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HomeMy WebLinkAbout02-0629RALPH LINDQUIST, Plaintiff, V. CHARLES SEAVER and RITE AID CORPORATION Defendants. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other Rites important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 NOTICIA Le hah demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas sugnuientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en con~ra de su persona. Sea avisado que si nsted no se defiende, la entre tomara me. didas y puede enirar una orden contra usted sin previo aviso o notificacinn y pot cualquier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o sus propiedades o olros derechns importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO 1MMEDIATEMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL D1NERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEPFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCR1TA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 240262.1 hMEK~LC4 RALPH LINDQUIST, Plaintiff, Vo CHARLES SEAVER and RITE AID CORPORATION, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW NO. C>;;[ JURY TRIAL DEMANDED COMPLAINT Plaintiff Ralph Lindquist is a citizen of the Commonwealth of Pennsylvania, who resides at 800 Mandy Lane, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant Charles Seaver is a citizen of the state of New York, who resides at 112 ½ W. Smith Street, Herkimer, New York. 3. Defendant Rite Aid Corporation is a Delaware corporation with its principle office located at 30 Hunter Lane, Camp Hill, Cumberland County, Pennsylvania. 4. At all times relevant to Plaintiff's Complaint, Defendant Charles Seaver was employed by Defendant Rite Aid. 5. At all times relevant to Plaintiff's Complaint, Defendant Charles Seaver operated a Ford Aerostar van owned by Defendant Rite Aid. 6. At all times relevant to Plaintiff's Complaint, Defendant Seaver was acting within the course and scope of his employment for Defendant Rite Aid Corp. 7. The facts and occurrences hereinafter related took place on March 21, 2000, at approximately 7:50 a.m., at the intersection of 34th and Market Streets in Camp Hill, Cumberland County, Pennsylvania. 8. Prior to the accident, Plaintiff Ralph Lindquist was stopped at a red traffic light at the intersection of 34a' and Market Streets while driving a 1997 Cadillac Eldorado and traveling eastbound on Market Street. 9. At that time and place, Defendant Seaver, operating Defendant Rite Aid's van, was stopped directly behind Plaintiff Ralph Lindquist at the red traffic light. 10. As the traffic light changed from red to green, Plaintiff Ralph Lindquist remained standing to allow the traffic in front of him to begin moving forward. 11. At that time and place Defendant Seaver began moving forward and violently collided with the rear-end of Plaintiff Ralph Lindquist's stopped vehicle. As a result of the above collision, Plaintiff Ralph Lindquist was thrown about his 12. vehicle. 13. The aforementioned accident and ail of the injuries and damages set forth above are the direct and proximate result of the negligent, careless, wanton, and reckless manner in which Defendant Seaver operated Defendant Rite Aid's vehicle within the scope and course of his employment as follows: (a) failure to have his vehicle under such control so as to be able to stop within the assured clear distance ahead; (b) failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the roadway; (c) failure to apply his brakes in time so as to avoid striking Plaintiffs vehicle; (d) failure to drive his vehicle with due regard for the highway and traffic conditions that were existing and of which he should have been aware; (e) failure to keep proper and adequate control over his vehicle; 240262. lXMEKXLC4 (f) otherwise driving his vehicle upon the highway in a manner endangering to persons and property and in a reckless manner with careless disregard to the Rites and safety of others and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania. 14. Plaintiff Ralph Lindquist sustained painful and severe injuries, which include, but are not limited to, cervical strain and an aggravated AC separation of the right shoulder as well as general shock to his nervous system. 15. As a result of the aforementioned injuries and resulting pain, Plaintiff Ralph Lindquist has undergone and in the future will continue to undergo physical and mental suffering, great inconvenience in carrying out his dally activities, loss of life's pleasures and enjoyment, and claim is made therefor. WHEREFORE, Plaintiff Ralph Lindquist demands judgment against Defendant Rite Aid Corporation and Charles Seaver in an amount in excess of Twenty-Five Thousand Dollars ($25,000), exclusive of interest and costs and in excess of any jurisdictional amount requiring compulsory arbitration. ~~K~ ~ ~uiri' C. I. D. No. 36513 4503 North Front Street Harrisburg, PA 17110-1799 (717) 238-6791 Counsel for Plaintiff 240262.1RvlEK~LC4 VERIFICATION I, RALPH LINDQUIST, do hereby swear and affirm that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that this verification is made subject to the penalties of the Rules of Civil Procedure relating to unswom falsification to authorities. Dated: ~,, ~a. ~. RALPH LINDQUIST, Plaintiff, CHARLES SEAVER and RITE AID CORPORATION, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW NO. 2002-00629 JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE This is to certify that on the 5th day of February, 2002 a tree and correct copy of the Complaint Civil Action No. 2002-00629 was mailed to CHARLES SEAVER by certified mail, return receipt requested at 112 ½ W. Smith Street, Herkimer, NY 13356. A copy of the certified mail receipt 7001 1940 0003 5168 4892 is attached hereto. Michelle. M. Milojevich ACCEPTANCE OF SERVICE This is to certify that on the 11th day of February, 2002, a Irue and correct copy of the above-noted Complaint was served upon the Defendant via certified mail, return receipt requested at the above-noted address. A copy of the signed receipt No: 7001 1940 0003 5168 4892 is attached hereto. Sworn to and subscribed before me this day of ~--~0[ U ~f~, 2002. ' Nota~ Public Michelle M. Milojevich 208149.1 hMEKhMMM 700t. 19~40 0003 ~- PS Form 3811, July lB 13ea~eec Reexn ~ l~ SHERIFF'S RETURN - REGULAR CASE NO: 2002-00629 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LINDQUIST RALPH VS SEAVER CHARLES ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RITE AID CORPORATION the DEFENDANT , at 1555:00 HOURS, on the 6th day of February , 2002 at 30 HUNTER LANE CAMP HILL, PA 17011 by handing to TRACY LANDIS, PARALEGAL a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing ~er attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this ~7~ day of So Answers: R. Thomas Kline 02/07/2002 ANGINOBy: & RovIq~ pu~y Sheriff POST & SCHELL, P.C. BY: PAUL W. GREGO I.D. #: 39701 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 ATTORNEYS FOR DEFENDANTS CHARLES SEAVER and RITE AID CORPORATION RALPH LINDQUIST, Plaintiff CHARLES SEAVER and RITE AID CORPORATION, Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 02-629, CIVIL PRAECIPE FOR ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Defendants, Charles Seaver and Rite Aid Corporation, relative to the above-captioned action. Date: POST & PAU~ !CHEL~f2 ORIGINAL CERTIFICATE OF SERVICE I, Candice M. Baker, an employee of the law offices of Post & Schell, P.C., do hereby certify that on the date listed below, I did serve a tree and correct copy of the foregoing document upon the following person(s) at the following address(es) by sending same in the United States First Class Mail, postage prepaid: Michael Kosik, Esquire Angino & Rovner 4503 North Front St. Harrisburg, PA 17110 Date: POST & SCHELL, P.C. /Candice M.~i~ayer .... POST & SCHELL, P.C- BY: PAUL W. GREGO I.D. #:39701 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 RALPH LINDQUIST, Plaintiff, CHARLES SEAVER and RITE AD CORPORATION, Defendants. ATTORNEYS FOR DEFENDANTS CHARLES SEAVER and RITE AID CORPORATION COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 02-629 CIVIL CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Michael E. Kosik, Esq. ANGIN0 & ROVNER, P.C. 4503 N. Front Street Harrisburg, PA 17110-1708 You are hereby notified to file a written response to the enclosed Answer with New Matter within twenty (20) days from service hereof or a judgment may be entered against you. POST & SCHELL P.C. By: Pt [1 '¢q. Gn ), Esquire A omey for DefendatSts Charles Seaver and Rite Aid Corporation ORIGINAL POST & SCHELL, P.C. BY: PAUL W. GREGO I.D. #:39701 240 GRANDVIEW AVENUE CAMP HILL, PA 17011 (717) 731-1970 RALPH LINDQUIST, Plaintiff, CHARLES SEAVER and RITE AD CORPORATION, Defendants. ATTORNEYS FOR DEFENDANTS CHARLES SEAVER and RITE AID CORPORATION COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 02-629 CIVIL CWIL ACTION - LAW JURY TRIAL DEMANDED ANSWER AND NEW MATTER NOW INTO COURT, through undersigned counsel, come the Defendants, who, in answer to the Complaint of the Plaintiff, respectfully represents that: 1. Defendants, pursuant to Pennsylvania Rule of Civil Procedure 1029(e), hereby generally deny the allegations of the Complaint, except to admit the allegations in paragraphs 2 and 3. WHEREFORE, Defendants pray that the Complaint be dismissed, at the cost of the Plaintiff. NEW MATTER The Defendants hereby raise the following New Matter: granted. 3. this action. The Plaintiff may have failed to state a cause of action upon which relief can be The applicable Statute of Limitations may have expired prior to the institution of 4. Defendants were not negligent. 5. Any acts or omissions of the Defendants alleged to constitute negligence were not substantial causes or factors of the subject incident and/or did not result in the injuries and/or losses alleged by the Plaintiff. 6. The incident and/or damages described in Plaintiff's Complaint may have been caused or contributed to by the Plaintiff. 7. The negligent acts or omissions of other individuals and/or entities may have constituted intervening, superseding causes of the damages and/or injuries alleged to have been sustained by the Plaintiff. 8. The Plaintiff may have assumed the risk. 9. The Plaintiff may have been contributorily negligent. 10. The incident, injuries and/or damages alleged to have been sustained by the Plaintiff were not proximately caused by Defendants. 11. Plaintiff may not have properly mitigated his damages. 12. Plaintiff may be bound by the limited tort option, and, as his injuries may not be considered "serious," non-economic damages would not be recoverable. WHEREFORE, Defendants pray that the Complaint be dismissed, at the cost of the Plaintiff. Date: Respectfully Submitted, POST & SCHEI~L~ PC. P Grego, Esq tomey for Defendants Charles Seaver and Rite Aid Corporation ATTORNEY VERIFICATION PAUL W. GREGO, ESQUIRE states that he is the attorney for the party serving the foregoing document; that he makes this Affidavit as an attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; that time is of the essence in the filing of this document; and that this statement is made subject to the penalties of Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: q~(~O~/ PAUl. ~REGO, ESQUIRE CERTIFICATE OF SERVICE I, Candice M. Baker, an employee of the law offices of Post & Schell, P.C., do hereby certify that on the date listed below, I did serve a tree and correct copy of the foregoing document upon the following person(s) at the following address(es) by sending same in the United States First Class Mail, postage prepaid: Michael Kosik, Esquire Angino & Rovner 4503 North Front St. Harrisburg, PA 17110 POST & SCHELL, P.C. RALPH LINDQUIST, Plaintiff, CHARLES SEAVER and RITE AID CORPORATION, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW NO. 2002-00629 JURY TRIAL DEMANDED PLAINTIFF'S REPLY TO DEFENDANTS' NEW MATTER AND NOW comes the Plaintiff Ralph Lindquist, by and through lfis attomeys, Angino & Rovner, P.C., and hereby }eplies to the New Matter of Defendants as follows: 2. Denied. This averment is a conclusion of law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that Plaintiff's Complaint fails to state a cause of action upon which relief can be granted. To the contrary, it is averred that Plaintiff's Complaint sets forth a cause of action for negligence in the operation of a motor vehicle by Defendant Charles Seaver as well as a claim against Defendant RIte Aid Corporation for respondeat superior for the negligence of their employee, Defendant Charles Seaver. 3. Denied. This averment is a conclusion of law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that the applicable statute of limitations expired prior to the institution of suit. As set forth in PlainfiWs Complaint, Plaintiff's cause of action arose as a result of a motor vehicle accident which occurred on March 21, 2000. Plaintiff's Complaint was filed on February 5, 2002 and served on Defendant RIte Aid Corporation on February 6, 2002 by the Cumberland County Sheriff. Plaintiff's Complaint was served on Defendant Charles Seaver via certified mail on February 11, 2002 as verified by an Affidavit of Service completed on February 13, 2002 as confirmed by the return of service from Defendant Seavers. Plaintiff maintains that both the filing of the Complaint and the 244170.1 ~IEKLMMM service on the Defendants occurred well before the two-year anniversary of the claim and that Plaintiff's claim is governed by the two-year statute of limitations contained in 42 Pa.C.S.A. §5524. 4. Denied. This averment is a conclusory statement unsupported by any factual statements and therefore is denied. It is specifically denied that the Defendants were not negligent. To the contrary, it is averred that Defendant Seavers was negligent in striking the rear of Plaintiff's vehicle and Defendant Rite Aid Corporation is negligent based upon the doctrine of respondeat superior. 5. Denied. This averment is a mixed conclusion of fact and law to which no responsive pleading is required. To the extent that a response may be required, it is specifically denied that Defendant's conduct was not a substantial factor in causing or aggravating PlaintiWs injuries, as set forth in PlaintiWs Complaint. 6. Denied. This averment is a conclusory statement unsupported by any factual statements and therefore no response is required. To the extent that a response may be required, it is specifically denied that Plaintiff Ralph Lindqnist was negligent in any manner upon the cause of action stated in his Complaint and therefore it is specifically denied that he caused or contributed to the accident or his injuries. 7. Denied. This averment is a conclusory statement unsupported by any factual statements as well as containing conclusions of law and therefore no responsive pleading is required. It is specifically denied that any other individuals or entities, not identified by the Defendants, were negligent in any manner in the happening of the accident. Therefore, it is denied that there was any intervening or superseding conduct or cause of Plaintiff's injuries or damages other than the conduct of the Defendants identified in Plaintiff's Complaint. 244170.1~IEK~IMM 8. Denied. This averment is a conclusion of law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that the defense of assumption of the risk is available to a defendant in a rear end motor vehicle accident. 9. Denied. This averment is a mixed conclusion of fact and law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that Plaintiff Ralph Lindquist was negligent in any manner upon the cause of action stated in Plaintiff's Complaint, and it is specifically denied that he was comparatively negligent in the happening of the accident. 10. Denied. This averment is a mixed conclusion of fact and law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that Plaintiff's injuries or damages were not proximally caused by the conduct of the Defendants. To the contrary, it is averred that Plaintiff's injuries and damages, as set forth in his Complaint, were the direct and proximate result of the Defendants' negligent conduct; 11. Denied. This averment is a mixed conclusion of fact and law to which no responsive pleading is required. To the extent that a response may be deemed proper, it is specifically denied that Plaintiff Ralph Lindquist failed to mitigate his damages. To the contrary, Plaintiff Ralph Lindquist at ail times followed the recommendations of his doctors concerning his care and recovery. 12. Denied. It is specifically denied that Plaintiff Ralph Lindquist was bound by the limited tort option. To the contrary, it is averred that Plaintiff Ralph Lindquist had selected full tort coverage on his automobile policy. It is specifically denied that Plaintiff's injuries should not be considered a serious impairment of a bodily function. To the contrary it is averred that Plaintiff Ralph Lindquist had ongoing pain and suffering and limitations in his daily activities. Plaintiff 244170.1 ~VlEK~VlMM Ralph Lindquist is permitted to recover both economic and non-economic damages against the Defendants as set forth in Plaintiff's Complaint. WHEREFORE, Plaintiffrespectfully request that this Honorable Court dismiss Defendants' New Matter emer judgment in favor of Plaintiff and agaln~ k~l~i~h'~ E. Kosik I.D. No. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiff 244170.1 ~[EK~IMM VERIFICATION o~ - ~. 5"- 0 ?_. I, RALPH LINDQUIST, Plaintiff, have read the foregoing Reply to New Matter and do hereby swear or affirm that the facts set forth in the foregoing are true and correct to the best of my knowledge, information and belief. I understand that this Verification is made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. RALPH L'-INDQU_.~ - 230542.1 ~VlEK~IMM CERTIFICATE OF SERVICE AND NOW, this 2nd day of April, 2002 I, Michelle M. Milojevich, an employee of Angino & Rovner, P.C., do hereby certify that I have served a true and correct copy oft.he PLAINTIFF'S REPLY TO DEFENDANTS' NEW MATTER in the United States mail, postage prepaid at Harrisburg, Pennsylvania, addressed as follows: Paul Grego, Esquire Post & Schell 1857 William Penn Way P. O. Box 10248 Lancaster, PA 17605-0248 Michelle M. IViifojevich 244170. I~VlEK~IMM CERTIFICATE PI~EQUISITE TO SERVIC~ 0F A SU~P0~.I~A PURSUANT TO RULE 4009.22 IN THE MATTER OF: RALPH LINDQUI ST COURT OF COMMON PLEAS TERM, -VS- CHARLES SEAVER & RITE AID CORP. CASE NO: 02-629 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of AMY L. CORYER, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/03/2002 cS on behalf of 0 U AttorMey for D~ENDANT DEll-321758 88506--L01 COMMON~sALTH OF PENNSYLVANIA COUNTY O~~ CUMBERLAND IN THE MATTER OF: RALPH LINDQUIST -VS- CHARLES SEAVER & RITE AID CORP. COURT OF COMMON PLEAS TERM, CASE NO: 02-629 NC~ICE OF IN~'~I~ ~0 SERVE A SUBPOENA TO PRODUCE DOCUMEI~S aND 'r~IN~S FOR DISCOVERY PURSUANT TO RULE 4009.21 MILLBACH ORTHOPARnICS DR.. DENNIS GILBERT DR. JONATRA# WHITNEY CO~Y MEDICAL ASSOCIATES STATE FArM MUTUAL INS. CO. ERIE INSUE~NCE GROUP HEDI~.AL RECORDS HEDICAL RECORDS MEDICAL RECORDS HEDICAL RECORDS INSURANCE INSURANCE TO: MICRA[q, E. KOSIK, ESQ. MCS on behalf of AHYL. CORYER, ESqUIrE intends to serve a subpoenaS? identical to the one that is attached to this notice. You have t~enty (20) days from the date listed below in~hich to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is ~raived or if no objection is made, then the subpoena may be served. C.--[.lete copies of any reproduced records may be ordered at your expense by c,,-,:,leting the attached counsel card and returning same to MCS or by contacting our local HCS office. DATE: 0311~12002 CC: AMY L. COR~, ESQUIRE - 0435~86485 MCS on behalf of AMY L. CORYER, ESqUIRE Attorney for DEFENDANT Any questions regarding this matter, contact TREMCS GROUP INC. 1601 HAKKET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-181247 88506--C01 _COMMON'WEALTH OF PE~SYI. VANI.L COUNTY OF CUMBERLA.ND RALPH LINDQUIST VS CHARLES SEAVER & RITE AID CORP. File No. 02-629 SUBPOENA TO PRODUCE DOCUM~'TS OR THLNGC FOR DISCOVERY PURSUA.N-I' TO RULE 4009 TO: CUSTODIAN OF RECORDS FOR: MILLBACH ORTHOPAEDICS & PREVENTIVE HEALTH IName of Pe~oon o~' ~,~a?j ching~ at MCR O. Rf~lTP TNC.. 1601 MARR'IET .qT. #ROil. PHTLA.PA 19103 You may dei~'et at mail le~ble copies of tho do~amenti at produce th,inlJI eequeeted by this subpoena, together with the ce~ificate o..' compliance, to tho p&'~. o~,lkifl$ this request at tho edd.'l~ lleecl above. You have the risht to seek. in adva2~ce, I,he ~uonable cost of prepm"JnS tho copies at producing the t~inf~s so~Shi. you fail to r"'roduce the documents or thinp required by this subpeer~, ~ ~,efl~ (20) days after its service, the patty. servifl$ this subpoena may seek · cou'l order compelling you to comply w~th THIS SUBPOENA WAS ISSUED AT Ti-IE REQUEST OF ~ F-OLLOWING PERSON: N.~uME: AMY CORYER~ ESq. ADDRESS: 9an ~.I~AlgnVTVIJ pl~, C~ HILL, PA 17011 TELEPHON~ 215-24~0~00 SUPR~ CO~ ID ~ A~O ~ ~ DEFEND~T Se~l of the Com'~ (--ff. EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MILLBACH ORTHOPAEDICS & PREVENTIVE HEALTH 101 S. MILLBACH RD. NEWMANSTOWN, PA 17073 RE: 88506 RALPH LINDQUIST Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject :RALPH LINDQUIST - Social Security ,q:. 158-20-6567 Date of Birth: 01-27-1929 SU10-361768 88~50 6 --LO1 CERTIFICATE PREREQUISITE TO SElbY'ICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RALPH LINDQUIST COURT OF COMMON PLEAS TERM, -VS- CHARLES SEAVER & RITE AID CORP. CASE NO: 02-629 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of AMY L. CORYER, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/03/2002 MCS on behalf of AMY L. CORYER, ESQUIRE Attorney for DEFENDANT DEll-321759 8850 6--L02 COI~IlvlOSr~rI~ALTH OF PENNSYLVANIA COUNTY OF CO%IBERLAND IN THE MATTER OF: RALPH LINDQUIST -VS- CHARLES SEAVER & RITE AID CORP. COU~T OF COMMON PLEAS TERM, CASE NO: 02-629 NOTICE OF IN'~NT ~0 SERVE A SUBPOENA 'PO PRODUCE DOCIIMRWS AN~ · i',-,i~GS FOR DISCuv,zK~ PURSUAI~I' TO RULE 4009.2] HILLBACH ORTHOPAEDICS DR. DENITIS GILBE~tT DR. JONATHAN ~HITNEY CO~L~Y ~DICAL AS$OCIATHS STATE FA~I4 HUTUAL INS. CO. ERIE INSURANCE GROUP HEDICAL RECORDS HEDICAL RECORDS ~DICAL RECORDS HEDICAL ~CORDS INSURANCE INSURANCE TO: H~CRA~. E. KOSIK, ESQ. , HC$ on behalf of AHY L. CORYER, ESQUIRE intends to serve a subpoe~ identical to the one that is attached to this notice. You have t~renty (20) days from the date listed belme in ~hich to file of record and serve upon the undersigned an objection to the subpoena. If the t~enty day notice period is · raived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contactin$ our local MCS office. DATE: 03114/2002 CC: AMY L. C0E%'~R, ESQUIRE - 0435186485 MCS on behalf of AMY L. CORYE~, gSqUIRE Attorney for DEI~NDANT Any questions regarding this matter, contact · ru~ HCS GROUP INC. 1601HAR~ET STg~T #800 PHILADELPHZA. PA 19103 (215) 246-0900 DE02-181247 88--~06 --C03_ COMMONWEALTH OF PE~$Y%VANI3. COUNTY OF CUMBERI_~\'F) RALPH LINDQUIST VS CHARLES SEAVER & RITE AID CORP. FHe No. 02-629 SUBPOENA TO PRODUC£ DO~'T$ OR TI"ILNG$ FOR DISCOVERY PURSUA. N-I' TO RULE 4009 ~'~ TO: CUSTODIAN OF RECORDS FOR: DR. DENNIS GILBERT (Nam, af P.-r~.c,a ,r ~..~. ~ at MCR C. RnuP TNC.. 1601 MARW~T ST. #~]0. PHTT,A.PA 19103 (Addrtss) YOu may de~'ff m m~l le~ble copi~ of the d~mefl~ or produce t~ ~u~ed by t~s sub~nL together with the ~e~ificare ~ compH~ce, to the p~ m~fl~ this t~uflt at the id~ ~ a~e. You advmee, thf ~uonable c~t of prep~nS the copifl or producinS th~ ~ ~t. Il you f~t m ~oduce the d~ments or t~np requir~ by t~s sub~ ~ ~en~ (~) days se~'i~ t~ s~e~ may ~k i c~ ord~ compelling you m comp~ ~ ~ SL'SPOk-WA WAS ISSULrD AT THE R£QUF_~ OF TH~ r-OLLOWING PERSON: AMY CORYER~ ESQ. ADDRF:~.~: ~an e.~a~mvTma ~n CAMP HILL, PA 17011 TEL E?HO.%'~ 215-246-0900 $UPRF~M£ COURT ID ~ A I'TO R.Nk'"f ~)K: DEFENDANT Sea] of the Co~'t EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. DENNIS GILBERT 50 NORTH MARKET STREET ELIZABETHTOWN, PA 17022 RE: 88506 RALPH LINDQUIST Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. ~ua.t~.s Requested: up to and including the present. bject: RALPH LINDQUIST Social Security #: 158-20-6567 Date of Birth: 01-27-1929 SU10-361770 88506--L02 90909090909.22 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009090909090909090909090909090909090909090 IN THE MATTER RALPH LINDQUIST COURT OF COItiON PLEAS TERM, -VS- CHARLES SEAVER & RITE AID CORP. CASE NO: 02-629. As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of AMY L. CORYER, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) NO objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/03/2002 MCS on behalf of AMY L. ¢ORYER~ ESQUIRE Attorney for DEFENDANT DEll-321760 88506--L03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CO'MBERLAND IN THE .MATTER OF: RALPH LINDQUIST -VS- CHARLES SHAVER & RITE AID CORP. COURT OF COP~40N PLEAS TERM, CASE NO: 02-629 NOTICE OF I~TzNT TO SERVE A SUBPORNa TO PRODUCE DOCI~S AND FOR DISCOVz~tx PURSUANT TO RULE 4009.2] ~frT.T.BAC~ ORTHOPAEDICS DR. DENNIS GILBERT DR. JO~ATBAN COI~EY MEDICAL ASSOCIATES STATE FA~4 MUTUAL INS. CO. ERIE INSURANCE 6ROUP MEDICAL RECORDS HEDICAL RECORDS ~DICAL RECORDS HEDICAL RECORDS INSURANCE INSURANCE TO: MICRA~. E. KOSIK, ESQ. MCS on behalf of AMY L. CORYER, ESQUIRE intends to serve a subpoe~ .. identical to the one that is attached to this notice. You have t~enty (20) days from the date listed belme in~hich to file of record and serve upon the undersigned an objection to the subpoena. If the t~enty day notice period is ~aived or if no objection is made, then the subpoena may be served. C~lete copies of any reproduced records may be ordered at your expense by c~,pleting the attached counsel card and returning same to HCS or by contactivg our local HCS office. DATE: 03/14~2002 CC: AFl L. CORI~, ESQU/~tE - 0435/86485 HCS on behalf of AHYL. CORYER~ ESQUIRE Attorney for DEFENDANT Any questions regarding this matter, contact Tt:u~MCS GROUP INC. 1601PlARl~T STRI~*T ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-1812&7 88~06--C0]_ GOMMONWEALTH OF PE~$YLVANI.% C, ,OUNTY 0 F CUMB ER L~.\'D RALPH LINDQUIST VS CHARLES SEAVER & RITE AID CORP. FHe 02-629 SUBPOENA TO PRODUCE DO---rS OR THING~, FOR DISCOVERY PURSUANT TO RULE 4009 7" CUSTODIAN OF RECORDS FOR: DR. JONATHAN WHITNEY {Name o/P,~on or 7.~Z,,..~ rwe.."~. - C~n) days a~ctet service of th~s ,ub~o~rm,_You are order*ed I~* ~e ~fl to product the following d~uments or '~ SEE A~ACHED ' at MC.q OROUP INC... 1601 MARKET ,qT. $;R00, PHTT.A.PA 19103 =--~- You may doit'et ~t mail losable copiee of the documeflt,j or produce th.ina~ requested by, th.is subpoena, together with the certificate ~.' compliance, to the pa,'x? ma,~,~ng Oh's request al the add. res~ LL~ed al:~ve. You have the riSht co s,k. in advance. Lhe ."euoflable c~Jt of pteparifls the ¢opie~ ot ptoducifl$ the th~n~ ~IL 1£ you ~a.il tc .,--.oduce the documents oF things required by t~s sub,nm, w,tt,~.,.in twefltv (20} cla,~.s abet its sera'ice, the pa'Q/ sera'in! t~'.is s::b::mefla may seek a c~u'~ order compelling you to comply w~th ~. ' ' T:-IIS SL'~PO~:~/A WAS ISSUED AT TI-IE REQUEST OF ~ r-OLLOW'I!WG PERSON: N..~MI~- ANY C0RYER~ ESq. ADDRF.$S: ~tn nna~mw~'x~ CAMP MILL, PA 17011 T£LEPMON-'- 215-246-090n A~'r 0 R.N~'Y FO~: DEFENDANT EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. JONATHAN WHITNEY COWLEY ASSOCIATES 425 NORTH 21ST ST. CAMP HILL, PA 17011 RE: 88506 RALPH LINDQUIST Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates iRequested: up to and including the present. Subject :RALPH LINDQUIST Social Security ~ 158-20-6567 Date of Birth: 01-27-1929 SU10-361772 88506--L03 CERTIFICATE PREP, EQUISIYE TO Sw--RVICE OF A SUBPOgNA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RALPH LINDQUIST COURT OF C0~40N PLEAS TERM, -VS- CHARLES SEAVER & RITE AID CORP. CASE NO: 02-629 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of AMY L. C0RYER, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04103/2002 MCS on behalf of AMY L. CORYER, ESQUIRE Attorney for DEFENDANT DEll-321761 8~5~50 6--LO4 COI~iO[~-~,~EALTH OF PENNSYLVANIA COUNTY OF C~4BERLAND IN THE MATTER OF: RALPH LINDQUIST -VS- CHARLES SEAVER & RITE AID CORP. COURT OF C0~40N PLEAS TERM, CASE NO.' 02-629 NOTICE OF IN~',~NT TO SERVE A SUBPOENA TO PRODUCE DOC~TS' aN~ · ku~H~S FOR DISCO~=~ ~u~SUANT TO RULE 4009.21 HZLLBACH OHTHOpAK~ICS DH. DENNIS GILBEHT DH. JONAI~AN ~ITNEY CO~EY HEDICAL ASSOC~ATES STAI~ FArM M~TUAL INS. CO. KRIK INSUP~NCK GHOUP MEDICAL P~CORDS I~DICAL ~ECO~DS ~DICAL RE00~DS MEDICAr. RECORDS INSUP~NCK TO: HZCRA~. E. EOSIK, ESQ. HCS on behalf of AMY L. COHYEH~ ESqFLHE intends to serve a subpoe~; identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in ~hich to file of record and serve upon the undersiKned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Cm~plete copies of any reproduced records may be ordered at your expense by cmspleting the attached counsel card and returning same to HCS or by contactin8 our local HCS office. DATE.- 0311412002 CC: AM'/ L. CO~TE~, ESqU~ - 0435186485 )4CS on behalf of AMY L. CORYER~ ESqUIHE Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 HARLOT STut*~T ~800 PHILADKLPHL%, PA 19103 (215) 246-0900 DE02-181247 88506--C0~_ C .O~MONWEALTH ,OF PE~SYLVANLL COUN .TY OF CUMB ERL~\,r) RALPH LINDQUIST VS CHARLES SEAVER & RITE AID CORP. ~,,Ze No. 02-629 SUBPOENA TO PRODUCE DO~'T$ OR THLN'G$ FOR DISCOVERY PURSUA.N-r TO RULE 4009 TO: CUSTODIAN OF RECORDS FOR: COWLEY MEDICAL ASSOC. ~'lthin r~e.--~..' (~) d~ys ~ s~ic* of t~s sub~ you ~ ord~ ~ ~ ~m to produc~ the followi.~ d~uments or thin~ SEE A~ACHED al MCR ~ROUP TNC. 1601 MARKET RT. #:qOO. PT~TT.A~PA lqlO~ You may de~'~ ~ m~l feeble copi~ of the d~men~ or produce t~ ~u~ed ~ t~s sub~n~ to~ether with the ~ :ni~ca~e ~ compli~ce, to the p~ ~nS this r~u~t at the id~ ~ ~ ~v~ce. ~he ~uonable COSt of ptep~n& the copifl or producing the ~ ~L H you f~l m ~oduce ~he d~mems or t~np requit~ by t~s sub~ sec'inS ~ s~ena may s~k a c~ ord~ compelHn~ you to comply ~ · ~.-'.:~ ~L~?O-~WA WAS ISSU%'D AT THE REQL~ST OF ~ FOSLQWTNC P£RSON: N.~M~ ~ CORYERt ESQ. TELEPHON~ 215-246-0g00 S~PR~ME CO~ lO ~ A~O~N~' ~ , DEFENDANT EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COWLEY MEDICAL ASSOCIATES 25 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 88506 RALPH LINDQUIST Any and all records, correspondence, files and memorandums, handwritten notes, billing and payment records, relating to any examination, consultation, care or treatment. Dates Requested: up to and including the present. Subject: RALPH LINDQUIST Social Security #: 158-20-6567 Date of Birth: 01-27-1929 SU10-361774 88506--L04 CERTIFICATE PREREQUISI?E TO $1~R¥ICE OF A S~PO~NA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RALPH LINDQUIST COURT OF COP~40N PLEAS TERM, -VS- CHAKLES SEAVER & RITE AID CORP. CASE NO: 02-629 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of AMY L. CORYER, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, includinE the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/03/2002 MCS on behalf of AMY L. CORY]ER, ESQUIRE Attorney for DEFENDANT DEll-321762 88~0 6--LO5 CO~40~ALTH OF PENNSYLVANIA COUNTY OF C~BE~LAND IN THE MATTER OF: RALPH LINDQUIST -VS- CHARLES SHAVER & RITE AID CORP. COURT OF C0~0N PLEAS TERM, CASE NO: 02-629 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE D(X~MRuTS &~ THINGS FOR DISCoggR¥ PURSUANT TO RULE 4009.21 HILLBACH ORTHOPAEDICS DR. DENNIS GILBERT DR. JONATHAN ~HITI~Y COMLKY HKDXCAL ASSOCIATES STATE PA~14 MUTUAL INS. CO. ERIE INSURANCE GROUP ~DICAL RECORDS )~DICAL RECOF, DS HEDIC&L ~ECORDS HEDICAL RECORDS INSURANCE HCS on behalf of AMYL. CORYERt ESQUIRE intends to serve a subp~ identical to the one that is attached to this notice. You have twenty (20) days frcm the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is ~aived or if no objection is made, then the subpoena may be served. C~lete copies of any reproduced records may be ordered at your expense by c.'-~:.leting the attached counsel card and returning same to HCS or by contacting our local HCS office. DATE: 0311412002 CC: AMY L. COi%'~, ESQUIRE - 0435186485 HCS on behalf of AHY L. CORYKR~ ESqUIRE Attorney for DEFENDANT Any questions resardin8 this matter, contact Tu~ MCS GROUP INC. 1601 PAUt'~T STUNT J800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-181247 88.~06--C0~. _COMMON'WEALTH OF PE~$YT_VANi.L COUNTY OF CUMB ERL.-k.ND RALPH LINDQUIST VS CHARLES SEAVER & RITE AID CORP. File No. 02-629 SUBPOENA TO PRODUCE DO~'T$ OR THL',4Gq FOR DISCOVERY PURSUA.N-I' TO RULE 4009 TO: CUSTODIAN OF RECORDS FOR: STATE FkRM INSURANCE lhin~ at MC.~ C, ROTTP TNC... 1601 MARKET RT. #800. PRTT,A.PA 19[03 You may ~e~'~ ~ m~I le~ble copi~ of the d~men~ or p~du~e t~ ~u~d by t~s su~n~ ~og~Ser wi:~ the :eniflc~te ~ tom,Ii,ce, ro ~he p~ m~n~ thi, r~u~t at the Id~ ~ a~. You ~ve the fight to see~ in advice, the ~uonable Cos~ of prep~n~ the co~i~ or producin~ the ~ I[ you f~l to ~oduce the d~umems or t~np required by t~s sub~ se~'in~ t~ sub~e~ rely ~k ~ ~ ord~ compellln~ you to compl~ THIS SUBPOENA WAS ISSUED AT THE REQUF. ST OF ~ FOLLOWING PERSON: AMY CORYER~ ESQ. ' ADDRESS: 9&o c, am~vr~x~ ~n C~ HILL, PA 17011 TELEPHON~ 215-2A6rOqOO SUPR~%{~ CO~ ID e A~O ~' ~ DEFENDANT Seal o~ the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: STATE FARM MUTUAL INS. CO. P.O. BOX 0257 NEW CUMBERLAND, PA 17070 RE: 88506 RALPH LINDQUIST CLAIM # 38J540862; DOL 09/29/2000; POLICY # 6031979381 INSD: HOMER KELLER Any and all claims files. Dates Rea~uested: up to and including the present. Subjec : RALPH LINDQUIST Social Security #: 158-20-6567 Date of Birth: 01-27-1929 Date of Loss: 03/21/2000 SU10-361776 88506--L05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: RALPH LINDQUIST COURT OF C0[940N PLEAS TERM, -VS - CHARLES SEAVER & RITE AID CORP. CASE NO: 02-629 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of AMY L. CORYER, ESQUIRE certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/03/2002 MCS on behalf of AMY L. CORYER~ ESQUIRE Attorney for DEFENDANT DEll-321763 815150 6--L0 6 COI~4ONX~EALTH OF PENNSYLVANIA COUNTY OF CT31~iBERLAND IN THE MATTER OF: RALPH LINDQUIST -VS- CHARLES SHAVER & RITE AID CORP. COURT OF COFD40N PLEAS TERM, CASE NO: 02-629 NOTICE OF Iler~ ~O SERVE A SUBPOENA ~O PRODUCE DOCUMEI~S AND · I'~INGS FOR DISCOVERY PURSUAN~ ~O RULE 4009.21 ~IJ.SACH ORI~OPAEDIC$ DR. DENNIS GILBERT DR. JONATHAN ~HXTNEY CO~LEY MKDICAL ASSOCIATES STATE FARM ~0TUAL INS. CO. I~TE INSURANCE GROUP J~DI~ u~CORDS ~I)ICAL RECORDS MKDICAL RECORDS MKDICAL RECORDS INSURANCE INSURANCE TO: HICHAKL E. KOSIK, ESQ. NCS on behalf of AMY L. COHYERr ESQUIRE intends to serve a subpoe~ identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in ~hich to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning s,m~ to HCS or by contacting our local HCS office. DATE: 0311412002 CC: AMY L. CORYER, ESQUIRE - 0435~86485 HCS on behalf of AMY L. CORYER, ESQUIRE Attorney for DK~EI~DAHT Any questions resarding this matter, contact Tu~MCS GROUP INC. 1601NAREET STUNT tS00 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-181247 88506--C01 coMmo nv ^t'r oF eE, s v COU'N'Z'r Or COMBERL~.\'D RALPH LINDQUIST VS CHARLES SEAVER & RITE AID CORP. No. 02-629 SUBPOENA TO PRODUCE Dock-rs OR THINGS FOR DISCOVERY PURSUAN'r TO RULE 4009 ?'~ TO: CUSTODIAN OF RECORDS FOR: ERIE INSURANCE GROUP IName or Pe~on a~ [hins~ at MCR GROUp TNC.. 1601 MARl(ET .qT. tiff00. PHTI,A,PA 19103 You may. de[h'er or mail legible copiff of the do~umeflts or produce thir~ ~uestod by. t~s subp~nL together wi~h the cemficate M compli~ce, m the p~ m~ng this r~uest a* the adW ~ a~e. You ~ve the right to see~ in advice. ~he ~uonable cost of prep~nS the copifl or produdfl~ the ~n~ ~t. you fa~l ro ~oduce the do~umen~ or thinp required by ~his subpqMrta, withL-.i rwen~ (20) days a~ter i~s ser%'ice, the pa, fy servin$ r.~s subpoena may seek a court order compollifl$ you to comply with i~ THIS SL'BPO~A WAS ISSUED AT THE REQtfEST OF ~ FOLLOW~G PERSON: NAM1~. A~Y GORYER~ ES(~. ' ADDRESS: ~an ~nA~r~ nn C~ HILL, PA 17011 TELEPHON~ 215-2~-0q00 SUPR~%~ CO~ ID ~ A~O~' ~ DEFE~ANT Seal of the ~o~rt EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ERIE INSURANCE GROUP P.O. BOX 2013 4901 LOUISE DRIVE MECHANICSBURG, PA 17055 RE: 88506 RALPH LINDQUIST INCLUDE DEC PAGE AND PIP PAYMENT LEDGER; DATE OF LOSS: 03/21/2000 CLAIM # 010170482871001 Any and all claims files. Dates Requested: up to and including the present. Subject: RALPH LINDQUIST Social Security #: 158-20-6567 Date of Birth: 01-27-1929 Date of Loss: 03/21/2000 SU10-361778 88506--L06 RALPH LINDQUIST, Plaintiff, CHARLES SEAVER and RITE AID CORPORATION, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW NO. 2002-00629 JURY TRIAL DEMANDED PRAECIPE FOR DISCONTINUANCE TO THE PROTHONOTARY: Please mark the docket settled, satisfied and discontinued in the above-captioned action. ylER, P.C. tael E. Kosik I.D. qo. 36513 4503 N. Front Street Harrisburg, PA 17110 (717) 238-6791 Attorney for Plaintiff DATED: 10/8/02 cc: Paul Grego, Esquire