on Form 1041,line 3. S1 0 if a loss,you must go to line 32. 32 If you have a loss,check the box that describes your Investment In this activity(see Instructions). — *it you checked 32a,enter the loss on Form 1040,line 12,and also on Schedule SF,line 2 All Investment is (statutory employees,see Instructions).Estates and trusts,enter on Form 1041,line 3. 32 s E]at risk. • If you checked 32b,you must attach Form 6191 Some Investment — 32 b (1 is not at risk. BAA For Paperwork Reduction Ad Notice,am Forn 1040 Instructions. Schedule C(Farm 1040)2000 FDIZ0112 11 D6= S6 an 7 ■ xq a� ® ® t / �f 2\ lie � ` � � E 7 ,E E � � � § 2 ■� t � §f sq O (w oran s � � � • n n v r N�H �a CT e a 8 s K �Ci�w S �CO tnj5 ct i n M F v QZ� g wn�v; Ne g �. GOOK;" e�c' I �y rr..�yyw IN a; S. 'ro n5 O O rY •d yN rM��I,� atv t S O H e t 9 OHM 9 � i i s 2 O r N N N O0 •r ' •N � 0 o v n n c, 4n �: �� ^ I °I �'I eI � �� � al � S �► IPw m �� v, I➢ i i � �l 31 � n FI f����0� i I ? 'SCkEDULE C Pr'oflt or Loss From Business ordBNo.1542:0074.___ (Form 1040) (Sale Proprietorship) 2001 Vepartmantaf:hoTnasiry ► .„rtnershipa,joint ventures,Olt.,must file Farm 1065 or K. ,.1086.8. tn:emel f#„ror.-je sere= ism j Attach to Form 1040 or form 1041, ►See Instructions for Schedule C(Form 10 40►. suer uoNc.09 Name of progriator social wanly nurr ruer(Um,, PETER J. SMOL A Principal business 0.profession,including prods ct or servici (see page C-1) B Enter oede+rom peep C•7 A e — OPHTHALMOLOGIST ► 621111 C -=8usiness�ame.if nosepbnte-business name Jeav"tank— --- ---—_ ptoyar 10 number(Eft if any--— DR. PETER J. SAKOL, MD, LLC �E— u8 smess address mcung s�iborr;d)►-*21z-JCiNATHAN --_ _----- ---- -1-0-4_ City,town or post office,state,and ZIP code HARE.IS BURG--PA 17 -------------------------- _ F Accounting method: (1) Cash (2)F7 Accrual (3)LJ Other(specify) ► 0 Did you'materially participate'in the operation of this business during 2001?It'No'ses page C-2 for limit on losses ..........................„•[ Yes ^No ff ou started or aceulred this business during 2001,check here 10. L .: income - 1 Gross receipts or sales.Caution.If this income was repodec to you on Form W-2 and the'Statutory employee'box an that form was checked,see page C-2 and check here . [� 1 2 Returns and allowances .............................................. ............................. .............................................. 2 ............... 3 Subtract line 2 from line 1 ......................................................................... ............................................................. J- 4 Cost of goods sold(from line 42 on page 2) .................. ......................... ................................................................ 5 Gross profit,Subtract line 4 from line 3 ..................................................................... ........................................... 5 , 5 Other income,including Federal and state gasoline or fuel ta:,credit or refund(see page C-3) ............... ............... 5 7 Grose Income. Add lines 5 and 6............................................... ............... ...................................................... ► 7 penses. Enter expenses for business use of your home only on line 30. 8 Adverti si ng.................................... 19 Pension and profit-sharing plans 1 _ 9 Bad debts from sales or 20 Rent or lease(see page C-4): K; services(see page C-3) .................. a Vehicles,machinery,and equipment ............ 2oa 10 Car and truck expenses b Other business properly ........................... 20 (see page C-3) ........STMT...8..,. 10 21 Repairs and maintenance ...... 21 11 Commissions and fees 11 22 Supplies(not Included in Pad ill) 22 12 Depletion .................................... 12 23 Taxes and 1'imnses.................................... 23 . r,...v 19 Depreciation and section 179 24 Travel,meals,and errtertainrnent: expense deduction(not included in a Travel .._.........•,_.,,,,............................... 124a Part III)(see page C-3)..................... 13 b Meats and 14 Employee benefit programs(other entertainment •.•.. than on line 19) 14 _ c Enter nondeductible 16 Insurance(other than health) 1 amount included on line 24b , z: :�: 16 Interest: ;; ; =;: (see page C-5).................. a Mortgage(paid to banks,etc.) ......... 16j d Subtract knb 24e tiom line 24b „• 24d h Other ........-.................... ........... lob 25 Utilities 17 Legal and professional 4� 26 Wales(less employment credits) , services ........ 17 27 Other expenses(from line 48 on 18 Office a nse .............................. 1 a e 2 ..... . ......................................... 1 27 28 Total expenses before alanses for business use of homf.Add tines 8 through 27 In columns .......................... ............ ► 28 • r 29 Tentative profit(loss).Subtract line 28 from line 7.......... 2 ................. ................. 30 Expenses for business use of your hems.Attach Form 8836 ................... ........ ....... ... _ 31 Net profit or(loss). Subtract line 30 from line 29. - e If a profit,enter on Form 1040,line 12,and also on 5ctsdule SE,line 2(statutory amploy:e..,see page C-5). I Estates and trusts,enter on Form 1641,line 3. y° e It a loss,you must g�to Ins 32." 32 If you have a loss,cheolathe box that describes your investment in this activity(see page C-fsl. e if you checked 32a,ether the loss on Form 1040,line 12,and also on Schedule SE,line 2(statutory employees, see page C-5)•Estates and trusts,enter on form 1041,tine 3. 32a s if you chocked 32b,you must-attach Form 6198. 92D LWA For Paperwork Reduction Act Notice,toe Form 1040 instructions. Schedule C(Form 1040)2001 120001 nor,e.nd06 759606 05080,0-2 2001.05025 SAKOL, PETER J. 050860-1 SQ ScheUUI#0 V01111 1040)2001 PETER J. SAKOL ^nee 2 Cost of Goods Sold (se, le c•6) 33 Method;s')used to value closing inventory: a rI Cost b lover of cost or market C Other(attach explanation) 34 Was there any change in determining quantities,costs,or valuations between oaaning and closing inventory?If Yes;attach explanation ...........•_........_. ---, _............................... .... .... ....... ........................................................ ,Yes I I No ----35—Inventory at begfnning-of year.if differen4from last years closing-loventory;-atteeh-explanat{on— ------ cbasesless cast ni,tems-withdrawn lor.personal use . 37 Cost of labor.Do not include any amounts paid to yourseh .......................... 38 Materials and supplies..................................................... 30 Other costs..................................... ....... 39 40 Add lines 35 through 39 ....................................................... 41 Inventory at and of year ....................................................... ................................ 41 = 42 Cott of sold. Subtract line 41 from line 40.Enter the resut here and on page 1,line 4 :fit:: .<: Information on Your Vehicle. Complete this part only if you are claiming car or truck expenses on line 10 and are not.required to file Form 4562 for this business.See the ina`ructions for line 13 on page C•3 to find out if you must file. 43 When did you place your vehicle in service for business p uposes?(month,day,year) Do- 44 Of th,e total number of miles you drove your vehicle during 2001,enter the number of miles you used your vehicle for: a Business b Commuting C Other _ 45 Do you(or your spouse)have another vehicle available for personal use?........... ......................... Yes No 48 Was your vehicle available for use during off.duty hours? ....................................................... .........................❑ yes ❑ No 47a Do you have evldence to support your deduction?......... Yes No ................................................................................... ............. b If`Yes'Is the evidence wrRten7................................ . .......... .... ............... 1 I yes I No Ex enses. List below business ex)enses�not Included on Imes 8.26 or line 30. DUES -� POSTAGE MEDICAL SUPPLIES MISCELLANEOUS ;. MEDICAL BOOKS TELEPHONE / PAGER I� � y I 48 Total other axpeesat. Enter here and on page t,line 2'' ... ............... ................ . ........... 48 I 9 Schedule C(Form 11)40)2001 nnMAnAng 759606 050860-2 2001.05025 SAKOL, PETER J. 050860-1 (D pMERiCf 14 ARBITRATION ASSSOCIATION - --- ------- - Pl3TER SAKOL,M.D.. -- claimant And rjeoTge P. Wood,Arbitrator PREMIER EYE CARE,INC., Respondent AWARD It THE[JNpBRSIGNED 1�kBITRATOR,having oven duly designated in accordance with the Arbitration Agreement eritned into by the above-named parties,dated April 25, 1998, and having been duly heard the proofs and allegations of the parties,ANVARD as follows: A. B, On the tnattetr of the dislrttte arising from Clairaants,Peter Sakol's,M.D.claim for bonus compensation for services performed during the year 2000 where t was not received until 2001,as award is entered In favor of clalmanleretor Sakol, M.D. and splast Responfieat,Premier Eye Cara;Inc.,in the amovAt of ?" together with Interest at t.he.annual rate of 60/9 beginning March 1, 0010 compounded ahaually to the date paid by Respondent. The administrative fees o'!:he American Arbitration Association totalingsball , be borne equally by the parties and paid as directed by A;sociation. Therefore Respondent shal l pay directly to Claimant the sum o or Respondent's one-half(h) share of the administrative fees previously advanced by Claimants"to the Association. The arbitrator's compena:ition and expenses totaling shall be borne equally by the parties and paid as directed by the Association. This award is in full settlrraent of all claims submitted to this arbitration. 1 May 17, 2002 carpe P. ood,Arbitrator � i GFLIGMAI\, FRIEDMAN & roMPAN.y P.C. CERTIFIED PUBLIC ACCOUNTANTS& 4SULTANTS ■ - www seligmancoa.com Harrisburg•1027 Mumma Roac •Wo!mleysburg,FA 17043•(717)761.0211 •Fax(717)975-9750 State College•1423 North Atherton Street•State Coilege,PA 16803•(814)238-8474•Fax(814)234.3523 – — York•96 South George Street,Suite 350•York.PA 17401•(717)843-0040•Fax(7171843-007 September"11 Dr.Peter J. Sakol 4212 Jonathan Lane Harrisburg, Pennsylvania 17110 Re: 2001 Profitability of Self-Employed Medical Practice Dear Dr. Sakol: You had requested our Firm to continent on the profitability of your medical practice for the year 2001. The income and expenses of your practice was reported on Schedule C (copy enclosed), which is attached to your individual income tax return Form 1040. Your Schedule C showed a net profit ofAINWor 2001. . However, there were legal expenses deducted in the amount of iMl which were a one- time type of expense for various legal matters. Additionally, there was a 44IMinunediate depreciation deduction for fixed assets you acquired during 2001, which is allowed as a tax deduction under Section 179. Therefore, we could restate otu 2001 profitability to im y P tY �y adding back the one-time legal expenses of 34Mand acce:erated depreciation of STIMto derive a more accurate picture of what your true 2001 profitability was. Please contact our office if you have any questions on the above matter. Sincerely, SELIGMAN,FRIE MAN&COMPANY,P.C. Donald J. , A Enclosure Robert M.Levy,CPA,CSEP David G.Phillips,CP4 Jodi L.Green.CPA Arthur J.Full,CPA, CrA Edward L.WaTtemyer,CPA John J.Cardello,CR% Michael S.Signor,CPA,ABV Edward E.Wagoner.CPA James A.Smeltzer.CPA,ABV Calvin J.wagrer,CFA James,:,Karchner,CPA/PFS,CFP Claire S.Weaver,CPA:CSEP Robert S.Freed,CPA,CFA,CFE Founding Partner Murray D.Friedman,CPA i CERTIFICATE OF SERVICE AND NOW, this ~6 %ay of '-7~A._ (L ~ , 2003, I, GERARD C. KRAMER, ESQUIRE, hereby certify that I have, this day, served a copy of the Motion for Protective Order by serving a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Girard Rickards, Esquire JACOBS & SABA 214 Senate Avenue Ste. 50.3 Camp Hill, PA 17011 Attorney for Defendant Respectfully submitted, SCHMIDT~ RONCA & KRAMER~ P.C. By/~ a.~ ./(~erard C. Kramer Attorney at Law Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for ]Plaintiffs PETER J. SAKOL, M.D. and CAROLYN M. ANNER, husband and wife, and CAROLYN M. ANNER, in her own right, Plaintiffs Vo GRETA and BRAD OLSEN, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW' NO. 02-0612 CIVIL TERM ORDER OF COURT AND NOW, this 1st day of April, 2003, upon consideration of Plaintiffs' Motion for Protective Order, a Rule is hereby issued upon Defendants to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Gerard C. Kramer, Esq. 209 State Street Harrisburg, PA 17101 Attorney for Plaintiffs Girard Rickards, Esq. JACOBS & SABA 214 Senate Avenue Suite 503 Camp Hill, PA 17011 Attorney for Defendants J~3/esley Ol~i:, ~lr., Jo :rc 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants PETER J. SAKOL, AND CAROLYN M. ANNER (PLAINTIFFS) VS. GRETA OLSON AND BRAD OLSON, (DEFENDANTS) IN THE COURT OF COMi CUMBERLAND COUNTY, No. 02-612 CIVIL ACTION - LAW JURY TRIAL DEMANDED ORDER And now the ~ day of ,2003, upon considerati~ Defendants' Answer to the Plaintiffs' Motion for Protective Order, said moti Plaintiff Peter J. Sakol, M.D. is hereby ordered to provide documents reque~ Defendants' Request for Production of Documents within days order. In the event that Plaintiff Peter J. Sakol, M.D. fails to comply with ti be precluded from presenting a claim for lost earnings or loss of future earm trial. Date: iON PLEAS PENNSYLVANIA I of the on is denied. ~ted in the service of this :is order, he will lg capacity at 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants PETER J. SAKOL, AND CAROLYN M. ANNER (PLAINTIFFS) VS. GRETA OLSON AND BRAD OLSON, (DEFENDANTS) IN THE COURT OF COM CUMBERLAND COUNTY, No. 02-612 CIVIL ACTION - LAW JURY TRIAL DEMANDED 1. Admitted. 2. Admitted in part, denied in part. Admitted that the Plaintiff claims to various injuries. It is specifically denied that Plaintiff Peter J. Sakol, M.D. injuries in the accident. 3. Admitted. 4. Admitted. 5. Admitted. By way of further answer, Plaintiff Peter J. Sakol, M.D. Complaint that he has suffered serious and permanent injuries, a loss of earni future earning capacity. 6. Admitted. iON PLEAS ?ENNSYLVANIA ?ROTECTIVE have suffered uffered any lead in the tgs and a loss of 7. Admitted. By way of further answer, the Defendant ihas requested Peter J. Sakol, M.D. produce documents to support his claim of loss of w: of future earning capacity. 8. Admitted. 9. Admitted. 10. Defendant is unaware of exactly what documents are in Plaintiff's p. Defendants request income tax filings forms, contracts of employment and documentary proof of past earnings as well as documents relevant to a clafl earning capacity. By way of further answer, the arbitration was redacted an employment has been produced. 11. Admitted that the Plaintiff has insisted upon a confidentiality agreem~ would produce documents relevant to his claim. 12. Admitted that Exhibit "A" contains a letter and documents sent by Ph It is specifically denied that any stipulation was reached. 13. Admitted. 14. Denied as a conclusion of law. 15. Admitted that the Plaintiff has offered said stipulation, ttowever, Pla~ Sakol, M.D. has not produced any legal support for a confidentiality order. ~l by filing a lawsuit and claiming permanent and serious injuries as well as loss loss of future earning capacity, Plaintiff Peter J. Sakol, M.D. has waived any i confidentiality of the records. By way of further answer, the Plaintiff has not l documents that include confidential information such as patient lists, etc. To tl Plaintiff has redacted certain portions of the arbitration award, in such a fashi~ and the Defendant are unable to determine whether the redacted portions of the :hat the Plaintiff :es as well as loss ;session. ny other of loss of future no contract of ~t before he [intiffs' attorney. ~tiff Peter J. o the contrary, of earnings and 'ight to >rovided any te contrary, the that this Court tward are relevant to the Plaintiff's claims. Wherefore, Defendants Greta Olson and Brad Olson respectfully re Honorable Court to deny the Plaintiffs' Motion for Protective Order. Date: Respectfully submitted, 'rard E. l(Lickard~, ~ Identification No: 58867 Attorney for Defendants ~uests your 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants PETER J. SAKOL, AND CAROLYN M. ANNER (PLAINTIFFS) VS. GRETA OLSON AND BRAD OLSON, (OEFENVANTS) IN THE COURT OF Co~ CUMBERLAND COUNTY, No. 02-612 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE ', Girard E. Rickards, Esquire, hereby certifies that he is the attorney f¢ herein, and that he caused a true and correct copy of Defendants' Answer to for Protective Order~ to be served by regular first class mail upon: Gerard C. Kramer, Esquire 209 State Street Harrisburg, PA 17101 Dated: April 8, 2003 Honorable J. Wesley Oler, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, Pa 17013 'rard E. ~ickards, Esqu~ Identification No. 58867 Attorney for Defendants iON PLEAS PENNSYLVANIA ,r the Defendants ?laintiffs' Motion PETER J. SAKOL, M.D. and CAROLYN IN THE COURT OF COMMON PLEAS M. ANNER, husband and wife, and CUMBERLAND COUNTY, PENNA. CAROLYN M. ANNER, in her own right, : NO. 02-612 (Civil Term) Plaintiffs . V. CIVIL ACTION - LAW GRETA AND BRAD OLSEN, Defendants JURY TRIAL DEMANDED PLAINTIFFS' RESPONSE TO REOUEST FOR ADMISSIONS 1. Admitted 2. Admitted based on belief and documents presented as part of the discovery. 3. Admitted. It is believed by the Plaintiffs that Nationwide Insurance Company did issue a gheck in the amount of to the Chrysler Financial Corporation. 4. Denied. Exhibit A is not a true and correct copy of the check, but an electronic receipt of the check. 5. Admitted that a check in the amount of was issued to Plaintiff, Peter J. Sakol, by Nationwide Insurance Company. 6. Denied. The check was handwritten to Peter J. Sakol and did not include any notation of full payment or full settlement. (See check attached as Exhbiit "1.") Exhibit B of Defendant's Request for Admissions is an electronic receipt of the check. 7. Admitted that has been paid either to Plaintiffs or to the lienholder for the damage in the claim. Denied as stated. 8. Admitted. Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. BY erard C. Kramer Attorney at Law Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs �„��-7 ''1"^''1 I• �•-r--�—`.fa1 �.+ sue. ,.._-, \ATjo,.% rz.;l.St:RAW% COMPARM, +• s NARRMBURO929VIC9 MXTER•uARRISSUtar PiL f �� ib iSds t` t•:tiit•�� DATA 01'Ltt::C "K./.•• :jam.'; •` i„� ,•• ..• :r,• l / �/, ,. `:w': �,.,,.;: �'[;: •'.%', � \e101(:AetCltaed�hti1i11QD,�!{� ;: :•Y••.'' i,.';r^•'.: .:i.w;.[ r`. a{i;�; :/,•t,rc � ,lr i"ij,i::.. .r•; ..:•. •*• r[ •..•.•s,rs.:`v) •-u�..,•!ty'js�,�� `�j v[��'��'::� "a�•a:+ K'-J.�,'4i.."�.'ti.' •:.J .�. tyj::.•iv'• •�R"`••21�,;•�'if ay.•ti nMl wh.':7:..'4•;Ki,"r/w i••J`!)r•A.a 'r�. •.. '. ... 'B.Y •w.Y�«..•.ti..`,+y-��• :�S•':Bir:�ei-!t.:~•t'3w+i,i•'•1�.'•��r', tl..� ... .. s .- .. . •.,.•t,�..!• ,'•r.w r. ..��.~"4 ABOVE CHECK COVERS ITEMS INDICATED BELOW-MAC'.i 5VUB BEFORE G47ti-1 itr ANZ XF.EP FOR YOUR RACORDS �M NAT10NW1DRMMALU't.""sCR v1I1t>AWIDEI�SA1AaXCS:f;Vi+VYt1 e'].C1t1CA ❑ NATIOttl.l�i�tAltltANC6COMPAIVY ❑ NATIONWID6MUWAL Mg tA'$11RANCR COMPANY ❑ I-Ar,0%WIDt:-°ROM9 r.0.)CAIU.0_-Y MY.W1Xf COMPXVV ❑ C7YljR iJ NAY'TONWiDB f F.V6RAL tfpTlRhl'tCli COLYAi`Y © -�ATIOKtt IM L OaMI.Tr IS A'L',KCH=NPAXY CMCK If I FuulPnarual PILT ment Icirde one} _ FulMrtial,Pav nt rele one Ato_unt Sodfit�taidiv � -t Com�.rehensiva I personal t_jucx Protectivn/NtP � I:.c,.c'Vaart i UniosurWUnderinsured •�b'nus Offsets �Tzwing and Labot 1 l tltn6aOV��eTlt Or ltoslae►t. %. —�Aniottt efaoaut FropuM Contents,fewelrY �It medical oravlde:is a es st1 Prue-E`Homa Business i�u,nvs eff3aJus t a2 c aN i NtiSC. rxxe ,T�1 inm deductiblefoffsct - .� S.'rvicecrs*ande to; -- ----- Total _ _ „L=u of sat•• - �pollca •iE?SP a_,LtL_bW=v1L to fellow: _ ,j lv/n► Additional[afartnation: _ if you have any quettior•L plow call i i ,•�._. %Ay Phone nambe is Your claim numbs:is -- I I i Ed Wd£Z:90 £00Z S0 •add 'ON Xdd _..-- - WO,'!d c ATTORNEY VERIFICATION I, Gerard C. Kramer, Esquire, verify that I am attorney of record for the Plaintiff. I verify that the facts contained in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsifications to authorities. Date: //~rard C. Kramer, Esquire CERTIFICATE OF SERVICE AND NOW, this ~/~7/- day of/D - ' "//~(~(~J/t~-/ , 2003, I, GERARD C. KRAMER, ESQUIRE, hereby certify that I have, this day, served a copy of the Plaintiffs' Response to Request for Admissions by serving a copy of the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Girard Rickards, Esquire JACOBS & SABA 214 Senate Avenue Ste. 503 Camp Hill, PA 17011 Attorney for Defendant Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. G~rd C. Kramer ,,/'Attorney at Law J Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant PETER J. SAKOL, AND CAROLYN M. ANNER (PLAINTIFF) VS. GRETA OLSON AND BRAD OLSON, (I EFENDANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 02-612 NO. CIVIL ACTION - LAW JURY TRIAL DEMANDED STIPULATION The parties here by stipulate that all claims against Defendant Greta Olson are dismissed with prejudiced. The caption should be amended to reflect the deletion of Greta Olson as a party. erard C. Kramer, Esquire Date: L']/- [f''~' 0 '~ Date: O~arit~. l~ica~ds, Esquire 01HB-00142 LAW OFFICES OF JACOBS & SABA 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant PETER J. SAKOL, AND CAROLYN M. ANNER (PLAINTIFF) VS. GRETA OLSON AND BRAO OLSON, (DEFENDANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW JURY TmAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of Stipulation, to be served by regular first class mail upon: Dated: April 30, 2003 Gerard C. Kramer, Esquire 209 State Street Harrisburg, PA 17101 Gir~d 1~. Rickards, Esquire Identification No. 58867 Attorney for Defendant VERIFICATION BASED UPON PERSONAL KNOWLEDGE AND INFORM&TION SUPPLIED BY COUNSEL I, PETER J. SAKOL, verify that I am the Plaintiff in the foregoing action and that the attached Response to Requests for Admissions is based upon the information which has been gathered by my counsel in preparation of this lawsuit. The language of the Response is that of counsel and is not mine. I have read the Response and to the extent that they are based upon information that I have given to counsel, they are true and correct to the best of my knowledge, information, and belief. To the extent that the contents of the Response are that of counsel, I have relied upon counsel in making this Verification. I understand that intentional false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsifications made to authorities. DATED: PE~,E~' J. SAKOL File No.: 0iHB-00i'42 PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate.) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case (check one): ( x ) for JURY trial at the next term of civil court. ( ) for trial without aiur~. CAPTION OF CASE: (Entire Caption Must Be Stated In Full) (Check One) ( ) Assumpsit Peter J. Sakol, M.D. and Carolyn M. Anner, husband and wife, Plaimiffs VS. ( ) Trespass ( x ) Trespass (Motor Vehicle) ( ) (Other) Greta and Brad Olsen, Defendants The trial list will be called on December 9, 2003 Trials commence on January 12, 2004 Pre-trials will be held on December 17, 2003 (Briefs are due 5 days before pre-trials.) (The party listing this case for trial shall provide forthwith a copy of the praecipu to all counsel, pursuant to local Rule 214-1.) No. 02-612 Civil 20 02 Indicate the attorney who will try case for the party who files this praecipe: Girard E. Rickards, Esquire, Attorney for Defendants; Jacobs & Associates, 214 Senate Avenue, Suite 503, Camp Hill, Pennsylvania, 17011; (717) 731-0988. Indicate trial counsel for other parties if known: Gerard C. Kramer, Esquire~ Attorney for Plaintiffs; Schmidt, Ronca & I~amer, 209 State Street, Harrisburg, Pennsylvania 17101; (717) 232-6300 This case is ready for trial.~~~ Signed: ~r-e~ ~-- Print N~ame: Girar~l~. Rickards, Esquire Attorney for: Defendants Date: November 20, 2003 01HB-00142 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendants PETER J. SAKOL, AND CAROLYN M. ANNER (PLAINTIFFS) VS. GRETA OLSON AND BRAD OLSON, (DEgENDANTS) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY~ PENNSYLVANIA NO. 02-612 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendants herein, and that he caused a true and correct copy of Praecipe for Listing Case for Trial to be served by regular first class mail upon: Dated: November 20, 2003 Gerard C. Kramer, Esquire 209 State Street Harrisburg, PA 17101 Girard E. Rlckards, Esquire Attorney for Defendants PETER J. SAKOL, M.D and CAROLYN M. ANNER, Husband and Wife, · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-612 CIVIL TERM BRAD OLSEN ORDER OFCOURT AND NOW, December 9, 2003, the above case is removed from the January trial term at the request of the plaintiffs. The Court notes that this is a delay attributable to the plaintiffs. ~Gerard C. Kramer, Esquire Schmidt, Ronca & Kramer, P.C. 200 State Street Harrisburg, PA 17101 ,//Girard E. Rickards, Esquire 214 Senate Drive Suite 507 Camp Hill, PA 17011 Court Administrator File No.: 01HB-00142 PRAECIPE FOR RE-LISTING CASE FOR TRIAL (Must be typewrittefi and submitted in dupl~ TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case (check one): ( x ) for JURY trial at the next term of civil court. CAPTION OF CASE: (Entire Caption Must Be Stated In Full) Peter J. Sakol, M.D. and Carolyn M. Anner, husband and wife, VS. Plaintiffs Brad Olson, (Check One) ( ) Assumpsit ( ) Trespass ( x ) Trespass (Motor Vehicle) ( ) (Other) Defendant The trial list will be called on_ February 17, 2004 Trials commence on March 15, 2004 Pre-trials will be held on February 25, 2004 (Briefs are due 5 days before pre-trials.) (~l~e party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214-1.) No.. 02-612 Civil __20 0.~_2 Indicate the attorney who will try case for the party who files this praecipe: Girard E. Rickards Es uire Attorne for Defendant- Jacobs & Associates 214 Sen. ate Aven. ue Suite 503 Cam Hill Penns lvania 17011' ~Indicate trial counsel for other parties ff known. Gerard C. Kramer Es uire Attorne for Plaintiffs- Schmidt Ronca & Kramer 209 State Street Harrisbur Penns lvania 1710~~6300 This case is ready for tri~~j~.~ Signed:~~~~-~~-- Print Name:. Girar[E. Rickards, Esquire Attorney for:_ Defendants Date: December 15, 2003 01HB-00142 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant PETER J. SAKOL, AND CAROLYN M. ANNER (PLAINTIFFS) VS. BRAD OLSON, (DEFENDANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-612 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of Praecipe for Re-Listing Case for Trial to be served by regular first class mail upon: Gerard C. Kramer, Esquire 209 State Street Harrisburg, PA 17101 Dated: December 15 2003 Girard E. Rickards, Esquire Attorney for Defendant PETER J. SAKOL, M.D. and CAROLYN M. ANNER, husband and wife, and CAROLYN M. ANNER, in her own right, Plaintiffs GRETA AND BRAD OLSEN, Defendants : IN THE COURT OF COMMON : PLEAS, CUMBERLAND COUNTY, : PENNSYLVANIA : : NO. 02-612 (Civil Term) : CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Gerard C. Kramer, Esquire, and SCHMIDT, RONCA, & KRAMER, P.C., as attorneys of record for the Plaintiffs in the above-captioned action. SCHMIDT, RONCA/~ KRAMER, P.C. BY · Kramer, Esquire Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232--6300 PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of G. Thomas Miller, Esquire, and MILLER & MILLER, as Attorneys of record for the Plaintiffs in the above-captioned action. MILLER/~ MI~,ER ~3~o~n~as Miller, Esquire 401 S. 32nd Street Camp Hill, PA 17011 (717} 920-5500 CERTIFICATE OF SERVICE I hereby certify that the copies of the foregoing Praecipe to Withdraw/Enter Appearance were this day served upon other counsel of record by United States First class mail, postage prepaid, addressed as follows: Edward McKarski, Esquire 107 North Commerce Way Bethlehem, PA 18017-8930 MILLER AND MILLER G. TH~A~ MILL'-E'R 401 South 32na Street Camp Hill, PA 17011-5105 Telephone: (717) 920-5500 Fax: (717) 920-5503 Attorney For Plaintiffs Date: January 29, 2004 File No.: 01HB-00142 PRAECIPE FOR RE-LISTING CASE FOR TRIAl, (Must be typewritten and submitted in duplicate.) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case (check one): ( x ) for JURY trial at the next term of civil court. ( ) for trial without a iur~,. CAPTION OF CASE: (Entire Caption Must Be Stated In Full) Peter J. Sakol, M.D. and Carolyn M. Anner, husband and wife, Plaintiffs VS. (Check One) ( ) Assumpsit ( ) Trespass ( x ) Trespass (Motor Vehicle) ( ) (Other) Brad Olson, Defendant The trial list will be called on April 6, 2004 Trials conunence on May 3, 2004 Pre-trials will be held on April 14, 2004 (Briefs are due 5 days before pre-trials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214-1.) No. 02-612 Civil 20 02 Indicate the attorney who will try case for the party who files this praecipe: Girard E. Rickards, Esquire, Attorney for Defendant; Jacobs & Associates, 214 Senate Avenue, Suite 503, Camp Hill, Pennsylvania, 17011; (717) 731-0988. Indicate trial counsel for other patties if known: G. Thomas Miller, Esquire, Attorney for Plaintiffs; Miller and Miller, 401 South 32~ Street, Camp Hill, Pennsylvania 17011; (717) 920-5500 This case is rea~ Signed:. Prim Name: Girard E. Rickards, Esquire Attorney for: Defendants Date: January 30, 2004__ 01HB-00142 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant PETER J. SAKOL, AND CAROLYN M. ANNER (PLA T VVS) VS. BRAO OLSON, (DEFENDANT) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02-612 CIVIL ACTION - LAW JURY TRIAt, DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of Praecipe for Re-Listing Case for Trial to be served by regular first class mail upon: G. Thomas Miller, Esquire Miller and Miller 401 South 32"a Street Camp Hill, PA 17011 Dated:~ 2004 ~irard E. Rickards, Esquire Attorney for Defendant Peter J. Sakol, M.D. and Carolyn M. Anner, Husband and Wife V Brad Olson IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-0612 CIVIL TERM ORDER OF COURT AND NOW, February 23, 2004, by agreemem of counsel, the above captioned case is hereby continued from the March 15, 2004 trial term. Counsel is directed to relist the case when ready. ~/~erard C. Kramer, Esquire For the Plaintiff v/Girard E. Rickards, Esquire For the Defendant Court Administrator By the Court, ld PETER J. SAKOL, M.D., : IN THE COURT OF COMMON PLEAS OF and CAROLYN M. ANNER, : CUMBERLAND COUNTY, PENNSYLVANIA husband and wife, : Plaintiff V. : BRAD OLSON, : Defendant : NO. 02-612 CIVIL TERM ORDER OF COURT AND NOW, this 14th day of ~ril, 2004, this case is being removed from the trial list ~_n order to give the parties the opportunity to pursue mediation. The matter may be relisted, if necessary, once the mediation efforts have been completed. Plaintiff's counsel has committed to give defense counsel a letter confirming that his client will not be pursuing personal liability from the Defendant in the event of an excess verdict. By the Edward E. Guido, J. G. Thomas Miller, Esquire For the Plaintiffs Girard E. Rickards, Esquire For the Defendant Court Administrator :lfh ,~,i?.iO;'.iOi-L,'OL':~ ;~qi _40 File No.: 01HB-00142 PRAECIPE FOR RE-LISTING CASE FOR TRIAL (Must be typewritten 'and submitted in duplicate.) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case (check one): ( x ) for JURY trial at the next term of civil court. ( ) for trial without a iur~/. CAPTION OF CASE: (Entire Caption Must Be Stated In Full) Peter J. Sakol, M.D. and Carolyn M. Anner, husband and wife, Plaintiffs VS. (Check One) ( ) Assumpsit ( ) Trespass ( x ) Trespass (Motor Vehicle) ( ) (Other) Brad Olson, Defendant The trial list will be called on June 15, 2004 Trials cormnence on _ July 12, 2004 Pre-trials will be held on June 23, 2004 (Briefs are due 5 days before pre-trials.) (The patty listing this case for trial shall provide forthwith a copy of the praecipe to all counsel, pursuant to local Rule 214-1.) No. 02-612 Civil 20 02 Indicate the attorney who will try case for the party who files this praecipe: Girard E. Rickards, Esquire, Attorney for Defendant; Jacobs & Associates, 214 Senate Avenue, Suite 503, Camp Hill, Pennsylvania, 17011; (717) 731-0988. Indicate trial counsel for other parties if known: Joseph F. Roda, Esquire, Attorney for Plaintiffs, 801 Este~e, Lancaster, Pennsylvania 17601; (717) 892-3000 This case is ready for trial. Signed:_~ _~~~~--~'~/'~ Print Name: Girard E. Rickards, Esquire Attorney for: Defendant Date: May 19, 2004 01HB-00142 LAW OFFICES OF JACOBS & ASSOCIATES 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Telephone Number: (717) 731-0988 Attorneys for Defendant PETER J. SAKOL, AND CAROLYN M. ANNER (PLAINTIFFS) VS. BRAD OLSON, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02-612 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE Girard E. Rickards, Esquire, hereby certifies that he is the attorney for the Defendant herein, and that he caused a true and correct copy of P_raecipe for Re-Listing C~ase for Trial to be served by regular first class mail upon: Dated:~Ma¥ 19, 2004 Joseph F. Roda, Esquire Roda ° Nast, P.C. 801 Estelle Drive Lancaster, PA 17601 G. Thomas Miller, Esquire Miller and Miller 401 South 32~a Street Camp Hill, PA 17011 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PETER J. SAKOL, M.D. and CAROLYN M. ANNER, husband and : Wife, and CAROLYN M. ANNER, in Her own right, Plaintiffs, No. 02-612 BRAD OLSEN AND GRETA OLSEN,: Defendants. JURY TRIAL DEMANDED ENTRY OF APPEARANCE Please enter the appearance of the undersigned on behalf of Plaintiffs. EJ~H F. RODA Atty. Id. No. 20615 JENNIFER S. SNYDER Atty. I.D. No. 89495 RODA & NAST, P.C. 801 Estelle Drive Lancaster, PA 17601 Tel: 717-892-3000 DATE: June 2, 2004 CERTIFICATE OF SERVICE I hereby certify that I have today caused to be served via first class marl a copy of the foregoing Entry of Appearance on the fo]lowing: Girard E. Rickards, Esquire Jacobs & Saba 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 DATE: June 2, 2004 Kristen M. Leddy Legal Assistant IN THE COURT OF COMMON PLEAS OF CLrMBERLAND COUNTY, PENNSYLVANIA PETER J. SAKOL, M.D. and CAROLYN M. ANNER, husband and Wife, and CAROLYN M. ANNER, in Her own right, Plaintiffs, No. 02-612 BRAD OLSEN AND GRETA OLSEN, : Defendants. JURY TRIAL DEMANDED PRAECIPE FOR DISCONTINUANCE Please discontinue this case against both Defendants under Pa. R.C.P. 229. ~SEPi~F. 'RODA Atty. I.D. No. 20615 JENNIFER S. SNYDER Atty. I.D. No. 89495 RODA & NAST, P.C. 801 F, steHe Drive Lancaster, PA 17601 Tel: '717-892-3000 DATE: June 2, 2004 CERTIFICATE OF SERVICE I hereby certify that I have today caused to be served via first class mai] a copy of the foregoing Praecipe for Discontinuance on the £ollowing: Girard E. Rickards, Esquire Jacobs & Saba 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Kristen M. Ledfiy Legs] Assistant DATE: June 2, 2004 14. Peter J. Sakol, M.D. and Carolyn M. Auner, Husband and Wife V Brad Olson : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : : NO. 02-0612 CIVIL TERM ORDER OF COURT AND NOW, June 15, 2004, counsel having failed to call the above case for trial, the case is stricken fi.om the July 12, 2004 thal term. Counsel is directed to relist the case when ready. By the Court, Joseph R. Roda, Esquire For the Plaintiff Girard E. Rickards, Esquire For the Defendant Court Administrator ld 20D~ JU~I I '/ P~I I: b, I