Loading...
HomeMy WebLinkAbout12-7721 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorne s for Plaintiff TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA J ~~ CIVIL ACTION -LAW JURY TRIAL DEMANDED v. ROSELLA M. WARRICK, Defendant NU~'tC~ _. -..1 ~ '- i ~i.~ e1 ~~' e.. ~ ~~ rt ~ ~ i;h;~~ r L~r~~~l YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that, if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA. 17013 (717) 249-3166 S $/03 , h~ e~~SGav ~-a~~~~ SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Plaintiff v~ CIVIL ACTION -LAW ROSELLA M. WARRICK, Defendant JURY TRIAL DEMANDED Nf3TlC1~1 LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la torte tomaro medidas y puede entrar una Orden contra usted sin previo aviso o notoficacaion y por cualquier queja o alivio que es pedido en la petition do demanda. usted puede perder dinero o sus propiededas o otros derechos importantes pars usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACIbN SOBRE LAS AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CORGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Lawyer Referral and Information Service LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA. 17013 (717) 249-3166 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ~~ ~ ~ ~ Gt,/v~I ~ClM v~ CIVIL ACTION -LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant COMPLAINT AND NOW comes the Plaintiff, TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, by and through her attorneys SHOLLENBERGER & JANUZZI, and does respectfully set forth the following: FACTS APPLICABLE TO ALL COUNTS 1. Plaintiff, TRACY L. RAMSEY, widow of the deceased, LEON G. RAMSEY, is an adult individual who resides at 116 Elm Street, Carlisle, Cumberland County, Pennsylvania. 2. Plaintiff, TRACY L, RAMSEY, is the Personal Representative of the Estate of LEON G. RAMSEY, by virtue of Letters of Administration granted by the Register of Wills, Cumberland County, Pennsylvania on July 12, 2011. A copy of these letters is attached hereto and incorporated by reference herein as Exhibit A. 3. Defendant, ROSELLA M. WARRICK, is an adult individual whose last known address is 161 Spur Road, Carlisle, Cumberland County, Pennsylvania. 4. The facts and circumstances hereinafter set forth took place on June 11, 2011, at or about 4:06 p.m., at or about the intersection of State Route 74NVaggoners Gap Road and Spur Road, North Middleton Township, Cumberland County, Pennsylvania. 5. At the aforesaid time and place, the deceased, LEON G. RAMSEY, was the owner and operator of a 2006 Kawasaki Ninja 1000 Motorcycle, bearing Pennsylvania Registration Number 7133P. 6. At the aforesaid time and place, Defendant, ROSELLA M. WARRICK, was the owner and operator of a 2005 Chevy Cobalt, bearing Pennsylvania Registration Number EBX8362. 7. At the aforesaid time and place, the deceased, LEON G. RAMSEY, was operating the aforesaid 2006 Kawasaki Ninja 1000 northbound on State Route 74NVaggoners Gap Road. 8. Defendant, ROSELLA M. WARRICK, was operating the 2005 Chevy Cobalt on Spur Road and was stopped at or behind the stop sign governing her direction of travel at the intersection of Spur Road and State Route 74/Waggoners Gap Road. 9. From a position at or behind the posted stop sign, Defendant, ROSELLA M. WARRICK, initiated a left hand turn onto southbound State Route 74NVaggoners Gap Road and directly into the path of a 2006 Kawasaki Ninja 1000 operated by the deceased, LEON G. RAMSEY when the motorcycle was so close as to constitute a hazard, whereupon the vehicles collided resulting in deceased, LEON G. RAMSEY, being thrown from the 2006 Kawasaki Ninja 1000, causing fatal injuries. COUNT I - NEGLIGANCE TRACY L. RAMSEY, as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, vs. ROSELLA M. WARRICK 10. Paragraphs 1 through 9 of the Plaintiff's Complaint are incorporated herein by reference and made part hereof as if set forth in full. 11. The aforesaid collision was the direct and proximate result of the negligence of Defendant, ROSELLA M. WARRICK, in operating the 2005 Chevy Cobalt in a careless, reckless, manner as follows: a. Failing to yield the right of way to another vehicle approaching an intersection on another roadway when that vehicle was so close as to constitute a hazard during the time that she was moving her vehicle within the intersection or junction of the roadways in a manner contrary to a preferential right of way stop sign placed at that intersection in violation of Section 3323 (b) of the PA Motor Vehicle Code; b. Failing to yield the right of way to another vehicle in the intersection in violation of Section 3323 (b) of the PA Motor Vehicle Code; c. Failing to stop her vehicle at the point nearest the intersecting roadway where she had a clear view of approaching traffic on that intersecting roadway before entering it in violation of Section 3323 (b) of The PA Motor Vehicle Code; d. Failing to slowly pull forward from a stopped position to a point where she had a clear view of approaching traffic after stopping at a clearly marked stop line in violation of Section 3323 (b) of the Pennsylvania Motor Vehicle Code; e. Driving her motor vehicle in such a manner as to deprive a motorcycle of the full use of its lane of travel in violation of Section 3523 (a) of The PA. Motor Vehicle Code; g. In failing to apply the brakes in time to avoid the collision; and h. In failing to observe Plaintiffs motorcycle on the highway prior to initiating her left turn. 12. As a result of the aforesaid collision, LEON G. RAMSEY suffered serious injuries resulting in his death. COUNT II -SURVIVAL ACTION TRACY L. RAMSEY, Individually and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, vs. ROSELLA M. WARRICK 13. Paragraphs 1 through 12 of the Plaintiffs Complaint are incorporated herein by reference and made part hereof as if set forth in full. 14. Plaintiff, TRACY L. RAMSEY, is entitled to bring this action on behalf of the decedent, LEON G. RAMSEY, of and by virtue of the provisions of P.L. 508, as amended by P.L. 202, No. 53, §8 (13), (20 Pa. C.S.A., §3371) and by virtue of P. L. 586, No. 142, §2 (42 Pa. C. S. A., §8302). 15. The Plaintiff, TRACY L. RAMSEY, brings this action on behalf of the following persons who are entitled to recover damages in the survival action: a) TRACY L. RAMSEY, spouse of LEON G. RAMSEY. The present residence of Tracy L. Ramsey is 116 Elm Street, Carlisle, Pennsylvania. b) AKEEM RAMSEY, son of LEON G. RAMSEY. The present residence of Akeem Ramsey is 116 Elm Street, Carlisle, Pennsylvania. c) DEONTE RAMSEY, son of LEON G. RAMSEY. The present residence of Deonte Ramsey is 116 Etm Street, Carlisle, Pennsylvania. d) RAJUAN RAMSEY, son of LEON G. RAMSEY. The present residence of Rajuan Ramsey is 116 Elm Street, Carlisle, Pennsylvania. 16. During the time of the incident set forth above until his death, LEON G. RAMSEY sustained mental and physical pain and suffering for which damages are claimed. 17. At the time of his death, LEON G. RAMSEY was forty-five (45) years old, having been born on February 28, 1966. 18. As a direct and proximate result of the aforesaid incident, LEON G. RAMSEY suffered a loss of gross earnings and gross earning power in excess of his personal maintenance expenses from the time of his death to the end of his life expectancy for which damages are claimed. WHEREFORE, the Plaintiff, TRACY L. RAMSEY, Individually and as the Personal Representative of the Estate of LEON G. RAMSEY, Deceased, demands judgment in her favor and against Defendant, ROSELLA M. WARRICK, for compensatory damages in excess of the amount requiring compulsory arbitration. COUNT III- WRONGFUL DEATH ACTION Tracy L. Ramsey, Individually and as Personal Representative of the Estate of Leon G. Ramsey, Deceased, vs. Rosella M. Warrick 19. Paragraphs 1 through 18 of the Plaintiff's Complaint are incorporated herein by reference and made part hereof as if set forth in full. 20. The Plaintiff, TRACY L. RAMSEY, is bringing this action on behalf of the beneficiaries of the Decedent by virtue of the provisions of the Act of July 9, 1976, P.L. 586, No. 142, §2, as amended by P.L. 1409, No. 326, Article II, §201 (42 Pa. C. S. A. §8301). No action was instituted during the lifetime of the Decedent. 21. By reason of the death of LEON G. RAMSEY as set forth above, the decedent, or his estate, incurred hospital, funeral, medical, burial and estate administration expenses for which damages are claimed. 22. By reason of the death of LEON G. RAMSEY, caused by the Defendant as set forth above, his wife, TRACY L. RAMSEY, has sustained the loss of the pecuniary value of the services, society, and comfort that he would have given to her had he lived, including but not limited to, work around the home, provision of physical comforts and services and provision of society, companionship and comfort, provision of a portion of the decedent's wages for her care, needs, and support, for which damages are claimed. WHEREFORE, the Plaintiff, TRACY L. RAMSEY, Individually and as the Personal Representative of the Estate of LEON G. RAMSEY, Deceased, demands judgment in her favor and against Defendant, ROSELLA M. WARRICK, for compensatory damages in excess of the amount requiring compulsory arbitration. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP By: ` ~ ~~ ~2 by o e erger, s uire A ID No. 34343 • • VERIFICATION I ~ ~~Z.~4 ~ ~ AM 4~ ,hereby acknowledge that I am a Plaintiff in this action and that I have read the _ (~ ol~l PLAS,~17" and that the facts stated herein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Signatur Date: ~ ~ ~ (~ ~ I a- G:IGLOBALIWPDATAIDOCSUNfTIAL CONSULT DOCS (SET-UPS)Nerification.wpd SHOLLENBERGER 8 JANUZZI, LLP 2225 Mlllenni~nn Way, Enola, PA 17D25 (717) 728-3200.! FAX (717) 728-3200 REGISTER OF WILLS CUMBERLAND CQUNTY PENNSYLVANIA CERTIFICATE OF GRANT OF LETTERS ADMINISTRATION No . 20 1 1- 00772 PA No . 21- 1 1- 0772 Estate Of s LEON G RAMSEY JR lFifSL Middle, LasU Late Of : CARLISLE BOROUGH CUMBERLAND COUNTY Deceased Social Securi_ ty No: 180-64-0513 WHEREAS, LEON G RAMSEY JR lFifst Middle, Last/ late of CARLISLE BOROUGH CUMBERLAND COUNTY died on the 11th day of June 2011 and, WHF,REAS, the grant of Letters of Administration is required for the administration of the estate. THEREFORE, I, GLENDA EARNER STRASBAIJGH Register of Wills in and for CUMBERLAND County, in the Commonwealth of Pennsylvania, have this day granted Letters of Administration to: TRACY L RAMSEY who has duly qualified as A17MINISTRATOR(RTX} of the estate of the above named decedent and has agreed to administer the_ estate according to law, all of_ which fully appears of record in my office at CUMBERLAND COUNTY COURT HOUSE, CARLISLE, PENNSYL VANIA. IIV TESTIMONY WHEREOF', I .have hereunto set my hand and affixed the seal of my office on the 12th day of July 2071.' ~ v ~ egrster r s ~~` .~ pUty ~, **NOTE** ALL NAMES ABOVE APPEAR (FIRST, MIDDLE, LAST) i` ' ,. r SHOLLENBERGER & JANUZZI, LLPr 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 '-_ Fax Number: (717) 728-3400 , Attorne s for Plaintiff ' TRACY L. RAMSEY, Individually, and IN THE COURT OF COMMON PLEAS as Personal Representative of the CUMBERLAND COUNTY, Estate of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff NO. 12-7721 V. CIVIL ACTION — LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant ig { r . r , And now, this%day of March, 2013, 1 hereby certify that a copy the foregoing Interrogatories have been served upon the following, via U.S. Postal Service First Class Mail: Stephen J. Barcavage, Esquire Owens Barcavage Mclnroy, LLC 2595 Interstate Drive Suite 101 Harrisburg, PA 17110 SHOLLENBERGER & JANUZZI, LLP By: Timothy A. Shollenberger, Esq. Attorney ID#34343 31 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)7283200!FAX(717)7283400 ED ;r i IDROTI-ION0Tt'f SHOLLENBERGER & JANUZZI, LLP � � PM 2: 2225 Millennium Way 2013 Enola, PA 17025 1,'UIJQEKAND GQUNT�' Telephone Number: (717) 728-3200 RMSYLVANIA Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and IN THE COURT OF COMMON PLEAS as Personal Representative of the CUMBERLAND COUNTY, Estate of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff NO. 12-7721 V. CIVIL ACTION — LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant And now, da this y of March, 2013, 1 hereby certify that a copy of the foregoing Request for Production of Documents have been served upon the following, via U.S. Postal Service First Class Mail: Stephen J. Barcavage, Esquire Owens Barcavage Mclnroy, LLC 2595 Interstate Drive Suite 101 Harrisburg, PA 17110 SHOLLENBERGER & JANUZZI, LLP By: Amot %9he , Esq. Attorney ID#34343 8 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)72 8-3200!FAX(717)728-3400 OWENS, BARCAVAGE AND MCINROY, LLC BY: Stephen J. Bracavage � Attorney I.D. No. 78867 ice- ° -r n 2595 Interstate Drive, Suite 101 Harrisburg, PA 17110 -- r= (717) 909-2500 ' TRACY L. RAMSEY, Individually, and IN THE COURT OF COMMON PLEAS As Personal Representative of the Estate CUMBERLAND COUNTY, of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff NO: 12-7721 CIVIL V. CIVIL ACTION ROSELLA M. WARWICK JURY TRIAL DEMANDED Defendant PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of the Defendant, Rosella M. Warwick. OWENS BARCAVAGE AND MCINROY, LLC. DATE: `1 )2613 BY: to n J. arcavage, Esquire 1. 0 8867 59 nterstate Drive Harrisburg, PA 17110 (717) 909-2500 FIL 0-01=FICL OF .THE PROTHONOTAR p' 2013 APR 30 7PM 1: 20 :CUMBERLAND-COUNTY J,�NNSY.LVA_NI,A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L.RAMSEY, Individually No. 12-7721 and as Personal Representative of the ESTATE OF LEON G. RAMSEY, Deceased, Plaintiff V. CIVIL ACTION - LAW ROSELLA M. WARRICK, Defendant JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE PURSUANT TO Pa.R.C.P. 1012 TO THE PROTHONOTARY: Kindly enter the appearance of Michael B. Scheib, Esquire of Griffith, Strickler, Lerman, Solymos & Calkins, as attorney for the Defendant, Rosella M. Warrick, in the above-captioned matter and mark the docket accordingly. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS Dated: 1�1 ,2013 By: k�za' 7,� MICHAEL B. S HEIB, ES QtJIW Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 Telephone (717) 757-7602 Fax (717) 757-3783 mscheib@gslsc.com Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. RAMSEY, Individually No. 12-7721 and as Personal Representative of the ESTATE OF LEON G. RAMSEY, Deceased, Plaintiff V. CIVIL ACTION - LAW ROSELLA M. WARRICK, Defendant JURY TRIAL DEMANDED J CERTIFICATE OF SERVICE AND NOW, this Aq--�Iay of A0 n' l_, 2013, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of Praecipe for Entry of Appearance,by United States Mail, addressed to the party or attorney of record as follows: Timothy A. Shollenberger, Esquire Shollenberger&Januzzi, LLP 2225 Millennium Way Enola, PA 17025 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: 1WY1"�jrl�—, il j1r MICH L B. S _1-10113, tSOU' IIW Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 Telephone (717) 757-7602 Fax (717) 757-3783 mscheib(a,gslsc.com Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. RAMSEY, Individually, No. 12-7721 and as Personal Representative of the ESTATE OF LEON G. RAMSEY, _. Deceased, Plaintiff V. CIVIL ACTION - LAW c�nr,`- CD ROSELLA M. WARRICK, Defendant JURY TRIAL DEMANDED =C) c r CERTIFICATE OF SERVICE AND NOW, this / day of Y_ , 2012, 1, Michael B. Scheib, a member of the firm of Griffith, Strickler, Lerman, Solymos & Calkins, hereby certify that I have this date served a copy of the Interrogatories/Request for Production of Documents of Defendant, Rosella M. Warrick, to Plaintiff, Tracy L. Ramsey, Individually, and as Personal Representative of the Estate of Leon G. Ramsey, Deceased, Set No. 1, by United States First-Class Mail, postage prepaid, addressed as follows: Timothy A. Shollenberger, Esquire Shollenberger&Januzzi, LLP 2225 Millennium Way Enola, PA 17025 .GRIFFITH, STRICKLER, LERMAN,, SOLYMOS & CALKINS B M CHAEL B. SCHEIB, ESQUI Attorney I.D.No. 63868 110 South Northern Way York, Pennsylvania 17402 Telephone (717) 757-7602 Fax (717) 757-3783 mscheib ,gslsc.com Attorney for Defendant Rosella M. Warrick Z�f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. RAMSEY, Individually, No. 12-7721 and as Personal Representative of the ESTATE OF LEON G. RAMSEY, Deceased, Plaintiff V. CIVIL ACTION - LAW ROSELLA M. WARRICK, Defendant JURY TRIAL DEMANDED NOTICE TO PLEAD To: Tracy L. Ramsey, Individually, and as Personal Representative of the Estate of Leon G. Ramsey, Deceased c/o Timothy A. Shollenberger, Esquire Shollenberger&Januzzi, LLP 2225 Millennium Way Enola, PA 17025 You are hereby notified to file a written response to the enclosed Answer with New Matter of Defendant,Rosella M. Warrick,within twenty(20)days from service hereof or a judgment may be entered against you. GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CAL S Dated: , 2013 By: M CI'IAEL B. S6Hbh, E Q. #6A68 110 South Northern Way York, Pennsylvania 17402 (717) 757-7602/Fax (717) 757-3783 mscheibggslsc.com Attorney for Defendant Rosella M. Warrick IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA TRACY L. RAMSEY, Individually, No. 12-7721 and as Personal Representative of the ESTATE OF LEON G. RAMSEY, Deceased, Plaintiff V. CIVIL ACTION -LAW ROSELLA M. WARRICK, Defendant JURY TRIAL DEMANDED ANSWER WITH NEW MATTER OF DEFENDANT, ROSELLA M. WARRICK Comes now Defendant,Rosella M.Warrick,by and through her attorneys Griffith,Strickler, Lerman, Solymos & Calkins and Michael B. Scheib, Esquire in response to the allegations of Plaintiff's Complaint as follows: 1. Denied. After reasonable investigation answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations in paragraph I of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Denied. After reasonable investigation answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations in paragraph 8 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 9. Denied. After reasonable investigation answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations in paragraph 9 of Plaintiff s Complaint and the same are denied and strict proof thereof is demanded. Furthermore, this paragraph states a legal conclusion to which no response is required. WHEREFORE,Defendant,Rosella M.Warrick,respectfully requests this Honorable Court to enter judgment in her favor together with the costs of this lawsuit. COUNT I—NEGLIGENCE TRACY L. RAMSEY, as Personal Representative of the Estate of LEON G. RAMSEY, Deceased vs. ROSELLA M. WARRICK 10. Paragraphs I through 9 of Defendant's Answer with New Matter are incorporated herein and as if fully set forth at length. 11. Denied. This paragraph states a legal conclusion to which no response is required. 12. Denied. After reasonable investigation answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations in paragraph 12 of Plaintiff s Complaint and the same are denied and strict proof thereof is demanded. WHEREFORE,Defendant,Rosella M.Warrick,respectfully requests this Honorable Court to enter judgment in her favor together with the costs of this lawsuit. 2 COUNT II—SURVIVAL ACTION TRACY L. RAMSEY,Individually and as Personal Representative of the Estate of LEON G. RAMSEY,Deceased vs. ROSELLA M. WARRICK 13. Paragraphs 1 through 12 of Defendant's Answer with New Matter are incorporated herein and as if fully set forth at length. 14. Denied. This paragraph states a legal conclusion to which no response is required. 15. Denied. This paragraph states a legal conclusion to which no response is required. Furthermore, after reasonable investigation answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations in paragraph 15 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 16. Denied. This paragraph states a legal conclusion to which no response is required. Furthermore, after reasonable investigation answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations in paragraph 16 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 17. Denied. After reasonable investigation answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations in paragraph 17 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 18. Denied. This paragraph states a legal conclusion to which no response is required. Furthermore, after reasonable investigation answering Defendant is without knowledge or 3 i information sufficient to form a belief as to the truth or veracity of the allegations in paragraph 18 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. WHEREFORE,Defendant,Rosella M.Warrick,respectfully requests this Honorable Court to enter judgment in her favor together with the costs of this lawsuit. COUNT III—WRONGFUL DEATH ACTION TRACY L. RAMSEY,Individually and as Personal Representative of the Estate of LEON G. RAMSEY,Deceased vs. ROSELLA M. WARRICK 19. Paragraphs 1 through 18 of Defendant's Answer with New Matter are incorporated herein and as if fully set forth at length. 20. Denied. This paragraph states a legal conclusion to which no response is required. 21. Denied. This paragraph states a legal conclusion to which no response is required. After reasonable investigation answering Defendant is without knowledge or information sufficient to form a belief as to the truth or veracity of the allegations in paragraph 21 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. 22. Denied.' This paragraph states a legal conclusion to which no response is required. After reasonable investigation answering Defendant is without knowledge or information sufficient to form a belief as to the.truth or veracity of the allegations in paragraph 22 of Plaintiff's Complaint and the same are denied and strict proof thereof is demanded. WHEREFORE,Defendant,Rosella M.Warrick,respectfully requests this Honorable Court to enter judgment in her favor together with the costs of this lawsuit. 4 By way of further defense: NEW MATTER 23. Paragraphs 1 through 22 of Defendant's Answer with New Matter are incorporated herein and as if fully set forth at length. 24. Plaintiff Ramsey's injuries, if any, may be barred or limited by the Motor Vehicle Financial Responsibility Law. 25. Plaintiff Ramsey's injuries,if any,may be barred or limited by a limited tort selection. 26. Plaintiff Ramsey's injuries, if any, were caused by the acts or omissions of a third party over whom Defendant had no control. 27. Plaintiff Ramsey's injuries, if any, were caused by events which either predated or postdated the motor vehicle accident which is the subject of this lawsuit. 28. Plaintiff Ramsey's damages were caused by his/her own conduct. 29. Plaintiff Ramsey's recovery may be barred or limited by the amount of uninsured or underinsured motorist's benefits, if any, to which Plaintiff Ramsey's may be entitled to recover. 30. Defendant is entitled to have the Court mold any verdict in Plaintiff Ramsey's favor to reflect the amount of uninsured or underinsured motorist's benefits, if any, which Plaintiff Ramsey's have received. 31. Plaintiff Leon Ramsey was contributorily negligent in the operation of his motorcycle. 32. Plaintiff Leon Ramsey was in violation of the Pennsylvania Motor Vehicle Code. 33. Plaintiff Leon Ramsey claims may be barred or limited by Leon Ramsey's assumption of the risk. 5 WHEREFORE,Defendant,Rosella M.Warrick,respectfully requests this Honorable Court to enter judgment in her favor together with the costs of this lawsuit. GRIFFITH, STRICKLER, LERMAN, . SOLYMOS & CALKINS Dated: V , 2013 BY: Y MI H EL B. S EIB, ESQUIRE Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 Telephone (717) 757-7602 Fax (717) 757-3783 mscheibgjzslsc.com Attorney for Defendant Rosella M. Warrick 6 r VERIFICATION I,Rosella M.Warrick,individually,verify that I am the Defendant in the foregoing action and that the Answer with New Matter of Defendant,Rosella M. Warrick is based upon the information which has been.gatheredby me.,my counsel an&or others on my behalf in preparation-of the,.defense. of this lawsuit. The language of the Answer with New Matter of Defendant,Rosella M.Warrick is that of counsel and is not mine. I have read the Answer with New Matter of Defendant,Rosella M. Warrick,and to the extent that it is based upon information which I have given to my counsel,is true and correct to the best of my knowledge,information and belief. To the extent that the contents of the Answer with New Matter of Defendant,Rosella M.Warrick are that of counsel and/or others on my behalf, I have relied upon them in making this Verification. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsifications made to authorities. Date: a Rosella M. Warrick IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. RAMSEY, Individually, No. 12-7721 and as Personal Representative of the ESTATE OF LEON G. RAMSEY, Deceased, Plaintiff V. CIVIL ACTION - LAW ROSELLA M. WARRICK, Defendant JURY TRIAL DEMANDED z CERTIFICATE OF SERVICE AND NOW, this 3(A day of JG�� , 2013, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of Answer with New Matter of Defendant,Rosella M. Warrick, by United States Mail, addressed to the party or attorney of record as follows: Timothy A. Shollenberger, Esquire Shollenberger&Januzzi, LLP 2225 Millennium Way Enola, PA 17025 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS By: MI HAIL B'--SCf10BESQt4RE Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 Telephone (717) 757-7602 Fax(717) 757-3783 mscheibggslsc.com Attorney for Defendant Rosella M. Warrick F11-PD-OFFICE Iii TIFF. PROTHONOTARY SHOLLENBERGER & JANUZZI, LLP 2033 JUN _5 PM 1: 44 2225 Millennium Way Enola, PA 17025 CUMBERLAND COUNTY Telephone'Number: (717) 728-3200 PLNNSYLVANIA Fax Number: (717) 728-3400 Attorne s for Plaintiff TRACY L. RAMSEY, Individually, and IN THE COURT OF COMMON PLEAS as Personal Representative of the CUMBERLAND COUNTY, Estate of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff NO. 12-7721 V. CIVIL ACTION — LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant CERTIFICATE OF SERVICE And now, thOm day of June, 2013, 1 hereby certify that a copy of the foregoing Interrogatories have been served upon the following, via U.S. Postal Service First Class Mail: Michael B. Scheib Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 SHOLLENBERGER & JANUZZI, LLP By: ;Wrneyy AS %4E< I D#34343 31 SHOLLENBERGER 8 JANUZZI,LLP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)728-3200?FAX(717)728-3400 D T[1EiED a 1 SHOLLENBERGER & JANUZZI, LLP . 0 R ( 2225 Millennium Way s JUN -S PM, 1. 44 Enola, PA 17025 CUMBERLAtio Telephone Number: (717) 728-3200 Et 1 SYiVCOUNTY Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and IN THE COURT OF COMMON PLEAS as Personal Representative of the CUMBERLAND COUNTY, Estate of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff NO. 12=7721 V. CIVIL ACTION — LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant ' CERTIFICATE;OF SERVICE And now, this day of June, 2013,' 1 hereby certify that a co of the Y fY copy foregoing Request for Production of Documnts have been served upon the following, via U.S. Postal Service First Class Mail: Michael B. Scheib Griffith, Strickler; Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 SHOLLENBERGER & JANUZZI, LLP By: T' A: hollenberger, Esq. orney ID#34343 8 SHOLLENBERGER 8 JANUZZI,LLP 2225 MILLENNIUM WAY!'ENOLA,PA 17025 (717)728-3200!FAX(717)728-3400 V- 11 ED-OF FILE OF THE PROTHONOTARY SHOLLENBERGER & JANUZZI, LLP 2013 JUG -6 AEI II: 16 2225 Millennium Way CUMBERLAND COUNTY Enola, PA 17025 PENNSYLVANIA Telephone Number: (717) 728-3200 Fax.Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and IN THE,COURT OF COMMON PLEAS as Personal Representative of the CUMBERLAND COUNTY, Estate of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff NO. 12-7721 V. CIVIL ACTION - LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant PLAINTIFF'S;REPLY TO DEFENDANT, ROSELLA M; WARPICK,S NEW MATTER AND NOW comes the Plaintiff, TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, by and through her attorneys SHOLLENBERGER & JANUZZI, files this Reply to New Matter of Defendant, Rosella M. Warrick, respectfully representing the following: 23. Paragraphs 1 through 22 of the Plaintiff's Complaint are incorporated herein.by reference as if set forth in full 24. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). .25. . "The above referenced.averment is a conclusion of:law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e' ). 26. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). 27. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). 28. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). 29. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). 30. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). 31. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). 32. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). 33. The above referenced averment is a conclusion of law to which no answer is required. To the extent an answer is required; same is denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, the Plaintiff respectfully requests that the Defendant's New Matter be dismissed and judgment entered in favor of the Plaintiff as a matter of law. Respectfully Submitted, SHOLLENBERGER & JANUZZI, LLP Attorneys for the Plaintiff By: 1 Timothy A. Shollenberger Attorney I.D. 34343 Date: SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and IN THE COURT OF COMMON PLEAS as Personal Representative of the CUMBERLAND COUNTY, Estate of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff NO. 12-7721 V. CIVIL ACTION — LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant CERTIFICATE OF;SERVICE. AND NOW this day of June, 2013, 1 hereby certify that I have served the foregoing Plaintiff's Reply to Defendant, Rosella M. Warrick's New Matter of Defendant on the following by forwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 SHOLLENBERGER & JANUZZI, LLP By: V'Timothy A. Shollenberger I HE PROIHOROiA:ti Z013 OCT -2 AM 11: 58 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. RAMSEY, Individually, No. 12-7721 and as Personal Representative of the ESTATE OF LEON G. RAMSEY, : Deceased, • Plaintiff • v. • CIVIL ACTION - LAW • • • ROSELLA M. WARRICK, Defendant • JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this day of C--)Lox— , 2013, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of Defendant's Answers to Plaintiff's Interrogatories,by United States Mail, addressed to the party or attorney of record as follows: Timothy A. Shollenberger, Esquire Shollenberger&Januzzi, LLP 2225 Millennium Way Enola, PA 17025 GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CATINS / / By: MICH EL B. SCHEIB, ESQUIRE Attorney I.D. No. 63868 110 South Northern Way York, Pennsylvania 17402 Telephone (717) 757-7602 Fax(717) 757-3783 mscheib @gslsc.com Attorney for Defendant Rosella M. Warrick 3F TN£} r`i0HOO�T - SHOLLENBERGER & JANUZZI, LLP #, QCT �7 P 2225 Millennium Way H 2: 50 Enola, PA 17025 CUl�9B£RLAAD.Cp(1tdTY Telephone Number: (717) 728-3200 PENNSYLVANIA Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and IN THE COURT OF COMMON PLEAS as Personal Representative of the CUMBERLAND COUNTY, Estate of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff .NO. 12-7721 v. CIVIL-ACTION — LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant CERTIFICATE OF SERVICE And now, this day f October, 2013, I hereby certify that a copy of the Y � Y fY PY foregoing Request for Production of Documents have been served upon the following, via U.S. Postal Service First Class Mail: - Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 SHOLLENBERGER & JANUZZI, LLP By: r I . Shollenberger, Es q. q• orney ID#34343 12 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)728-3200!FAX(717)728-3400 OFT�jr° 4r u7 li,.%, i ii% PnU TtiUilFU A Y iN3DEC p4 SHOLLENBERGER & JANUZZI, LLP Li 0 2225 Millennium Way eUP'`T Ejf AND COUNTY Enola, PA 17025 f'tNNS YL' ANIA Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and IN THE COURT OF COMMON PLEAS as Personal Representative of the CUMBERLAND COUNTY, Estate of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff NO. 12-7721 v. CIVIL ACTION — LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S DISCOVERY RESPONSES AND NOW, come the Plaintiff, TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, by and through her attorneys, SHOLLENBERGER & JANUZZI, LLP, and respectfully represent the following: 1. Plaintiff served Interrogatories upon the Defendant on June 3, 2013. A copy of the Interrogatories is attached hereto as Exhibit "A". 2. Defendant provided Answers to Interrogatories to counsel for the Plaintiff on October 1, 2013. A copy of Defendant's Answers to Interrogatories is attached hereto as Exhibit "B". 3. Defendant did not comply with Pa. R.C.P. 4006 (a)(1) which states, "... The answers shall be inserted into the spaces provided in the Interrogatories." V 4. Counsel for the Plaintiff sent a letter to Counsel for the Defendant on October 7, 2013, stating the Answers to the Interrogatories were not placed at the end of each Interrogatory in the spaces provided in clear violation of the Pennsylvania Rules of Civil Procedure. A copy of the letter is attached hereto as Exhibit "C". 5. Counsel for the Defendant responded on October 17, 2013, by suggesting that our office hand write the Defendant's responses into the space at the end of the Interrogatory. A copy of the letter is attached hereto as Exhibit "D". 6. Counsel for the Plaintiff has sent the same letter to counsel for the Defendants in other matters in the past, including attorneys at the same law firm as counsel for the Defendant. A copy of a response received from another attorney is attached hereto as Exhibit "E". 7. Plaintiffs' counsel requests attorney's fees and costs for the preparation of this Motion as well as any and all time spent in presenting this Motion to the Court. 8. Plaintiff's counsel certifies that he has disclosed the full text of this motion and proposed order to counsel for the Defendant via facsimile and email on December 16, 2013. Based upon his previous letter, Plaintiff believes that the Defendant's counsel does not concur in the Motion. 9. No Judge has previously ruled on any issue in this matter. WHEREFORE, the Plaintiff respectfully requests the Court enter the following Order: a. Defendant shall pay to the Plaintiff reasonable attorneys fees not to exceed $500 for the preparation of this Motion as well as the time spent presenting the Motion; b. In compliance with Pa. R.C.P. 4006 (a)(1), Defendant shall provide the Answers to all Interrogatories propounded by the Plaintiff in the space following each Interrogatory within 10 days of the Court's Order; and c. Such other relief as the Court deems equitable and just. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP Attorneys or Plaintiff By: ,/rir i ,,fh - . al- :merger, Esq. Attorney I.D. #34343 Date: /04/-/- fey 20 () SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and IN THE COURT OF COMMON PLEAS as Personal Representative of the CUMBERLAND COUNTY, Estate of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff NO. 12-7721 v. CIVIL ACTION — LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant CERTIFICATE OF SERVICE AND NOW this 1.12 day of December, 2013, I hereby certify that I Y � Y Y have served the foregoing Plaintiff's Motion to Compel Discovery Responses on the following by forwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 SHOLL NBERGER & JANUZZI, LLP By: Y 'y A. Sho enberger SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorne s for Plaintiff TRACY L. RAMSEY, Individually, and IN THE COURT OF COMMON PLEAS as Personal Representative of the CUMBERLAND COUNTY, Estate of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff NO. 12-7721 v CIVIL ACTION-- LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant INTERROGATORIES PROPOUNDED BY PLAINTIFF TO BE ANSWERED BY DEFENDANT To: Rosella M. Warrick do Michael B. Scheib Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 Pursuant to the Provisions of Pa. R. C. P. 4005 and 4006, as amended, you are required to serve on the undersigned your Answers and Objections, if any, in writing, to the following Interrogatories, within thirty (30) days after service of the Interrogatories. The Answers shall be inserted in the spaces provided following each Interrogatory. If there is insufficient space to answer an Interrogatory, the remainder of the Answer shall follow on a supplemental sheet. These Interrogatories shall be deemed to be continuing in nature, in accordance with the provisions of Pa. R. C. P. 4007.4 as amended. If between the time of serving your original Answers to these Interrogatories, and the time of trial of this matter, you or anyone acting in your behalf learn the identity of persons expected to be called as an expert witness at trial not disclosed in your Answers, or if you or an expert witness obtain information upon the basis of which you or he knows that an Answer was incorrect when made, or knows that an Answer though correct when made is no longer true, then you shall promptly supplement your original Answers under oath to include 1 SHOLLENBERGER&JANU22I,LLP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)7283200!FAX(717)7284100 such information thereafter acquired, and promptly furnished such a Supplemental Answer on the undersigned. Definitions. --The following definitions are applicable to these standard interrogatories: "Document" means any written, printed, typed, or other graphic matter of any kind or nature, however produced or reproduced, including photographs, microfilms, phonographs, video and audio tapes, punch cards;magnetic tapes, discs, data cells, drums, and other data compilations from which information can be obtained. "Identify" or"identity" means when used in reference to— (1) A natural person, his or her; a. full name; and, b. present or last known residence and employment address (including street name and number, city or town, and state or county); (2) A document: a. its description (e.g., letter, memorandum, report, etc.), title and date; b. its subject matter; c. its author's identity; d. its addressee's identity; e. its present location; and, f. its custodian's identity; (3) An oral communication: a. its date; b. the place where it occurred; c. its substance; d. the identity of the person who made the communication; e. the identity of each person whom such communication was made; and, f. the identity of each person who was present when such communication was made; (4) A corporate entity: • a. its full corporate name; - b. its date and place of corporation, if known,. . and, • c. its present address and telephone number; - (5) Any other context: 2 SHOLLENBERGER 8 JANUZZI,LLP 2225 MILLENNIUM WAY I ENOLA,PA 17025 (717)728.3200 I FAX(717)7283400 A description with sufficient particularity that the thing may thereafter be specified and recognized, including relevant dates and places, and the identification of relevant people, entities, and documents. "Incident" means the occurrence that forms the basis of a cause of action or claim for relief set forth in the Complaint or similar pleading. "Person" means a natural person, partnership, association, corporation, or government agency. STANDARD INSTRUCTIONS The following instructions are applicable to these standard interrogatories. (1) Duty to answer. --The interrogatories are to be answered in writing, verified, and served upon the undersigned within thirty(30) days of their service on you. Objections must be signed by the attorney making them. In your answers, you must furnish such information as is available to you, your employees, representatives, agents and attorneys. Your answers must be supplemented and amended as required by the Pennsylvania Rules of Civil Procedure. (2) Claim of privilege. --With respect to any claim of privilege or immunity of discovery, you must identify the privilege or immunity asserted and provide sufficient information to substantiate the claim. (3) Option to produce documents. -- In lieu of identifying documents in response to these interrogatories, you may provide copies of such documents with appropriate references to the corresponding interrogatories. 3 SHOLLENBERGER&JANUZ21,LIP 2225 MILLENNIUM WAY I ENOLA,PA 17025 (717)728-3200 1 FAX(717)728-3400 1. Personal Information. -- State: a. Your full name; b. Each other name, if any, which you have used or by which you have been known; c. The name of your spouse at the time of the accident and the date and place of your marriage to such spouse; d. The address of your present residence and the address of each other residence which you have had during the past five (5)years; e. Your present occupation and the name and address of your employer; f. Date of your birth; g. Your Social Security number; h. Your military service and positions held, if any; and, The schools you have attended and the degrees or certificates awarded, if any. 4 SHOLLENDERGER&JANUZZ1,LIP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)728-3200!FAX(717)728-3400 • 2. Witnesses. -- a. Identify each person who: (1) was a witness to the incident through sight or hearing and/or (2) has knowledge of facts concerning the happening of the incident or conditions or circumstances at the scene of the incident prior to, at the time of, or after the incident. b. With respect to each person so identified, state that person's exact location and activity at the time of the incident. 5 SHOLLENBEROER&JANUZZI.LLP 2225 MILLENNIUM WAY 1 ENOLA PA 17025 (717)728-3200 I FAX(717)7283400 3. Trial Witnesses. -- Identify each person you intend to call as a non-expert witness at the trial of this case, and for each person identified, state your relationship with the witness and the substance of the facts to which the witness is expected to testify. 6 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY I ENOLA,PA 17025 (717)728-3200 I FAX(717)7283400 4. Trial Preparation Material. -- If you, or someone riot an expert subject to Pa. R.C.P. No. 4003.5, conducted any investigations of the incident, identify: a. each person, and the employer of each person, who conducted any investigation(s); and, b. all notes, reports or other documents prepared during or as a result of the investigation(s) and the persons who have custody thereof. 7 SHOLLENSERGER 8 JANUZZI,LLP 2225 MILLENNIUM WAY I ENOLA,PA 17025 (717)728-3200 I FAX(717)728-3400 5. Interviews and Statements. -- State the name, age, address (including the street, street number, city and state), occupation and place of employment of every person interviewed by you or by anyone acting on your behalf in regard to the happening of the accident set forth in the Plaintiff's Complaint or as to Plaintiffs physical condition either before or after the date of the accident or as to oral statements made by the Plaintiff concerning her physical condition or as to the happening of the accident, along with the date and place of such interviews, the name of the person conducting such interviews, and the relationship of such interviewer to Defendant. 8 SHOLLENBERGER&JANUZZI,LIP 2225 MILLENNIUM WAY I ENOLA,PA 17025 (717)728-3200 I FAX(717)728-3400 6. Demonstrative Evidence. -- If you know of the existence of any photographs, motion pictures, video recordings, maps, diagrams, or models relevant to the incident, state: a. the nature or type of such item; b. the date when such item was made; c. the identity of the person that prepared or made each item; and, d. the subject that each item represents or portrays. 9 SHOLIENBERGER&JANUZZI.LIP 2225 MILLENNIUM WAY t ENOLA,PA 17025 (717)728-3200 I FAX(717)7283400 7. Trial Exhibits. -- Identify all exhibits that you intend to use at the trial of this matter and state whether they will be used during the liability or damages portions of the trial. 10 SHOLLEN8ERGER&JANUZZI,LIP 2225 MILLENNIUM WAY I ENOLA,PA 17025 (717)7283200 I FAX(717)7283400 8. Has the Plaintiff to this cause ever made any oral statements regarding the happening of this accident, the events immediately preceding the accident or as to the nature and extent of her injuries received in this accident. If so, list the dates and locations such statements were made, the names and addresses of those persons to whom said statements were made and names and addresses of all other persons who heard or were present at the time said statements were made. 11 SHOLLENDERGER&JANUZZI,LLP 2225 MILLENNIUM WAY I ENOLA,PA 17025 (717)72832001 FAX(717)728-3400 9. Did you or anyone acting in your behalf submit any notes, reports, statements or memorandums to your insurance liability carrier concerning this incident? If so, state the date when such report or statement was made and the person or persons to whom it was made. 12 SUOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY 1 ENOLA,PA 17025 (717)7283200 I FAX(717)7283400 10. Insurance. -- If you are covered by any type of insurance, including any excess or umbrella insurance, that might be applicable to the incident in this matter, state the following with respect to each such policy: a. the name of the insurance carrier which issued the policy; b. the named insured under each policy and the policy number of each policy; c. the type(s) and effective date(s) of each policy; d. the amount of coverage provided for injury to each person, for each occurrence, and in the aggregate, for each policy; and, e. each exclusion, if any, in the policy which is applicable to any claim thereunder and any reasons, if any, why you or the carrier claim the exclusion is applicable. 13 SHOLLENBERGER&JANUZZI,!LP 2225 MILLENNIUM WAY I ENOLA,PA 17026 (717)728-3200 I FAX(717)728-3400 • 11. Defenses. -- State with particularity the facts upon which you intend to rely in establishing any of the following defenses: a. that the Plaintiff was contributorily or solely negligent; b. that the incident was caused by the negligent act of a third party or agency other than the named Defendant; c. that the incident occurred as a result of negligence on the part of no one; d. that the Court lacks jurisdiction over the present action; and, e. that the Plaintiff's claim is barred by the defense of assumption of risk. • 14 SHOLLENBEROER&JANUZZI,LLP 2225 MILLENNIUM WAY I FNMA,PA 17025 (717)728-320D I FAX(717)728-3400 12. Factual Basis for Claims and Defenses. -- State with particularity the factual basis for each claim or defense you are asserting in this case. 15 SHOLLENBERGER&JANU221.LIP 2225 MILLENNIUM WAY 1 ENOLA,PA 17025 (717)728-3200!FAX(717)728-3400 13. Expert Witnesses. -- Identify each expert you intend to call as a witness at the trial of this matter, and for each expert state: a. the subject matter about which the expert is expected to testify; and, b. the substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion. (You may file as your answer to this interrogatory the report of the expert or have the interrogatory answered by your expert.) 16 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY! ENOLA.PA 17025 (717)728-3200 1 FAX(717)728.3400 14. Books, Magazines, Etc. -- If you intend to use any book, magazine, or other such writing at trial, or in depositions for use at trial, state: a. the name of the writing; b. the author of the writing; c. the publisher of the writing; d. the date of publication of the writing; and, e. the identity of the custodian of the writing. 17 SHOLLENBERGER&JANUZZI,LLP 2226 MILLENNIUM WAY! ENOLA,PA 17025 (717)728-3200 3 FAX(717)728.3400 15. Licensure. -- If you were required by law or regulation to be licensed for the activity in which you were engaged at the time of the incident, state: a. the type of license required; b. the date you first obtained such a license; c. the dates of issuance and expiration of your current license(s); d. the identity of the authority that issued your license(s); e. the number of your license(s); f. the nature and duration of any revocation or suspension of your license(s); and, g. the special restrictions, if any, imposed on your license. 18 SHOLLENBEROER&JANUZZI,LIP 2225 MILLENNIUM WAY 1 ENOLA,PA 17025 (717)728-3200 t FAX(717)728-3400 16. Defendant's Background. -- Have you ever pled guilty, nob conteneve or been convicted of a crime that involved dishonesty or false statement? If so, for each such crime, please state the following: (a) date of conviction or plea; (b) your release from the confinement imposed for that conviction; (c) whether said conviction has been the subject of a pardon or other equivalent procedure based on a specific finding of innocence; (d) a pardon or other equivalent procedure based on a specific finding of rehabilitation of the person convicted, and that person has not been convicted of any subsequent crime; (e) if an appeal is pending. 19 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY! ENOIA,PA 17025 (717)7283200 1 FAX(717)7283400 17. Substance Impairment. -- If you consumed any alcoholic beverage, sedative, tranquilizer, marijuana, cocaine, hashish, or other drug, medicine or pill during the eight(8) hours immediately preceding the incident, state: a. the nature, amount, and type of item consumed; b. the amount of time over which consumed; c. the identity of any and all persons who have any knowledge as to the consumption of those items, and, d. the identity of the physician or medical practitioner or other person who gave, purchased or prescribed any of said items, if any. 20 SHOLLENBERGER 8 JANUZZI,LIP 2225 MILLENNIUM WAY 1 ENOLA,PA 17026 (717)728-3200 1 FAX(717)728-3400 18. Physical or Mental Disability. -- I If you were under any physical or mental disability at the time of the incident, explain the disability. 21 SHOLLENBEROERBJANUZZI,LLP 2225 MILLENNIUM WAY f ENOLA.PA 17025 (717)728-3200 I FAX(717)728.3400 • 19. Criminal Charges Related to Incident. -- If you have been charged with any criminal violations as a result of the incident, describe the charges and identify all documents filed or served in connection with those charges. 22 • SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY I ENOLA,PA 17025 (717)728.3200 f FAX(717)728-3400 • 20. Have you ever been charged for any violation of the motor vehicle traffic laws or ordinances of any state or municipality other than from the incident referred to in the Complaint? 23 SHOLLENBERGER&JANUZZi,LLP 2225 MILLENNIUM WAY I ENOLA,PA 17025 (717)728-3200!FAX(717)7283400 ti 21. Admissions. -- If you intend to use any admission(s) of a party at trial, identify such admission(s). 24 SHOLLENBERGER&JANUZZI.LLP 2225 MILLENNIUM WAY t ENOLA,PA 17025 (717)728.3200 t FAX(717)728.3400 22. Motor Vehicle Information. -- With respect to all motor vehicles involved in the incident, state: a. the identities of the owner(s) and operator(s) of each vehicle; • b. the identity of the passenger(s) in each vehicle, if any; and, c. the make, model and year of each vehicle. 25 SHOLLEN8EROER&JANUZZI,LLP 2225 MILLENNIUM WAY t ENOLA,PA 17025 (717)728-3200 1 FAX(717)7283400 23. Motor Vehicle Damage. -- With respect to any vehicle you owned or operated that was involved in the incident, state: a. the nature of any damage existing prior to the incident; b. the identity of any person who performed repairs to the vehicle following the incident; c. the total amount of the repair bill(s), or if not yet repaired, the total estimated cost of repairing the vehicle or the estimated value of the damages to the vehicle (include the identity of the person furnishing any such estimate); d. the date and place of last state inspection prior to the incident and identify the person making said inspection; and, e. the nature of any defect in or problem with the vehicle and the length of time such defect or problem existed. 26 SHOLLENBEROER&JANUZZI,LLP 2225 MILLENNIUM WAY 1 ENOLA,PA 17025 (717)728-3200 1 FAX(717)728-3400 24. Motor Vehicle Operation. — With respect to the vehicle you operated or in which you were a passenger, state: a. the destination and the point and time of departure of the vehicle; b. the purpose of the trip or journey in the vehicle; c. the time and place of all stops and departures between the commencement of the trip or journey and the time of the incident; d. whether the operator of the vehicle was familiar with the surrounding area of the incident; and, e. the weather conditions at the time of the incident, including visibility and roadway conditions. 27 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY 1 ENOLA,PA 17025 (717)728-3200 I FAX(717)728-3400 25. Motor Vehicle Accident Causation. -- State in detail the manner in which you assert that the incident occurred, specifying the speed, position, direction and location of each vehicle involved during its approach to, at the time of, and immediately after the collision. 28 SI-OLL€NBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY I ENOLA,PA 17025 (717)728-3200 t FAX(717)728-3400 26. Has the Defendant, or any representative of the Defendant, his counsel or his insurer performed or contracted to be performed, or arranged in any way, any type of surveillance of the Plaintiff or her activities at any time. If so, please identify each such person(s) or entities who have custody of and attach a complete copy, without editing, of all reports, memorandum, letters, electronic data or information of any type (including computer records), regarding such surveillance activity, along with a copy of any photographs, films, videotapes or other information, including, but not limited to videos, 8 mm. film and hand written notes. 29 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY I ENOLA,PA 17025 (717)728-3200 1 FAX(717)7283400 • 27. At the time of the collision, were you in the course and scope of your employment? If so, state a. the name of your employer? b. your employer's address and telephone number? SHOLLENBERGER &JANUZZI, LLP By: n) 'A olle • ger,/ sc. et ey' I :3434' Date: OM 30 SHOLLENBERGER&JANUZZI.LIP 2225 MILLENNIUM WAY I EM IL PA 17025 (717)7283200 i FAX(717)7283400 SHOLLENBERGER & JANUZZI, LLP • 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorne s for Plaintiff TRACY L. RAMSEY, Individually, and IN THE COURT OF COMMON PLEAS as Personal Representative of the CUMBERLAND COUNTY, Estate of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff NO. 12-7721 v. CIVIL ACTION— LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant CERTIFICATE OF SERVICE iy1 And now, this:it"day of June, 2013, I hereby certify that a copy of the foregoing Interrogatories have been served upon the following, via U.S. Postal Service First Class Mail: Michael B. Scheib Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 SHOLLENBERGER & JANUZZI, LLP By: T' ���t* '�Sholrnber2r, E l •rney ID#34343 31 SHOLLENBERGER&JANURZ4 LLP 2225 MILLENNIUM WAY I ENOLA,PA 17025 (717)7283200!FAX(717)728-3400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA • TRACY L. RAMSEY, Individually, No. 12-7721 • and as Personal Representative of • the ESTATE OF LEON G. RAMSEY, Deceased, • Plaintiff V. • CIVIL ACTION-LAW • • ROSELLA M. WARRICK, Defendant • JURY TRIAL DEMANDED DEFENDANT'S ANSWERS TO PLAINTIFF'S INTERROGATORIES 1. a. Rosella May Warrick. b. None. c. Spouse deceased. d. 161 Spur Road, Carlisle,PA 17013. e. Retired. f. December 28, 1924. g. 278-24-9045. h. N/A. i. Pyle Elementary Jenner Township grades 1-8;Somerset High did not graduate., Frederick's Beauty Academy Lima, Ohio Certificate. 2. Judi Ohara, Brittany Marsh, Harry Morrett,Ms. Morrett, Officer Richard Grove, Corporal James Peterson. 3. Officer Jeffrey Rudolph,Judi Ohara,Officer Richard Grove,Jr.,Brittany Marsh, Harry Morret,Officer Matthew Claeys,Investigator David Ickler,Officer Matthew Grunden, Officer Seth Weikert and Deputy Matthew Stoner. 4. See Police Report. 5. See Statement of Rosella Warrick. Judy Ohara,Harry Morrett,Officer Richard Grove, Corporal James Peterson;Nephew Willie G. "Andy"Anderson,Jr. spoke with these individuals. 6. Trial exhibits have not been identified at this time. This Answer will be supplemented pursuant to the Local Rules and the Pennsylvania Rules of Civil Procedure. 7. Trial exhibits have not been identified at this time. This Answer will be supplemented pursuant to the Local Rules and the Pennsylvania Rules of Civil Procedure. 8. Unknown. Obviously,Mr.Ramsey passed away and Ms.Ramsey was not a witness to the incident. Discovery is ongoing. This Answer will be supplemented. 9. See Statement of Rosella Warrick. 10. See Declaration Sheet from Allstate. 11. Discovery is ongoing. Plaintiff should be prepared to prove each and every element of her case. It does appear that Plaintiff was negligent in the operation of his motorcycle. 12. Discovery is ongoing. Plaintiff should be prepared to prove each and every element of her case. It does appear that Plaintiff was negligent in the operation of his motorcycle. 13. Expert witnesses have not been identified at this time. This Answer will be supplemented pursuant to the Local Rules and the Pennsylvania Rules of Civil Procedure. 14. Expert witnesses have not been identified at this time. This Answer will be supplemented pursuant to the Local Rules and the Pennsylvania Rules of Civil Procedure. 15. a. Class C License. b. 1945 or 1946. 2 c. Issue date: October 3,2012;Expiration date: December 29,2016. d. PennDOT Driver Services. e. 07875832. f. None. g. None. 16. No. 17. None. 18. None. 19. None. 20. Objection. Plaintiff was not charged as a result of this incident. Any other citations are not discoverable and are not admissible. 21. Discovery is ongoing. This Answer will be supplemented pursuant to the Local Rules and the Pennsylvania Rules of the Civil Procedure. 22. Rosella M.Warrick owned and operated a 2006 Chevrolet. Leon Ramsey owned and operated a 2006 Kawasaki Ninja 1000. 23. Rosella M. Warrick owned and operated a 2006 Chevrolet. a. None. b. N/A. c. Believe vehicle totaled by insurance company. d. Lawrence Chevrolet,Mechanicsburg,PA; August 13,2010. e. None. 24. a. Destination was Saint Paul Lutheran Church in Carlisle,Pennsylvania. Left 3 my residence on Spur Road at approximately 4:00 p.m. b. Attend church service. c. No stops. d. Has lived in area a number of years. e. Weather was clear and the roads were dry. 25. Ms. Warrick was traveling southwest on Spur Road. She stopped at the intersection of Spur Road and Waggoners Gap Road,looked left and right several times before starting a left turn to proceed southeast on Waggoners Gap Road toward Carlisle, Pennsylvania. As Ms. Warrick entered the intersection a motorcycle came around the curve to her left traveling at a high rate of speed. Ms. Warrick applied her brakes and the motorcycle struck the front of her vehicle. Impact was in the southeast lane of Waggoners Gap Road. The motorcyclist was ejected and ended up in a field near a tree line on the north shoulder several hundred feet from the area of impact. 26. No surveillance. 27. No. GRIFFITH,STRICKLER,LERMAN, SOLYMOS&CALKINS Dated: C o b ht,r I 2013 By: MICHAEL B. CHE1 , SQ. :63868 110 South Northern Way York, Pennsylvania 17402 (717)757-7602/Fax(717)757-3783 mscheibagslse.com Attorney for Defendant Rosella M. Warrick 4 VERI FICATION 1,Rosetta NI. Warrick,individually,verify that I am the Defendant in the foregoing action and that the Defendant's Answers to Plaintiff's Interrogatories is based upon the information which has been gathered by me, my counsel and/or others on my behalf in preparation of the defense of this lawsuit. The language of the Defendant's Answers o Plaintiff's Interrogatories is that of counsel and is not mine. I ha‘e read the Defendant's Answers to Plaintiffs Interrogatories,and to the extent that it is based upon information which I have given to my counsel, is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the Defendant's Answers to Plaintiff's Interrogatories are that of counsel and/or others on my behalf,I have relied upon them in making this Verification. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsifications made to authorities. Date: Rosella M. Warrick 5 • • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA TRACY L. RAMSEY, Individually, : No, 12-7721 and as Personal Representative of • the ESTATE OF LEON G.RAMSEY, . • Deceased, . Plaintiff : v, CIVIL ACTION LAW • ROSELLA M. WARRICK, Defendant • JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this day of 00-6 La- , 2013, I, Michael B. Scheib, Esquire, a member of the firm of GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS, hereby certify that I have this date served a copy of Defendant's Answers to Plaintiff's Interrogatories,by United States Mail,addressed to the party or attorney of record as follows: Timothy A. Shollenberger,Esquire Shollenberger&Janu77i,LLP 2225 Millennium Way Enola,PA 17025 GRIFFITH,STRICKLER,LERMAN, SOLYMOS&CA . NS Y= B at-if A MICHAEL B.SCHEIB,ESQUIRE Attorney T.D.No. 63868 110 South Northern Way York,Pennsylvania 17402 Telephone(717) 757-7602 Fax(717)757-3783 mscheib cr.gslsc.com Attorney for Defendant Rosella M.Warrick Writer's Direct E-mail jerb @sholljanlaw.com October 7, 2013 Michael B. Scheib Griffith, Strickler, Lerman, Solymos & Calkins 110 South Northern Way York, PA 17402 Re: The Estate of Leon G. Ramsey, Jr. Dear Attorney Scheib: I acknowledge receipt of your letter dated October 1, 2013, enclosing Defendant, Rosella M. Warrick's Answers to Interrogatories of Plaintiff, Tracy L. Ramsey, Individually and as Personal Representative of the Estate of Leon G. Ramsey, Deceased. I enclose a copy of Defendant's Answers to Interrogatories. As you can see they were not placed at the end of the Interrogatory itself. This is clearly in violation of the Pennsylvania Rules of Civil Procedure which are non-discretionary on the issue. This may not seem like a big deal to you but it is to me because one of two things must occur, either we must toggle between two separate documents to determine the defendant's answers or we have to use secretarial time to do what the Rules require the answering party to do. Please have the answers placed at the end of the Interrogatories as required by the Rule within 20 days, otherwise I will be forced to file a Motion. Thanks for your courtesy in complying with this request. Very truly yours, Timothy A. Shollenberger TAS/jme Enclosure it � I LAW OFFICES GRIFFITH, STRICKLER, LERMAN,SOLYMOS & CALKINS 110 S.NORTHERN WAY ROBERT H.GRIFFITH(1928-2009) YORK,PENNSYLVANIA 17402-3737 ROBERT M.STRICKLER TELEPHONE:(717)757-7602 ANN MARGARET GRAB ROBERT A.LERMAN° FAX:(717)757-3783 JOHN C.PORTER— PETER D.SOLYMOS EMAIL: infotEa,slsc.com ROBERT D.O'BRIEN CHARLES B.CALKINS WEBSITE:www.gslsc.com CHARLES T.YOUNG,JR.• PAUL G.LUTZ ROBERT W.MELICK** MICHAEL B.SCHEIB* Michael B.Scheib's EMAIL: mscheib(dctsIsc.com THOMAS B.SPONAUGLE°+ °Also Member MD Bar ^LL.M(Taxation);also Member CT Bar *Also Member NY and D.C.Bars "Also Member NY Bar —Also Member NJ Bar **Also Member WI Bar • +Board Certified Civil Trial and Pretrial Practice Advocate by the National Board of Trial Advccccy II October 17, 2013 Timothy A. Shollenberger, Esquire Shollenberger& Januzzi, LLP 2225 Millennium Way Enola, PA 17025 Re: Tracy L. Ramsey, Individually, and as Personal Representative of the Estate of Leon G. Ramsey, Deceased v. Rosella M.Warrick • Cumberland County C.C.P. No. 12-7721 Dear Attorney Shollenberger: I am in receipt of your letter dated October 7, 2013. It is my suggestion that you simply have your office hand write my client's responses into the space at the end of the Interrogatory. This appears to be the simplest and most cost effective method to resolve your concern and will eliminate the need for you to "toggle between two separate documents." In my opinion, this is the best and most cost effective solution to the problem. Rest assured, I have advised my staff that you prefer the Answer to appear directly below the Interrogatory. Thus, the problem should be avoided in the future. Sorry for any inconvenience. Very truly yours, ,., ' • 1/ /,„,/ 7ti ,/,// t /4(7j/ MIC AEL B. SCHEIB MBS:wst/warrick.ramsey-ltr. ,1 � e Jessica Erb \ I I II /.11111 \\I From: John Porter <jporter @gslsc.com> Sent: Thursday, October 10, 2013 6:24 PM To: Jessica Erb Cc: Tim Shollenberger; Karmin Smith Subject: RE: Bellamy v.Allstate Attachments: 061913 P Rogs to D set 1 hlo.doc;061913 P RPD's to D set 1 hlo.doc Jessica: Ask and thou shalt receive! John C. Porter Attorney Griffith,Strickler, Lerman,Solymos&Calkins LEGAL NOTICE Unless expressly stated otherwise, this e-mail is intended to be confidential, attorney work product, and may be privileged. It is intended for the addressees only. Access to this e-mail by anyone except addressees is unauthorized. If you are not an addressee, any disclosure or copying of the contents of this e-mail or any action taken (or not taken) in reliance on it is unauthorized and may be unlawful. If you are not an addressee, please inform the sender immediately. E-mail communications may be intercepted or inadvertently misdirected. While the American Bar Association deems e- mail a valid and authorized form of communication between attorneys and clients, absolute secrecy, confidentiality,and security (of this e-mail message and any attachments thereto) cannot be assured. The relationship of attorney/client shall not be, and is not, established solely as a result of the transmission of this e-mail. Absent a written engagement letter signed by Griffith, Strickler, Lerman, Solymos & Calkins, no attorney/client relationship shall be deemed to, nor shall, exist and any belief that information or documents provided by this e-mail are privileged is mistaken, unwarranted and incorrect. U.S. Treasury Circular 230 restricts written federal tax advice contained in this communication (including attachments), and nothing in this message is intended to, or may, be used (a) to avoid any penalty that may be imposed under the internal revenue code or (b) to promote, market or recommend to another party any tax-related matter or transaction. This disclosure is provided on all outbound e-mails to assure compliance with standards of professional tax practice, pursuant to which certain advice must satisfy requirements as to form and substance. From: Jessica Erb [mailto:jerb @sholljanlaw.com] Sent: Thursday, October 10, 2013 4:01 PM To: John Porter Subject: RE: Bellamy v. Allstate Attorney Porter, We received your Discovery Responses in today's mail. The questions are not on the page with the answers. I sent the Interrogatories and RPD's to you in word format on October 8th. Please let me know if you are planning to send the answers with the questions on the same page. 1 A Z thanks and I await your response. Jessica From: Jessica Erb Sent: Tuesday, October 08, 2013 8:38 AM To:Tim Shollenberger; John Porter Subject: RE: Bellamy v. Allstate Attorney Porter, Per your request, attached please find the Interrogatories and Request for Production of Documents directed to the Defendant in word format. Should you have any questions, please do not hesitate to contact me. Thanks, Jessica Jessica M. Erb, RP®,Pa.C.P. Paralegal to Timothy A. Shollenberger,Esquire Shollenberger and Januzzi,LLP 2225 Millennium Way Enola, PA 17025 phone-717-728-3200 fax-717-728-3400 From: Tim Shollenberger Sent: Tuesday, October 08, 2013 6:50 AM To: John Porter Cc: Jessica Erb Subject: RE: Bellamy v. Allstate My paralegal will email them to you. Please give me some dates and times that the doctors who performed the Initial Determination and Reconsideration are available for deposition as well as when Mr. Lytle is available. Please inform Mr. Lytle that he will have to come to Pennsylvania to be deposed. Timothy A.Shollenberger, Esq. Shollenberger and Januzzi, LLP 2225 Millennium Way Enola, PA 17025 717-728-3200 PH 717-728-3400 FAX 717-439-8039 CELL tas@shollianlaw.com From: John Porter fmailto:jporter(agslsc.coml Sent: Monday, October 07, 2013 10:00 PM To: Tim Shollenberger Subject: RE: Bellamy v. Allstate Attorney Shollenberger: 2 � v Please provide an MS Word version of Plaintiff's interrogatories and I will be able to do a quick turnaround on your request. I apologize for missing this formatting requirement. Thank you, John John C. Porter Attorney Griffith, Strickler, Lerman,Solymos&Calkins LEGAL NOTICE Unless expressly stated otherwise, this e-mail is intended to be confidential, attorney work product, and may be privileged. It is intended for the addressees only. Access to this e-mail by anyone except addressees is unauthorized. If you are not an addressee, any disclosure or copying of the contents of this e-mail or any action taken (or not taken) in reliance on it is unauthorized and may be unlawful. If you are not an addressee, please inform the sender immediately. E-mail communications may be intercepted or inadvertently misdirected. While the American Bar Association deems e- mail a valid and authorized form of communication between attorneys and clients, absolute secrecy, confidentiality, and security (of this e-mail message and any attachments thereto) cannot be assured. The relationship of attorney/client shall not be, and is not, established solely as a result of the transmission of this e-mail. Absent a written engagement letter signed by Griffith, Strickler, Lerman, Solymos & Calkins, no attorney/client relationship shall be deemed to, nor shall, exist and any belief that information or documents provided by this e-mail are privileged is mistaken, unwarranted and incorrect. U.S. Treasury Circular 230 restricts written federal tax advice contained in this communication (including attachments), and nothing in this message is intended to, or may, be used (a) to avoid any penalty that may be imposed under the internal revenue code or (b) to promote, market or recommend to another party any tax-related matter or transaction. This disclosure is provided on all outbound e-mails to assure compliance with standards of professional tax practice, pursuant to which certain advice must satisfy requirements as to form and substance. From: Tim Shollenberger [mailto:tas(@sholljanlaw.com] Sent: Monday, October 07, 2013 7:50 PM To: John Porter Subject: RE: Bellamy v. Allstate Importance: High Dear Mr. Porter: The Pennsylvania Rules of Civil Procedure are quite clear on the point that Answers to Interrogatories are to be placed in the spaces immediately following the questions. Unless they are provided in this fashion, we will be forced to file a Motion to assure that the rule is complied with. Please resend in the proper format. I await your response. Very truly yours, 3 Ttrnothy A.Shollenberger, Esq. Shollenberger and Januzzi, LLP 2225 Millennium Way Enola, PA 17025 717-728-3200 PH 717-728-3400 FAX 717-439-8039 CELL tas@sholllanlaw.com From: John Porter [mailto:iporter(agslsc.com] Sent: Monday, October 07, 2013 6:23 PM To: Tim Shollenberger Subject: Bellamy v. Allstate Attorney Shollenberger: Attached please find: 1) Defendant's answers to Plaintiff's interrogatories; 2) Defendant's responses to Plaintiff's document requests; and 3) Defendant's privilege log. The documents Bates stamped A1-A173 will follow via several emails. Respectfully, John John C. Porter Attorney Griffith,Strickler, Lerman,Solymos&Calkins LEGAL NOTICE Unless expressly stated otherwise, this e-mail is intended to be confidential, attorney work product, and may be privileged. It is intended for the addressees only. Access to this e-mail by anyone except addressees is unauthorized. If you are not an addressee, any disclosure or copying of the contents of this e-mail or any action taken (or not taken) in reliance on it is unauthorized and may be unlawful. If you are not an addressee, please inform the sender immediately. E-mail communications may be intercepted or inadvertently misdirected. While the American Bar Association deems e- mail a valid and authorized form of communication between attorneys and clients, absolute secrecy, confidentiality, and security (of this e-mail message and any attachments thereto) cannot be assured. The relationship of attorney/client shall not be, and is not, established solely as a result of the transmission of this e-mail. Absent a written engagement letter signed by Griffith, Strickler, Lerman, Solymos & Calkins, no attorney/client relationship shall be deemed to, nor shall, exist and any belief that information or documents provided by this e-mail are privileged is mistaken, unwarranted and incorrect. U.S. Treasury Circular 230 restricts written federal tax advice contained in this communication (including attachments), and nothing in this message is intended to, or may, be used (a) to avoid any penalty that may be imposed under the internal revenue code or (b) to promote, market or recommend to another party any tax-related matter or transaction. This disclosure is provided on all outbound e-mails to assure compliance with standards of professional tax practice, pursuant to which certain advice must satisfy requirements as to form and substance. 4 ri' ,'t (>� . !,' t rUTNUPJ OTf,;; ; SHOLLENBERGER & JANUZZI, LLP Z0I4 JAPE 15 PH I: Qs topi 2225 Millennium Way UMBERL tID COU�JT4' Enola, PA 17025 FF��N5YLVA�Iq Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and IN THE COURT OF COMMON PLEAS as Personal Representative of the CUMBERLAND COUNTY, Estate of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff NO. 12-7721 v. CIVIL ACTION — LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant PRAECIPE TO WITHDRAW PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S DISCOVERY RESPONSES Kindly withdraw, without prejudice, Plaintiffs' Motion to Compel Defendant's Discovery Responses filed with this Court on December 18, 2013. Respectfully submitte• SHOLLENB ' JANUZZI, LLP ,‘„ogiippire 0000e. - B . Timothy A. :lenberger, Esq. Date: Attorney I'# 34343 / 1 " r SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and IN THE COURT OF COMMON PLEAS as Personal Representative of the CUMBERLAND COUNTY, Estate of LEON G. RAMSEY, PENNSYLVANIA Deceased, Plaintiff NO. 12-7721 v. CIVIL ACTION — LAW ROSELLA M. WARRICK, JURY TRIAL DEMANDED Defendant CERTIFICATE OF SERVICE AND NOW this day of January, I hereby certify that I have Y rY, Y fY served the foregoing Praecipe to Withdraw Plaintiff's Motion to Compel Defendant's Discovery Responses on the following by forwarding a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 SHOLL BERGER & JANUZZI, LLP By. . i ot- A." h• lenberger SHOLLENBERGER & JANUZZI, LLP 2( ;i� ' 20 �� � 2225 Millennium.Way CfilIBER�..AND Enola, PA 17025 € , TY Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and as IN THE COURT OF COMMON PLEAS Personal Representative of the Estate of CUMBERLAND COUNTY, LEON G. RAMSEY, Deceased, PENNSYLVANIA Plaintiff NO. 12-7721 v. CIVIL ACTION — LAW ROSELLA M. WARRICK, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE R�1 And now, this V day of March, 2014, I hereby certify that a copy of the foregoing Notice of Deposition of Kevin Shrawder, has been served upon the following, via U.S. First Class Mail: Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 and Kevin Shrawder 1968 Spring Road Carlisle, PA 17013 SHOLLENBERGER & JANUZZI, LLP By: /ZAK, //./,=�,��t��S• •Ile •er•er, sq. • n- ID#34343 SHOLLENBERGER & JANUZZI, LLP 28l4 14° PRo i 20 2225 Millennium Way , �' l d: /o t� � ytyr.. Enola, PA 17025 t Abil Telephone Number: (717) 728-32005 y1y4l4fT Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and as IN THE COURT OF COMMON PLEAS Personal Representative of the Estate of CUMBERLAND COUNTY, LEON G. RAMSEY, Deceased, PENNSYLVANIA Plaintiff NO. 12-7721 v. CIVIL ACTION — LAW ROSELLA M. WARRICK, Defendant JURY TRIAL DEMANDED , CERTIFICATEOFSERVICE mss: And now, this IV day of March,h, 2014, I hereby certify that a copy of the foregoing Notice of Deposition of Judy O'Hara, has been served upon the following, via U.S. First Class Mail: Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 and Judy O'Hara 49 W. Oakwood Drive Carlisle, PA 17015 SHOLLENBERGER & JANUZZI, LLP By. • y ' . S ollenberger, sq. Attorney ID#34343 S HOLLENBERGER & JANUZZI, LLP *L. i''t)Tf 1-'` 2225 Millennium Way U/l//i 1 f: Enola, PA 17025 g i 20 1M 1: /9 Telephone Number: (717) 728-3200 `fi t A/-0 Fax Number: (717) 728-3400 PEN/V .. "L V OUNT), Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and as IN THE COURT OF COMMON PLEAS Personal Representative of the Estate of CUMBERLAND COUNTY, LEON G. RAMSEY, Deceased, PENNSYLVANIA Plaintiff NO. 12-7721 v. CIVIL ACTION — LAW ROSELLA M. WARRICK, Defendant JURY TRIAL DEMANDED I CERTIFICATE OF SERVICE And now, this I S day of March, 2014, I hereby certify that a copy of the foregoing Notice of Deposition of Officer, Richard M. Grove, Jr., has been served upon the following, via U.S. First Class Mail: Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 and Richard M. Grove, Jr. 6204 Valleybrook Drive Mechanicsburg, PA 17055 SHOLLENBERGER & JANUZZI, LLP By: A, // T/ y �!S.�en.,__� • ney ID#34343 Thie-PV02rFif' SHOLLENBERGER &JANUZZI, LLP 204 , 2 ¢' 2225 Millennium Way Ctjt - i g Enola, PA 17025 PE IS ` f r'/ Telephone Number: (717) 728-3200 YL VAN14 Y Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and as IN THE COURT OF COMMON PLEAS Personal Representative of the Estate of CUMBERLAND COUNTY, LEON G. RAMSEY, Deceased, PENNSYLVANIA Plaintiff NO. 12-7721 v. CIVIL ACTION — LAW ROSELLA M. WARRICK, Defendant JURY TRIAL DEMANDED I CERTIFICATE OF SERVICE th And now, this J$ day of March, 2014, I hereby certify that a copy of the foregoing Notice of Deposition of Rosella M. Warrick, has been served upon the following, via U.S. First Class Mail: Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 SHOLLENBERGER & JANUZZI, LLP B : �r'?!,.! , o -n..-�g-r, s. / ttorney ID• #34343 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, Plaintiff v. ROSELLA M. WARRICK, Defendant 13 PE11NCUIVERS /� ACp1/,'1rT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-7721 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a Subpoena for documents and things pursuant to Rule 4009.22, Plaintiff certifies that: (1) A Notice of Intent to serve the Subpoena with a copy of the Subpoena attached thereto was mailed or delivered to each party at least twenty (20) days prior to the date on which the Subpoena is sought to be served, (2) A copy of the Notice of Intent, including the proposed Subpoena, is attached to this Certificate, (3) 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. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP Bv: oth Sho enberger, Esq. Date: Attorney I.D. # 34343 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, Plaintiff v. ROSELLA M. WARRICK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-7721 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, this 1 0 day of 1Y14 , 2014, I hereby certify that a copy of the foregoing Certificate Prerequisite has en served upon the following, via First - Class q p 9 Class Mail: Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 SHOLLENBERGER & JANUZZI, LLP i .th _ S • •Ilenberger, sa Attorney ID#34343 2 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, Plaintiff v. ROSELLA M. WARRICK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-7721 CIVIL ACTION — LAW JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 PLEASE TAKE NOTICE that Plaintiffs intend to serve a subpoena identical to the one attached to this notice. You have 20 days from the date listed below in which to file on record and serve upon the undersigned an objection to the subpoena. If no objection is made, the subpoena may be served. SHOLLENBERGER & JANUZZI, LLP By � )7. h enb • ey ID#34343 Date: DL) ', \L4 er, COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Estate of LEON G. RAMSEY, Deceased Plaintiff . File No. 12-7721 VS. ROSELLA M. WARRICK Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: North Middleton Township Police Department (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all documents or things contained in Case File Number 11-002385 pertaining to a motorcycle/motor vehicle crash which occurred on June 11, 2011 at the intersection of Spur Road and Waggoners Gab Road in North Middleton Township. This request includes, but is not limited to the Police Report, Crash Report, photographs, witness statements, and video or tape recordings. at 2225 Millennium Way Enola, PA 17025 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Timothy A. Shollenberger ADDRESS: 2225 Millennium Way Enola, PA 17025 TELEPHONE: . 717-728-3200 SUPREME COURT ID # 34343 ATTORNEY FOR: Estate of LEON c. RAMSEY, Deceased Date: Seal of the Court BY THE COURT: SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, Plaintiff v. ROSELLA M. WARRICK, Defendant rifE. PRO � 2814 JUN RO f �,, ,. 2 PP2.25 CU `BERLAtdp PENNSYLVANIA T Y , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-7721 CIVIL ACTION — LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE L And now, this 11aY of , 2014, I hereby certify that a copy of the foregoing Notice of. Deposition of arry Morrett, has been served upon the following, via U.S. First Class Mail: Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 and Harry Morrett 499 Zion Road Carlisle, PA 17015-7112 SHOLLENBERGER & JANUZZI, LLP By: i thy ' . Sho enbe er, A orney ID#34343 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff c�, THE Pi FILED OFF IC::. 204 JUN e��y� 122: 26 P EP, PENNS YL�,AIDUN r y d1A TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, Plaintiff v. ROSELLA M. WARRICK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-7721 CIVIL ACTION — LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, this 1 I day of foregoing Notice of Deposition of Elizabeth Morrett, has been served upon the following, via U.S. First Class Mail: , 2014, I hereby certify that a copy of the Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 and Elizabeth Morrett 499 Zion Road Carlisle, PA 17015-7112 SHOLLENBERGER & JANUZZI, LLP By: olle •erger, Esq. ttorney ID#34343 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff OF. THE Zply JIM aTi,�; e�BE f 2 2: 26 PEN NSYL COUNTY ANIA TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, Plaintiff v. ROSELLA M. WARRICK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-7721 CIVIL ACTION — LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, this --h'— day of Ti, 2014, I hereby certify that a copy of the foregoing Notice of Deposition of Britney Marsh, has been served upon the following, via U.S. First Class Mail: Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 and Britney Marsh 3175 N. Price Road Apt. 2217 Chandler, AZ 85224 SHOLLENBERGER & JANUZZI, LLP By: Ti J�• y A Sh • enbe ger, sq / A orney ID#34343 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff vly JUN /2 Pfl 2: 26 °fey,;, CUI°18ERLAND COUNTY PENNSYLVANIA TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, Plaintiff v. ROSELLA M. WARRICK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-7721 CIVIL ACTION — LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, this 11q lay of M , 2014, I hereby certify that a copy of the foregoing Notice of Deposition of Officer Matthew B. Claeys, has been served upon the following, via U.S. First Class Mail: Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 and Officer Matthew B. Claeys Lower Allen Township Police Department 2233 Gettysburg Road Camp Hill, PA 17011 SHOLLENBERGER & JANUZZI, LLP By: T)- "hy A . Shollenberger, A ttorney ID#34343 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiff 11114 JUN 12 Ph' 2:25 PENNS AN0 COUNTY q,'Vlq TRACY L. RAMSEY, Individually, and as Personal Representative of the Estate of LEON G. RAMSEY, Deceased, Plaintiff v. ROSELLA M. WARRICK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 12-7721 CIVIL ACTION — LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE And now, this May of , 2014, I hereby certify that a copy of the foregoing Notice of Deposition of orporal James Peterson, has been served upon the following, via U.S. First Class Mail: Michael B. Scheib, Esquire 110 South Northern Way York, PA 17402 and Corporal James Peterson North Middleton Township Police Department 2051 Spring Road Carlisle, PA 17013 SHOLLENBERGER & JANUZZI, LLP By: "t`► • by A. Shollenberger, Esq. Attorney ID#34343