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HomeMy WebLinkAbout13-1672 r --, "C1 rr1 rn rn -+• •� ' "?? to SHOLLENBERGER & JANUZZI, LLP - -`' 2225 Millennium Way = Enola, PA 17025 Telephone Number: (717) 728 -3200 l Fax Number: (717) 728 -3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY IN THE COURT OF COMMON PLEAS SELLERS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. l3 AaRal 0,1vI 1�r� MAJOK HENRY MAJOK and TEREZA G. CIVIL ACTION - LAW MACHAR, JURY TRIAL DEMANDED Defendants YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that, if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION ' *103.7 A AT? - f 2 LIBERTY AVENUE 6*1007 CARLISLE, PA. 17013 OA03� (717) 249 -3166 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728 -3200 Fax Number: (717) 728 -3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY IN THE COURT OF COMMON PLEAS SELLERS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. MAJOK HENRY MAJOK and TEREZA G. CIVIL ACTION - LAW MACHAR, JURY TRIAL DEMANDED Defendants 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 notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomaro medidas y puede entrar una orden contra usted sin previo aviso o notoficacaion y por cualquier queja o alivio que es pedido en la peticion do demanda. usted puede perder dinero o sus propiededas o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE LAS AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CORGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. Lawyer Referral and Information Service CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA. 17013 (717) 249 -3166 SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728 -3200 Fax Number: (717) 728 -3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY IN THE COURT OF COMMON PLEAS SELLERS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. MAJOK HENRY MAJOK and TEREZA G. CIVIL ACTION - LAW MACHAR, JURY TRIAL DEMANDED Defendants QINIPWN AND NOW, comes the Plaintiffs, LAURIE BIXLER and ZACHARY SELLERS by and through their attorneys, SHOLLENBERGER & JANUZZI, LLP, and respectfully represent the following: FACTS APPLICABLE TO ALL COUNTS 1. Plaintiff, Laurie Bixler is an adult individual who currently resides at 903 16 Street, New Cumberland, Cumberland County, Pennsylvania. 2. Plaintiff, Zachary Sellers, is an adult individual who currently resides at 903 16 Street, New Cumberland, Cumberland County, Pennsylvania. 3. Plaintiffs, Laurie Bixler and Zachary Sellers are husband and wife, having been married on December 16, 2010. 4. Defendant, Majok Henry Majok, is an adult individual whose last known address is 4707 Linden Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 5. Defendant, Tereza G. Machar, is an adult individual whose last known address is 4707 Linden Avenue, Mechanicsburg, Cumberland County, Pennsylvania. V 6. The facts and circumstances hereinafter set forth took place on November 4, 2011, at or about 7:18 p.m. on Carlisle Road, Lower Allen Township, Cumberland County, Pennsylvania. 7. At the aforesaid time and place, Plaintiff, Laurie Bixler, was the occupant of a 2000 Ford Focus operated by her husband, Zachary Sellers, bearing Pennsylvania Registration Number HHD -8849. 8. At the aforesaid time and place, Defendant, Majok Henry Majok, was the operator of a 1997 Cadillac Deville, owned by Defendant, Tereza G. Machar, bearing Pennsylvania Registration Number EJY -2303. 9. At the aforesaid time and place, the vehicle occupied by Plaintiff, Laurie Bixler, was being driven east on Carlisle Road approaching the intersection with Cedar Cliff Drive in Cumberland County, Pennsylvania. 10. At the aforesaid time and place, Defendant, Majok Henry Majok, was operating the 1997 Cadillac Deville and attempted to pull out of a pizza parlor parking lot onto Carlisle Road and pulled directly into the path of the 2000 Ford Focus occupied by Plaintiff, Laurie Bixler, whereupon the vehicles collided. 11. As a result of the aforesaid collision, Plaintiff, Laurie Bixler, has suffered serious and permanent injuries, including but not limited to the following: a. Stretching and tearing of the supportive and connective tissues, including but not limited to the muscles, tendons, ligaments and cartilage which with the bones comprise the left ankle joint; b. Injury in and around the left eye; C. Injury to the left knee; d. Concussion with loss of consciousness and temporary amnesia; e e. Injury to the right ankle; f. Annular abrasion on the surface of the left patella; g. Linear laceration across the nasal bone with a slight deformity without open laceration; and h. Partial tear of the anterior talofibular ligament with surrounding mild soft tissue edema. 12. As a direct and proximate result of the aforesaid injuries, Plaintiff, Laurie Bixler, has undergone and in the future will undergo great pain and suffering for which damages are claimed. 13. As a further result of the aforesaid injuries, Plaintiff, Laurie Bixler, has suffered and may continue to suffer a loss of earnings for which damages are claimed. 14. As a further result of the aforesaid injuries, Plaintiff, Laurie Bixler, has and /or may in the future incur a loss of earning capacity for which damages are claimed. 15. As a further result of the aforesaid injuries, Plaintiff, Laurie Bixler, has sustained a permanent diminution in her ability to enjoy life and life's pleasures for which damages are claimed. 16. As a further result of this collision, Plaintiff, Laurie Bixler, has and /or may incur reasonable and necessary medical and rehabilitative costs and expenses in excess of the amounts paid or payable pursuant to Subchapter B of the Pennsylvania Motor Vehicle Financial Responsibility Law, Workers' Compensation or any program, group contract, or other arrangement for payment of benefits as defined in 75 Pa. C.S.A. Section 1719. 17. As a further result of the aforesaid injuries, Plaintiff, Laurie Bixler, has incurred or may hereinafter incur financial expenses and losses which exceed sums recoverable i under the limitations and exclusions of the Pennsylvania Motor Vehicle Financial Responsibility Law for which damages are claimed. 18. Plaintiff, Laurie Bixler, was the named insured on a policy of insurance issued to her by State Farm bearing policy number 147 9990 A01 -38A which was in effect on the date of the above referenced collision. Plaintiff selected the full tort option regarding that policy. Therefore, Plaintiff, Laurie Bixler, remains eligible to claim compensation for non - economic loss and economic loss sustained in this collision pursuant to applicable tort law. COUNT 1 LAURIE BIXLER v. MAJOK HENRY MAJOK 19. Paragraphs 1 through 18 of Plaintiff's Complaint are incorporated herein by reference and made a part hereof as if set forth in full. 20. The aforesaid collision was the direct and proximate result of the negligence of the Defendant, Majok Henry Majok, in operating the 1997 Cadillac Deville in a careless, reckless, and negligent manner as follows: a. Moving his vehicle which was stopped, standing or parked before the movement could be made with safety in violation of Section 3333 of the PA Motor Vehicle Code; b. Failing to stop his /her vehicle at the point nearest the 'intersecting roadway where he /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; C. Entering the roadway from a place other than another roadway without yielding the right -of -way to vehicles approaching on the roadway to be C entered or crossed in violation of Section 3324 of The PA Motor Vehicle Code; d. In failing to have his /her vehicle under proper and adequate control; e. In failing to apply the brakes in time to avoid the collision; f. In failing to observe Plaintiff's vehicle on the highway; g. In operating the motor vehicle at a time when defendant did not have a current Pennsylvania operator's license or registration card in his possession; h. In failing to keep a reasonable look -out for other vehicles lawfully on the road; i. In failing to yield the right -of -way to traffic already upon the highway; j. In turning in such a manner as to endanger other vehicles on the highway; and k. In failing to keep a proper look -out for approaching vehicles. COUNT 2 LAURIE BIXLER v. TEREZA G. MACHAR 21. Paragraphs 1 through 20 of Plaintiff's Complaint are incorporated herein by reference and made a part hereof as if set forth in full. 22. The aforesaid collision is the direct and proximate result of the negligence of the Defendant, Tereza G. Machar, in allowing the Defendant, Majok Henry Majok, to operate the 1997 Cadillac Deville when she knew or should have known that Defendant, Majok Henry Majok, would likely operate the 1997 Cadillac Deville in such a manner as to create an unreasonable risk of harm to other drivers on the roadway s because: a. Defendant Majok Henry Majok's was given the 1997 Cadillac Deville while his driver's license was suspended or revoked. 23. Defendant Tereza G. Machar is jointly, severally and /or vicariously liable with Defendant Majok Henry Majok and Defendant Majok's negligent acts as set forth above are imputed to her because she allowed Defendant Majok Henry Majok to operate a vehicle which was under her ownership and control on a highway when Majok Henry Majok was not authorized to do so under Chapter 15 of the Pennsylvania Motor Vehicle Code and /or was not licensed for the type or class of vehicle being operated in violation of 75 Pa.C.S.A. § 1574. WHEREFORE, Plaintiff, Laurie Bixier, demands judgment against Defendant Tereza G. Machar, for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. COUNT 3 ZACHARY SELLERS v. MAJOK HENRY MAJOK and TEREZA G. MACHAR 24. Paragraphs 1 through 23 of Plaintiff's Complaint are incorporated herein by reference and made a part hereof as if set forth in full. 25. As a further result of injuries sustained by his wife, Plaintiff, Zachary Sellers, has been and will be deprived of the assistance, companionship, consortium and society of his wife, all of which has been and will be to her great detriment and loss. WHEREFORE, Plaintiff, Zachary Sellers, demands judgment against Defendants, Majok Henry Majok and Tereza G. Machar, for compensatory damages in an amount in excess of the amount requiring compulsory arbitration. J � Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP Attorneys for Plai By: A. of nb ger, Esq. /, IiryKot ttorney I.D. #34343 2225 Millennium Way Enola, PA 17025 (717) 728 -3200 Date: 20 (717) 728 -3400 (fax) VERIFICATION I �Url �! X ��� , hereby acknowledge that I am a Plaintiff in this action c n and that I have read the � and that the facts stated herein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Signature Date: G:IGLOBALIWPDATAIDOCSUNITIAL CONSULT DOCS (SETUPS)lverMcation.wpd SHOLLENBERGER 8 JANUZZI, LLP 2225 Millennium wry, Enola, PA 17025 (717) 728 -32oo 1 FAX (717) 728 -3200 AW VERIFICATION 1, &JI-er& hereby acknowledge that I am a Plaintiff in this action and that I have read the C5 Ong IQ rn � 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. Sign re Date: GAGLOSAMPDATAIDOMINITIAL CONSULT DOCS (SETUPS)Werificat(on.wpd SHOLLENBERGER 6 JANUZZI, LLP 2225 M8lannhrm Way, Enola, PA 17025 (717) 728 -3200 ! FAX (717) 728 -3200 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ; Ronny R Anderson Co 3.W. � ,7 f z ' Sheriff of � Jody S Smith CD Chief Deputy , Richard W Stewart 'C-, Solicitor Laurie Bixler(et al.) Case Number vs. Majok Henryy Akoch Isaac Majok(et al.) 2013-1672 SHERIFF'S RETURN OF SERVICE 04/03/2013 12:14 PM-Deputy William Cline, being duly sworn according to law,served the requested Complaint& Notice by handing a true copy to a person representing themselves to be Tereza Machar, Mother,who accepted as"Adult Person in Charge"for Majok Henryy Akoch Isaac Majok af,4707 Linden Ave., Apt 201, Mechanicsburg, PA 17011. LLIA CLINE, DEPUTY 04/03/2013 12:14 PM-Deputy William Cline, being duly sworn according to law, served the requested Complaint& Notice by"personally"handing a true copy to a person representing themselves be the Defendant, to wit:Tereza Machar at 4707 Linden Avenue, Lower Allen, Mechanicsburg A 055. L IAM CLINE, DEPUTY SHERIFF COST: $54.46 SO ANSWERS, ) April 04, 2013 RbNW R ANDERSON, SHERIFF ..County Suite Sheriff,ralaosoft '_... Y BARRY A. KRONTHAL,ESQUIRE i Est �Q n1�+,°, Pa.Supreme Court I.D.No. 55672 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill,PA 17011 ; lM►BE1- � COUNTY Telephone: (717)975-8114 PERSSYLVA" A Attorneys for Facsimile: (717)975-8124 Defendants E-Mail: bkronthal @margolisedelstein.com Majok Henry Majok and Tereza G.Machar File#20200.4-00043 LAURIE BIXLER AND ZACHARY SELLERS COURT OF COMMON PLEAS CUMBERLAND COUNTY, VS. PENNSYLVANIA MAJOK HENRY MAJOK AND TEREZA G. NO. 13-1672 MACHAR CIVIL ACTION-LAW JURY TRIAL DEMANDED PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly enter my appearance on behalf of Defendants, Majok Henry Majok and Tereza G. Machar, in the above-captioned matter. MARGOLIS EDE STEIN Date: �ZZ �� iz arry t 1 ID# 55672 3510 Trindle Road Camp Hill, PA 17011 717-975-8114 Attorney for Defendants CERTIFICATE OF SERVICE / I,t e undersigned, do hereby certify that I have this � 7" day of Ann 1 2013, served a true and correct copy of the foregoing upon the person(s) and in the manner indicated below: Service via United States Postal Service First Class Mail: Tim Shollenberger, Esquire 2225 Millennium Way Enola, PA 17025 MARGOLIS EDELSTEIN By: M:\mdir\Carol\Forms-Info.Sheets-BarTy0eading.headermpd F ILEA;-0FFI , 0 TIDE I'i OTI{0 G A' Y SHOLLENBERGER & JANUZZI, LLP 2'013 KAY 3 1 PM 1-: 59 2225 Millennium Way Enola, PA 17025 CUMBERLAND COUNTY Telephone Number: (717) 728-3200 PENNSYLVANIA Fax Number: (717) 728-3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY IN THE COURT OF COMMON PLEAS SELLERS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. 13-1572 MAJOK HENRY MAJOK and TEREZA G. CIVIL ACTION w LAW MACHAR, JURY TRIAL DEMANDED Defendants CERTIFICATE Oh'SERVlCE And.now; this, day of May, 2013, 1 hereby certify that a copy of the foregoing Plaintiffs Answers to Defendants' Interrogatories, have been served upon the following, via U.S. First Class Mail: Barry Kronthal, Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17110 SHOLLENBERGER & JANUZZI, LLP Aff By: o y Sho enb rger, Esq. Attorney ID#34343 i G F T14'E 1'RO THOND 1 A") SHOLLENBERGER & JANUZZI, LLP �� �, Phi I` 59 2225 Millennium Way Enola, PA 17025 CUMBERLAND COLINT\," Telephone Number: (717) 728-3200 PENNSYLVANIA Fax Number: (717) 728-3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY IN THE COURT OF COMMON PLEAS SELLERS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. 13-1672 MAJOK HENRY MAJOK and TEREZA G. CIVIL ACTION - LAW MACHAR, :;. : JURYTRIAL DEMANDED Defendants CERTIFICATE'bF SERVICE And now, this day of May, 2013, 1 hereby certify that a copy of the foregoing Plaintiff's Response to Defendants' Request for Production of Documents, have been served upon the following, via U.S. First Class Mail: Barry Kronthal, Esquire Margolis Edelstein 3510 Trindle Road .y Camp Hill, PA 17110 t SHOLLENBERGER & JANUZZI, LLP .By. o y . ShollV- 4btrr Attorney ID#34343 r. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, CUMBERLAND -vs- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR rri As a prerequisite to service of a subpoena for documents and thing r su'ant to Rule 4009.22 TCS3 �., >C-) MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE:—07/01/20.13 ;.. c4 n beha f B RY A. K T L, ESQ. T Attorney fo WD FENDANT LWESLOSKIE@MARGOLISEDELSTEIN.COM MCS # 60667-LO1 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, -VS- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations TO: TIMOTHY A. SHOLLENBERGER,ESQ. , PLAINTIFF COUNSEL MCS on behalf of BARRY A. KRONTHAL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/07/2013 MCS on behalf of BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT CC: BARRY A. KRONTHAL, ESQ. 20200.4-00043 THE MCS GROUP INC. TIMOTHY A. SHOLLENBERGER,ESQ. 1601 MARKET STREET SHOLLENBERGER & JANUZZI #800 2225 MILLENIUM WAY PHILADELPHIA, PA 19103 (215) 246-0900 ENOLA, PA 17025 MCS # 60667-CO1 DE02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED DRAYER PHYSICAL THERAPY MEDICAL RECORDS & BILLING ORTHOPEDIC INSTITUTE OF PA MEDICAL RECORDS & BILLING QUANTUM IMAGING MEDICAL RECORDS & BILLING HARRISBURG HOSPITAL MEDICAL RECORDS HARRISBURG HOSPITAL BILLING ONLY INTERNISTS OF CENTRAL PA, LTD MEDICAL RECORDS & BILLING PINNACLE HEALTH EMPLOYMENT STATE FARM INSURANCE SMITH RADIOLOGY MEDICAL RECORDS & BILLING PRATHEESH VISWANATHAN,MD MEDICAL RECORDS & BILLING HERSHEY MEDICAL CENTER MEDICAL RECORDS HERSHEY MEDICAL CENTER BILLING ONLY WEST SHORE EMERGENCY MED SERV. EMS RECORDS MCS # 60667-001 DE02 1 COMMONWEALTH OF PENNSYLVANIA COUNTY.OF CUMBERLAND LAURIE BIXLER&ZACHARY SELLERS File No. 13-1672 vs. MAJOK HENRY MAJOK&TEREZA G. MACHAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DRAYER PHYSICAL THERAPY (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:_ **** SEE ATTACHED RIDER**** at The MCS Group. Inc MI Market Street,Suite Ron Philadelphia PA 19103 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: BARRY A.KRONTHAL, ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILL.PA 17011 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY C U Prot otary/Clerk, Oivil Division / Dater Deputy (Q�(p//3 Seal of the Court 60667-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DRAYER PHYSICAL THERAPY 3399 TRINDLE ROAD FLOOR 2 CAMP HILL, PA 17011 RE: MCS # 60667-L01 LAURIE BIXLER Social Security #: XXX-XX-6171 Date of Birth: 03-13-1985 Please provide entire medical and billing file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten notes, emails, phone messages, history, physical reports and all prescriptions records. Including but not limited to, itemized billing, insurance claims, invoices and payments This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as maybe stored in a computer database or otherwise in electronic form. - Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 60667-LO1 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, CUMBERLAND -VS- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. beh if of DATE: 07/01/2013 BARRY A. KRONTHA SQ. Attorney for DEF NDANT LWESLOSKIE @MARGOLISEDELSTEIN.COM MCS # 60667-L02 DE11 f COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAURIE BDCLER&ZACHARY SELLERS File No. 13-1672 vs. MAJOK HENRY MAJOK&TEREZA G.MACHAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ORTHOPEDI C IN TIT TE(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: **** SEE ATTACHED RIDER at The MCS Group Inc...1601 Marker StrA delphia PA 19103 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: BARRY A. KRONTHAL ESO. ADDRESS: 3510 TR_INDLE ROAD _CAMP HILL PA 17011 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY T C RT: Prot notary/Clerk,Civil Division /�// Date: Deputy Seal of the Court 60667-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ORTHOPEDIC INSTITUTE OF PA 3399 E. TRINDLE RD. CAMP HILL, PA 17011 RE: MCS # 60667-L02 LAURIE BIXLER Social Security #: XXX-XX-6171 Date of Birth: 03-13-1985 Please provide entire medical and billing file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten notes, emails, phone messages, history, physical reports and all prescriptions records. Including but not limited to, itemized billing; insurance claims, invoices and payments This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 60667-L02 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, CUMBERLAND -VS- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. CS o f of DATE: 07/01/2013 BARRY A. KR NTHAL, ESQ. Attorney for DEFENDANT LWESLOSKIE @MARGOLISEDELSTEIN.COM MCS # 60667-L03 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAURIE BIXLER&ZACHARY SELLERS File No. _ 13-1672 VS. MAJOK HENRY MAJOK&TEREZA G. MACHAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for OUANTUM IMA ING (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: **** SEE ATTA HFD RIDER at The MCS Group.Inc t tin t tyrar><Pr C+ran* quite 800 Philadelt�hia PA 19103 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: BARRY A. KRONTHAL ESO. ADDRESS: 3510 TRINDLE ROAD CAMP HILT PA 17011 TELEPHONE:_(215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY Z TH OUR Prot tvi Division Date: (o�(p/�� Deputy Seal of the Court 60667-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: QUANTUM IMAGING 405 SAINT JOHNS CHURCH RD SUITE 102 CAMP HILL, PA 17011 RE: MCS #60667-L03 LAURIE BIXLER Social Security #: XXX-XX-6171 Date of Birth: 03-13-1985 Please provide entire medical and billing file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten notes, emails, phone messages, history, physical reports and all prescriptions records. Including but not limited to, itemized billing, insurance claims, invoices and payments This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 60667-1-03 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, CUMBERLAND -VS- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/01/2013 BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT LWESLOSKIE @MARGOLISEDELSTEIN.COM MCS # 60667-L04 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAURIE BIXLER&ZACHARY SELLERS File No. 13-1672 VS. MAJOK HENRY MAJOK&TEREZA G. MACHAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (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: **** SEE ATTACHED RIDER**** at The MCS Group.Inc L601 Market Street Suite 800 Philadelphia PA 19103 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: _BARRY A. KRONTHAL. ESO ADDRESS: -3 510 TRINDLE ROAD CAMP HILL PA 17011 TELEPHONE:1215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE CO R Prothon /Clerk, Civil ivision Deputy Date: Co ��/3 Seal of the Court 60667-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL MEDICAL RECORDS 111 S. FRONT STREET HARRISBURG, PA 17101 RE: MCS # 60667-L04 LAURIE BIXLER Social Security #: 204-68-6171 Date of Birth: 03-13-1985 Please provide the entire hospital medical file, including but not limited to all inpatient and outpatient records, ER records, physical therapy records, intake or admission forms, correspondence to and from the consulting and treating physicians, and discharge forms. Include all files, memoranda, handwritten notes, history and physical reports. Supply all medication and prescription records, nurses' notes, doctor's comments, dietary and all patient consent or refusal of treatment, . This should contain all records in your possession, including all archived records, records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 60667-L04 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, CUMBERLAND -VS- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. jARRY S n 0 DATE: 07/01/2013 A. K , ESQ. torney for EFENDANT LWESLOSKIE @MARGOLISEDELSTEIN.COM MCS # 60667-L05 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAURIE BIXLER&ZACHARY SELLERS File No. 13-1672 vs. MAJOK HENRY MAJOK&TEREZA G.MACHAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HARRISBURG HOSPITAL (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: **** SEE ATTACHED RIDER**** at The MCS Group. Inc 1601 Market Street Suit 800 Philadelphia,PA 19103 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: BARRY A. KRONTHAL ESQ. ADDRESS: _3.510 TRINDLE ROAD CAMP HILL PA 17011 TELEPHONE:_(215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE C U Prothonotary/Clerk, 1 Di ision Date: Deputy �� Seal of the Court 60667-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HARRISBURG HOSPITAL BILLING DEPARTMENT 111 S. FRONT STREET HARRISBURG, PA 17105 RE: MCS # 60667-L05 LAURIE BIXLER Social Security #: 204-68-6171 Date of Birth: 03-13-1985 Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 60667-LO5 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, CUMBERLAND -VS- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on ehal DATE: 07/01/2013 BARRY A. KRON , ESQ. Attorney for DEV8NDANT LWESLOSKIE @MARGOLISEDELSTEIN.COM MCS # 60667-L06 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAURIE BIXLER&ZACHARY SELLERS File No. 13-1672 VS. MAJOK HENRY MAJOK&TEREZA G. MACHAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for INTE NI. T OF CENTRAL PA LTD (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: **** SEE ATTA HED RIDER**** at The MCS Group- Inc 1601 Market treet Suite 800 Philadell2hia PA 19103 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: BARRY A. KRONTHAL ESQ. ADDRESS: 3510 TRINDLE ROAD CAMP HILL, PA 17011 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Pro iv ivision Date: j�l(p�3 Deputy Seal of the Court 60667-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: INTERNISTS OF CENTRAL PA, LTD 108 LOWTHER STREET LEMOYNE, PA 17043 RE: MCS # 60667-LO6 LAURIE BIXLER Social Security #: XXX-XX-6171 Date of Birth: 03-13-1985 Please provide entire medical and billing file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten notes, emails, phone messages, history, physical reports and all prescriptions records. Including but not limited to, itemized billing, insurance claims, invoices and payments This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 60667-LO6 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, CUMBERLAND -VS- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/01/2013 BARRY A. KRONTHAL, ESQ. Attorney for DEFENDANT LWESLOSKIE @MARGOLISEDELSTEIN.COM MCS # 60667-L07 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAURIE BIXLER&ZACHARY SELLERS File No. 13-1672 VS. MAJOK HENRY MAJOK&TEREZA G. MACHAR : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PINNACLE HEALTH (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: **** SEE ATTACHED RIDER**** at The MCS Groijp.Inc.. 1601 M rke treet Sulte 800 Philadelphia PA 19103 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: BARRY A. KRONTHAL ES ADDRESS: 3510 TRINDLE ROAD CAMP HII.,L PA 17011 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BYTK COURT: n /Clerk,Ci 1 Division Date: Deputy Seal of the Court 60667-07 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH P.O. BOX 8700 HARRISBURG, PA 17105 RE: MCS # 60667-L07 LAURIE BIKER Social Security #: XXX-XX-6171 Date of Birth: 03-13-1985 Any and all employment records— including applications, files, memoranda, compensation, disciplinary actions, time and attendance records. Please include personnel records, W2 forms, payroll and salary information. Supply all employee medical records including any disability, workers compensation, or incident reports and claims. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 60667-LO7 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, CUMBERLAND -VS- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS o f o DATE: 07/01/2013 7 B RY A. NT L, ESQ. Attorney for EFENDANT LWESLOSKIE @MARGOLISEDELSTEIN.COM MCS # 60667-L08 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAURIE BIXLER&ZACHARY SELLERS File No. 13-1672 VS. MAJOK HENRY MAJOK&TEREZA G. MACHAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for STATE FARM (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: **** SEEAJTACHEDRIDER**** at The MC roue Inc 1601 Market Street Suite 800-Philadelphia-PA 19103 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: BARRY A. KRONTHAL ESQ ADDRESS: 3510 TR_INDLE ROAD -CAMP HILL,PA 17011 TELEPHONE:121 5)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT- Prothonotary/Clerk,CiJ it Division l Date: Deputy (o /3 Seal of the Court 60667-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: STATE FARM P.O. BOX 106105 ATLANTA, GA 30348 RE: MCS # 60667-L08 LAURIE BIXLER Social Security #: XXX-XX-6171 Date of Birth: 03-13-1985 Please provide any and all insurance records and PIP files including but not limited to medical records. Include all claims, correspondence documentation supporting plaintiff's claim, and investigative reports, payments including dates of payments, payee, and reasons for payments. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as otherwise in electronic form. CLAIM #38-056S-673 Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 60667-L08 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, CUMBERLAND -VS- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. of DATE: 07/01/2013 BAR Y A. KRONT L, ESQ. Attorney for DEA#DANT LWESLOSKIE @MARGOLISEDELSTEIN.COM MCS # 60667-L09 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAURIE BIXLER&ZACHARY SELLERS File No. 13-1672 VS. MAJOK HENRY MAJOK&TEREZA G.MACHAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SMITH RADIOLOGY (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: SEE ATTACHED RIDER at The MCS—G roue.Inc.. 160 Market Street, Suite 800 Philadelphia.PA 19103 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: BARRY A.KRONTHAL,ESO. ADDRESS: 3510TRIN LE ROAD -CAMP HILL, PA 17011 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Pro::otirylt-erk,Civil ivision Date: Deputy Seal of the Court 60667-09 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: SMITH RADIOLOGY 1515 BRIDGE STREET NEW CUMBERLAND, PA 17070 RE: MCS # 60667-L09 LAURIE BIXLER Social Security #: XXX-XX-6171 Date of Birth: 03-13-1985 Please provide entire medical and billing file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten notes, emails, phone messages, history, physical reports and all prescriptions records. Including but not limited to, itemized billing, insurance claims, invoices and payments This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 60667-L09 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, CUMBERLAND -vs- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. of DATE: 07/01/2013 BARR, A. KRON ESQ. Attorney for DE ENDANT LWESLOSKIE @MARGOLISEDELSTEIN.COM MCS # 60667-L10 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAURIE BIXLER&ZACHARY SELLERS File No. 13-1672 VS. MAJOK HENRY MAJOK&TEREZA G.MACHAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PRATHEESH VISWANATHAN.MD (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: SEE ATTACHED RIDER at The MCS Group.Inc.. 1601 Market Street.Suite 800.Philade ia.PA 19103 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: BARRY A. KRONTRAL.ESO. ADDRESS: -351OT—RINDLEROAD -CAMPHILL.PA 1701.1 TELEPHONE:-L215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: -- Defendant BY THE COURT: n Date:' Deputy Seal of the Court 60667-10 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR: PRATHEESH VISWANATHAN,MD 108 LOWTHER STREET PO BOX 107 LEMOYNE, PA 17043 RE: MCS # 60667-L10 LAURIE BIXLER Social Security #: XXX-XX-6171 Date of Birth: 03-13-1985 Please provide entire medical and billing file, including but not limited to any and all inpatient and outpatient records, ER records, physical therapy records, correspondence to and from the consulting and treating physicians. Include all files, memoranda, handwritten notes, emails, phone messages, history, physical reports and all prescriptions records. Including but not limited to, itemized billing, insurance claims, invoices and payments This should contain all records in your possession, all office and admission charts, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 60667-L10 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, CUMBERLAND -VS- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. t MCS o e of r DATE: 07/01/2013 BARRY A. KRON L, ESQ. Attorney for D ENDANT LWESLOSKIE @MARGOLISEDELSTEIN.COM MCS # 60667-L11 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAURIE BIXLER&ZACHARY SELLERS File No. 13-1672 vs. MAJOK HENRY MAJOK&TEREZA G.MACHAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty(20)day's after service of this subpoena,you are ordered by the court to produce the following documents or things: SEE ATTACHED RIDER at The MCS Group.Inc., 1601 Market Strpet.Suite 800,Philadelphia,PA 19103 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: BARRY A.KRONTHAL,ESO, ADDRESS: 351 TRMDLE ROAD CAMP HILL,PA 17011 TELEPHONE: (215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant OU BY THE C RT�. THE ,Civil lvisi4 Proth'���,Civil ivision Deputy Date:. LI& Seal of the Court 60667-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER MEDICAL RECORDS**HU24 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: MCS # 60667-Lll LAURIE BIXLER Social Security #: 204-68-6171 Date of Birth: 03-13-1985 Please provide the entire hospital medical file, including but not limited to all inpatient and outpatient records, ER records, physical therapy records, intake or admission forms, correspondence to and from the consulting and treating physicians, and discharge forms. Include all files, memoranda , handwritten notes, history and physical reports. Supply all medication and prescription records, nurses' notes, doctor's comments, dietary and all patient consent or refusal of treatment, . This should contain all records in your possession, including all archived records, records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 60667-Lll SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, CUMBERLAND -VS- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. 'behalf DATE: 07/01/2013 BARRY A. KR L, ESQ. Attorney for D FENDANT LWESLOSKIE @MARGOLISEDELSTEIN.COM MCS # 60667-L12 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAURIE BIXLER&ZACHARY SELLERS File No. 13-1672 VS. MAJOK HENRY MAJOK&TEREZA G. MACHAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for HERSHEY MEDICAL CENTER (Name of Person or Entity) Within twenty(20)days after service of this subpoena,you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The M Tro n Inc 1601 Marker Street Suite 800 Philadelphia PA 19103 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: BARRY A. KRONTHAL. ESQ. ADDRESS: 3510 TRiNDLE ROAD CAMP HILL, PA 17011 TELEPHONE:-(215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: Protho otary/ c, Civil vision Date: Deputy Seal of the Court 60667-12 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HERSHEY MEDICAL CENTER BILLING DEPT. 500 UNIVERSITY DRIVE HERSHEY, PA 17033 RE: MCS # 60667-L12 LAURIE BIXLER Social Security #: 204-68-6171 Date of Birth: 03-13-1985 Please provide any and all billing, insurance claims, and payments, outstanding and delinquent invoices. This should contain all records in your possession, all archived records, or records in storage. Including any and all items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 60667-L12 SU10 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS LAURIE BIXLER & ZACHARY SELLERS TERM, CUMBERLAND -VS- CASE NO: 13-1672 MAJOK HENRY MAJOK & TEREZA G. MACHAR As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of BARRY A. KRONTHAL, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. on, DATE: 07/01/2013 BARRY A. F T �`�� Attorney for FENDANT LWESLOSKIE @MARGOLISEDELSTEIN.COM MCS # 60667-L13 DE11 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LAURIE BIXLER&ZACHARY SELLERS File No. 13-1672 VS. MAJOK HENRY MAJOK&TEREZA G. MACHAR SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for WEST SHORE EMERGENCY MED SERV (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: **** SEE ATTACHED RIDER **** at The MC ro n Inc., 1601 Market Street Suite 800-Philadelphia.PA 19103 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: BARRY A. KRONTHAL ESQ. ADDRESS: _3510 T1RINOT,F ROAD CAMP HILL..PA 17011 TELEPHONE:_(215)246-0900 SUPREME COURT ID#: ATTORNEY FOR: Defendant BY THE COURT: ho ler Civil on Date: Deputy � Seal of the Court 60667-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WEST SHORE EMERGENCY MED SERV. 205 GRANDVIEW AVE. SUITE 211 CAMP HILL, PA 17011 RE: MCS # 60667-L13 LAURIE BIXLER Social Security #: XXX-XX-6171 Date of Birth: 03-13-1985 Please provide all treatment, transport, and any refusal of treatment records . This should contain all records in your possession, all archived records and records in storage. Include any items as may be stored in a computer database or otherwise in electronic form. Prior approval is required for fees in excess of $150.00 for hospitals, $100.00 for all other providers. MCS # 60667-L13 SU10 Filt -0-OFFICE BARRY A.KRONTHAL,ESQUIRE C- i�H( P R O T H Q N I O TA i+ Pa.Supreme Court I.D. MARGOLIS EDELSTEIN.5512 } L lg ; 3510 Trindle Road CUMBERLAND COUNTY Camp Hill,PA 17011 PENNSYLVANIA Telephone: (717)975-8114 Attorneys for Facsimile: (717)975-8124 Defendants E-Mail: bkronthal @margolisedelstein.com Majok Henry Majok and Tereza G.Machar File#20200.4-00043 LAURIE BIXLER AND ZACHARY SELLERS COURT OF COMMON PLEAS : CUMBERLAND COUNTY, VS. : PErr NSYL.VANLA MAJOK HENRY MAJOK AND TEREZA G. NO. 13-1672 MACHAR CIVIL ACTION-LAW JURY TRIAL DEMANDED STIPULATION AND NOW, comes Defendants,Majok Henry Majok and Tereza G. Machar, and Plaintiffs,Laurie Bixler and Zachary Sellers, in the above-captioned matter, by and through their respective counsel, and hereby stipulate to the removal of the term"reckless"in Plaintiffs' Complaint. This Stipulation is effective upon the approval of the Cumberland County Court. MARGOLIS EDEL TE1N Date: —711PI43 Barry A. KroAq ID##55672 3510 Trindle Road Camp Hill,PA 17011 717-975-8114 Date: • ' Tim $ 1 er, Es uire ID# 2225 Millennium Way Enola, PA 17025 JUDGE Distribution List: Tim Shollenberger, Esquire 2225 Millennium Way Enola, PA 17025 Barry Kronthal, Esquire 3510 Trindle Road Camp Hill, PA 17011 F CERTIFICATE OF SERVICE I,the undersigned, do hereby certify that I have this . day of 2013, served a true and correct copy of the foregoing upon the person(s) and in thg maaAer indicated below: Service via United States Postal Service First Class Mail: Tim Shollenberger, Esquire 2225 Millennium Way Enola, PA 17025 MARGOLIS EDELSTEIN By: Q'z L u:j 0 F F I C E BARRY A.KRONTHAL,ESQUIRE 01 Pa.supreme Court I.D.No.55672 23113 JUL 24 AM 10: 1 ` MARGOLIS EDELSTEIN 3510 Trindle Road I CUMBERLAMD COUNTY Camp Hill,PA 17011 PENNSYLVANIA Telephone: (717)975-8114 Attorneys for Facsimile: (717)975-8124 Defendants E-Mail: bkronthal @margoli§edelstein.com Majok Henry Majok and Tereza G.Machar File#20200.4-00043 LAURIE BIXLER AND ZACHARY SELLERS COURT OF COMMON PLEAS CUMBERLAND COUNTY, VS, PE!,TNS`T A,rANL"4 _ -- -- MAJOK HENRY MAJOK AND TEREZA G. NO. 13-1672 MACHAR : CIVIL ACTION-LAW JURY TRIAL DEMANDED STIPULATION AND NOW, comes Defendants, Majok Henry Majok and Tereza G. Machar, and Plaintiffs, Laurie Bixler and Zachary Sellers, in the above-captioned matter,by and through their respective counsel,,and hereby stipulate to the removal of the term"reckless"in Plaintiffs' Complaint. This Stipulation is effective upon the approval of the Cumberland County Court. MARGOLIS EDEL TEIN Date: j Barry A. Kro ID# 55672 3510 Trindle Road Camp Hill,PA 17011 717-975-8114 Date: • Tim S 1 er,Es uire ID# , 2225 Millennium ay Enola, PA 17025 JUDGE Xc) Q O� ' t Distribution List: ,Tim Shollenber ,er Esquire g � q 2225 Millennium Way Enola, PA 17025 /Barry Kronthal, Esquire 3510 Trindle Road Camp Hill, PA 17011 CERTIFICATE OF SERVICE I,the undersigned, do hereby certify that I have this L day of 2013, served a true and correct copy of the foregoing upon the person(s) and in thg maaAer indicated below: Service via United States Postal Service First Class Mail: Tim Shollenberger, Esquire 2225 Millennium Way Enola, PA 17025 MARGOLIS EDELSTEIN By: FILED-OFFICE �F THE I'�QTP�Q��#Q1AF�'��. SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way ZB13 SEP "4 AN II. 33 Enola, PA 17025 CUMBER!_ANI) COUNTY Telephone Number: (717) 728-3200 PENNSYLVANIA Fax Number: (717) 728-3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY IN THE COURT OF COMMON PLEAS SELLERS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. 13-1672 MAJOK HENRY MAJOK and TEREZA G. CIVIL ACTION - LAW MACHAR, JURY TRIAL DEMANDED Defendants CERTIFICATE OF SERVICE And now, this -5tdday of September, 2013, 1 hereby certify that a copy of the foregoing Notice of Deposition of Defendant, Majok Majok, has been served upon the following, via U.S. First Class Mail: Barry Kronthal, Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17110 SHOLLENBERGER & JANUZZI, LLP By aimothy A. Shollenberger, Esq. Attorney ID#34343 FILED-OFFICE OF THE PROTHONO F SHOLLENBER'GER & JANUZZI, LLP _ g 33 2225 Millennium Way Enola, PA 17025 CUMBERLAND COUNTY Telephone Number: (717) 728-3200 PENNSYLVANIA Fax Number: (717) 728-3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY IN THE COURT OF COMMON PLEAS SELLERS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. 13-1672 MAJOK HENRY MAJOK and TEREZA G. CIVIL ACTION - LAW MACHAR, JURY TRIAL DEMANDED Defendants CERTIFICATE OF SERVICE And now, this NDWday of September, 2013, 1 hereby certify that a copy of the foregoing Notice of Deposition of Defendant, Tereza Machar, has been served upon the following, via U.S. First Class Mail: Barry Kronthal, Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17110 SHOLLENBERGER & JANUZZI, LLP Byg1moithy IZAhol nber er, Esq. Attorney ID#34343 14 LED-OFFICE OF` THE PROTH.DNOTAR ' .2013 SEP 13 QM Iz = Z SHOLLENBERGER & JANUZZbMftRLAND COUNTY 2225 Millennium Way PENNSYLVANIA Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: . (717) 728-3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY IN THE COURT OF COMMON PLEAS SELLERS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. 13-1672 MAJOK HENRY MAJOK and TEREZA G. CIVIL ACTION - LAW MACHAR, JURY TRIAL DEMANDED Defendants - i CERTIFICATE OF SERVICE i And now, this I day f 2013 1 hereby certify that a co of the t Y � Y fY copy foregoing Request for Production f Documents to the Defendant, Tereza G. Machar, set. No. 1 have been served upon the following, via U.S. First Class Mail: Barry A. Kronthal, Esq. Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 SHOLLENBERGER:& JANUZZI, LLP By: of y X Shol enb ger, sq. Attorney ID#34343 F14-LEa(-oF. 'ic, OF THP �'-RQTHp�OJAL �. SHOLLENBERGER & JANUZZI, LLP 2.813 SEP 13 2225 Millennium Way AN t . 26 Enola, 'PA 17025 CUNBERL,ANp Telephone Number: (717) 728-3200 REN1dSYLVANIA TY Fax Number: (717) 728-3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY IN THE COURT OF COMMON PLEAS SELLERS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. 13-1672 MAJOK HENRY MAJOK and TEREZA G. CIVIL ACTION - LAW MACHAR, JURY TRIAL DEMANDED Defendants CERTIFICATE OF SERVICE And now, this Luray of SeAl. , 2013, 1 hereby certify that a copy of the foregoing Interrogatories have bee served upon the following, via U.S. First Class Mail: Barry A. Kronthal, Esq. Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 SHOLLENBERGER & JANUZZI, LLP By: ; i thy A. holl fiberger, Esq. Attorney ID#34343 31 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)728-3200!FAX(717)728-3400 OFT FILED-OFF-iCL- NOTACZ' , SHOLLENBERGER & JANUZZI, LLP 1J1 $FP, 3 {� 2225 Millennium Way f,! 2 7 Enola, PA 17025 CUNBERLANd COUNTY Telephone Number: (717) 728-3200 PENNSYLVANIA Fax Number: (717) 728-3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY IN THE COURT OF COMMON PLEAS SELLERS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. 13-1672 MAJOK HENRY MAJOK and TEREZAG.' 'CIVILACTION`:= LAW MACHAR, JURYITRIAL DEMANDED Defendants CERTIFICATE OF-SERVICE And now, this, lay of � , 2013, 1 hereby certify that a copy of the foregoing Interrogatories have been upon the following, via U.S. First Class Mail: 9 9 9 p 9� Barry A. Kronthal, Esq. Margolis Edelstein 3510 Trindle Road Camp Hill, PA i17011 SHOLLENBERGER & JANUZZI, LLP . By: o y A. S ollenberg0' ser Attorney ID#34343 31 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)728-3200!FAX(717)72 8-3400 I^1LE °Orr-F' ICE OF THE PROTHONO IAR' 1013 SEP 13 AM 11 21 SHOLLENBERGER & JANUZZI, LbUMBERLAND COUNTY 2225 Millennium Way PENNSYLVANIA Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY IN THE COURT OF COMMON PLEAS SELLERS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. 13-1672 MAJOK HENRY MAJOK and TEREZA G. CIVIL ACTION - LAW MACHAR, JURY TRIAL DEMANDED Defendants I CERTIFICATE OF SERVICE And now, this fAday of i6 2013 .I hereb certi that a co of the Y certify PY foregoing Request for Production of Documents,to the Defendant, Majok Henry Majok, set. No. 1 have been served upon the following, via U.S. First Class Mail: Barry A. Kronth al, Esq. Margolis Edelstein 3510 Trindle Road i Camp Hill,.PA 17011 A SHOLLENBERGER & JANUZZI, LLP By: 0ttc 6fify A. Shollenberger, Esq. rney I D#34343 I. E PRO SHOLLENBERGER & JANUZZI, LLP A R y 2225 Millennium Way 81.3 SEP !8 y ��91�1: 48 Enola, PA 17025 $ AD Telephone Number: (717) 728-3200 PEp ER 5 ` COUNTY Fax Number: (717)728-3400 Y �!A �UP NIA Attorne s.for Plaintiffs LAURIE BIXLER and ZACHARY IN THE COURT OF COMMON PLEAS SELLERS; CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. 13-1672 MAJOK HENRY MAJOK and TEREZA G. CIVIL ACTION - LAW MACHAR, JURY TRIAL DEMANDED , Defendants CERTIFICATE" OF:SERVICE ; And now, this ay of September, 2013 thereby certify that a copy of the ; foregoing Notice of Deposition of Panak Ring Aru, has been served upon the following, via U.S. First Class Mail: i Panak Ring Aru j 5211 Trindle Road Apt. 7 Mechanicsburg, PA 17050 and Barry Kronthal, Esquire Margolis Edelstein 3510 Trindle Road' Camp Hill; PA 17110 SHOLLENBERGER & JANUZZI, LLP i By: T' A. holl berger, Esq. Attorney ID#34343 i I FlL.E,D-QFF110E OF THE PROTHONOTARY SHOLLENBERGER & JANUZZI, LLP Z ;I:3 SEP 18 AM IT: 48 2225 Millennium Way Enola, PA 17025 CUMBERLAND COUNTY Telephone Number: (717) 728-3200 PENNSYLVANI A Fa.x Number: (717) 728-3400 Attorne s for Plaintiffs LAURIE BIXLER and ZACHARY. IN THE COURT OF COMMON PLEAS SELLERS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA V. NO. 13-1672 MAJOK HENRY,MAJOK and TEREZA G. CIVIL ACTION,--LAW MACHAR, JURY TRIAL DEMANDED Defendants CE:RTIFICATEOF'SERVICE And now, this�3 day of September, 2013, I,hereby certify that foregoing Notice of Deposition of Steven Yovicich, has been served upon the following, via U.S. First Class Mail: Steven Yovicich , 697 Julie Court Mechanicsburg, PA 17055 and Barry Kronthal, Esquire Margolis Edelstein s 3510 Trindle Road Camp Hill, PA 17110 SHOLLENBERGER & JANUZZI, LLP i By: oll er er, Esq. Attorney ID#34343 `�1� THE P-RuOT nr iCt. i SHOLLENBERGER & JANUZZI, LLP 2 l rim 2U 2225 Millennium.Way �' 1. �2 Enola, PA 17025 Cu Enola, COO Telephone Number: (717) 728-3200 (�yA Fax Number: (717) 728-3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY IN THE COURT OF COMMON PLEAS SELLERS, CUMBERLAND COUNTY, Plaintiffs PENNSYLVANIA v. NO. 13-1672 MAJOK HENRY MAJOK and TEREZA G. CIVIL ACTION - LAW MACHAR, JURY TRIAL DEMANDED Defendants - I. CERTIFICATE>OF SERVICE`. - And now, thisda y of titWeAll 2013, I hereby certify that a copy of the foregoing Supplemental Interrogatories Directed to Defendant, Tereza G. Machar, have been served upon the following, via U.S. First Class Mail: Barry A. Kronthal, Esq. Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 ;. SHOLLENBERGER & JANUZZI, LLP 111/210(0S.f.Ar By � o' /A ' % len'erg r, sq Attorney l i#34343 6 SHOLLENBERGER&JANUZZI,LLP 2225 MILLENNIUM WAY! ENOLA,PA 17025 (717)728-3200!FAX(717)728-3400 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Laurie Bixler and Zachary Sellers: Plaintiff No. 13-1672 CIVIL TERM VS ■••-.4 rn Ca X. rn-- r - Majok Henry Majok and Tereza G. Machar : ---2:3 = cnr- i= cp , Defendant -<3> ••••4 C) S "In C) RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in following form: r". THE PETITION FOR APPOINTMENT OF ARBITRATORS . 44) TO THE HONORABLE, THE JUDGES OF SAID COURT: Barry A. Kronthal , counsel for the plaintiff/defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $ The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Barry A. Kronthal and Tim Shollenberger WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. ORDER OF COURT AND NOW, 20 , in consideration of the foregoing petition, Esq., and Esq., and Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. By the Court, KEVIN A. HESS, P.J. 4a8.5oPbtv ofao8?alo ef3oilold CERTIFICATE OF SERVICE I, E ; the undersigned, do hereby certify that I have this I6- day of , 2014, served a true and correct copy of the foregoing upon the person(s) and in the manner indicated below: Tim Shollenberger, Esquire 2225 Millennium Way Enola, PA 17025 Service via United States Postal Service First Class Mail: By: MARGOLIS EDELSTEIN s. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Laurie Bixler and Zachary Sellers : Plaintiff NO. 13-1672 CIVIL TERM_ t VSf� c � -a 4, Majok Henry Majok and Tereza G. Machar. _7 N "u Defendant NHS -•. r--.- sue, RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in ) , following form: Az t is THE PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE,THE JUDGES OF SAID COURT: Barry A. Kronthal , counsel for the plaintiff/defendant in the above action(or actions),respectfully represents that: 1. The above-captioned action(or actions)is( )at issue. 2. The claim of plaintiff in the action is$ The counterclaim of the defendant in the action is The following attorneys are interested in the case(s)as counsel or are otherwise disqualified to sit as arbitrators: Barry A. Kronthal and Tim Shollenberger WHEREFORE,your petitioner prays your Honorable Court to appoint three(3)arbitrators to whom the case shall be submitted. Respe 1 su,, 'ed, ORDER OF COURT AND NOW, afill,1,6 P"1 , 20/if , in consideration of the foregoing 91�d4petition, �,._ 1. , /4c,„ Esq., and % " � Esq., and / i i1/i 2 . Esq., are appointed arbitrators in the above Aiptigned action(or actions)as prayed for. de I-- t=. z Q 3ze-- °�7n $1e //r nAr'iyr " - By the Court, /114,),:/ r KEVIN A. S, P.J. tl w2 y� t1 49.8.5o PDt -cc maw-. ///i 0-30 told A CERTIFICATE OF SERVICE L the undersigned, do hereby certify that I have this I6 day of 2014, served a true and correct copy of the foregoing upon the person(s) and in t e manner indicated below: Service via United States Postal Service First Class Mail: Tim Shollenberger, Esquire 2225 Millennium Way Enola, PA 17025 MARGOLIS EDELSTEIN By: 0-00 )12------. i.,...f N.C. g F. Tht:E.I LED 61-71-0FNI COSA N\I- , 1 , . BARRY A.KRONTHAL,ESQUIRE Pa.Supreme Court I.D.No. 55672 MARGOLIS EDELSTEIN 28111 JUN 2 6 A 11 II: 38 3510 Trindle Road Camp Hill,PA 17011 CUNBERL 4ND tCAil TY Telephone: (717)975-8114 PENNS AteA Facsimile: (717)975-8124 Defendirift E-Mail: blcronthal@margolisedelstein.com Majok Henry Majok and Tereza G.Machar File#20200.4-00043 LAURIE BIXLER AND ZACHARY SELLERS : COURT OF COMMON PLEAS CUMBERLAND COUNTY, VS. : PENNSYLVANIA MAJOK HENRY MAJOK AND TEREZA G. • • . • • • NO. 13-1672 MACHAR CIVIL ACTION-LAW JURY TRIAL DEMANDED STIPULATION AND NOW, comes Defendants, Majok Henry Majok and Tereza G. Machar, and Plaintiffs, Laurie Bixier and Zachary Sellers,in the above-captioned matter, by and through their respective counsel, and hereby stipulate to the dismissal with prejudice of Defendant, Tereza G. Machar in Plaintiffs' Complaint. This Stipulation is effective upon the approval of the Cumberland County Court. MARGOLIS .EL, TE114 --Alifata. I Date: 6 I p• _______ ird B&Ty A. ront al ID# 55672 3510 Trindle Road Camp Hill, PA 17011 717-975-8114 Date: 09 „ I , N Tim Shollenber er Esquire ID# St34 2225 Millennium Way Enola, PA 17025 JUDGE M:lmdirkl Main Street America\20200.4-00043 Bizlcr v.MajoklPleadings\Stipularion.2-2K-l4.wpd Date: 09 IS IN Tim Sho1lenberfer Esquire ID# S13i 2225 Millennium Way Enola, PA 17025 JUDGE MAindir11 Main Street America120200.4-00043 Rixler v. Majotaleadings\Stipttlation,2-28-14 wpd ED -OFFICE BARRY A. KRONTHAL, ESQ%JIRK i.' C T L f' C T r '1 Pa. Supreme Court I.D. No. 55672 MARGOLIS LSTEIN 3510 Trindle Road 22 Camp Hill, PA 17011 MOM' Ili Telephone: (717) 975-8114UIcfit_il� CU l Attorneys for Facsimile: (717) 975-8124 r �° Defendants E -Mail: bkronthal@margolisdl§e{{+ in:com� i r Majok Henry Majok File#20200.4-00043 LAURIE BIXLER AND ZACHARY SELLERS COURT OF COMMON PLEAS CUMBERLAND COUNTY, VS. PENNSYLVANIA MAJOK HENRY MAJOK NO. 13-1672 CIVIL ACTION -LAW JURY TRIAL DEMANDED NOTICE TO PLEAD To: Laurie Bixler and Zachary Sellers c/o Tim Shollenberger, Esquire 2225 Millennium Way Enola, PA 17025 YOU ARE HEREBY NOTIFIED to plead to the enclosed ANSWER WITH NEW MATTER OF DEFENDANT, MAJOK HENRY MAJOK, within twenty (20) days from service hereof, or a default judgment may be entered against you. Respectfully submitted, Date: ` © `21 ( MARGOLIS EDE L' EIN Bv: Barry A. Kronthal ID No. 55672 3510 Trindle Road Camp Hill, PA 17011 717-975-8114 Attorney for Defendant BARRY A. KRONTHAL, ESQUIRE Pa. Supreme Court I.D. No. 55672 MARGOLIS EDELSTEIN 3510 Trindle Road Camp Hill, PA 17011 Telephone: (717) 975-8114 Attorneys for Facsimile: (717) 975-8124 Defendants E -Mail: bkronthal@margolisedelstein.com Majok Henry Majok File#20200.4-00043 LAURIE BIXLER AND ZACHARY SELLERS COURT OF COMMON PLEAS CUMBERLAND COUNTY, VS. PENNSYLVANIA MAJOK HENRY MAJOK NO. 13-1672 CIVIL ACTION -LAW JURY TRIAL DEMANDED ANSWER NEW MATTER OF DEFENDANT, MAJOK HENRY MAJOK, TO THE COMPLAINT OF PLAINTIFFS, LAURIE BIXLER AND ZACHARY SELLERS AND NOW, comes Defendant, Majok Henry Majok ("Defendant"), by and through his counsel, Margolis Edelstein, and hereby files this Answer with New Matter to the Complaint of Plaintiffs, Laurie Bixler and Zachary Sellers, collectively referred to as ("Plaintiffs"), averring the following in support thereof: ANSWER 1. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 2. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 3. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted upon information and belief. 8. Admitted. 9. Admitted upon information and belief. 10. Admitted in part and denied in part. It is admitted that at the aforesaid time and place, Defendant was operating a 1997 Cadillac Deville and attempted to pull out of a pizza parlor parking lot onto Carlisle Road and that there was a collision between Defendant's vehicle and the vehicle being occupied by Plaintiff, Laurie Bixler. The remaining averments of this paragraph are generally denied, pursuant to Pa. R.C.P. No. 1029(e). 11. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 12. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 13. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 14. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 15. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 16. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 17. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. 18. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. COUNT I LAURIE BIXLAR v. MAJOK HENRY MAJOK 19. The answers contained in Paragraphs 1 through 18, inclusive hereof, are incorporated by reference herein as is set forth in their entirety. 20. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, the averments of this paragraph are generally denied, pursuant to Pa. R.C.P. No. 1029(e). COUNT II LAURIE BIXLAR v. THERESA G. McCARR 21. The Answer contained in Paragraphs 1 through 20, inclusive hereof, are incorporated by reference herein as is set forth in their entirety. 22-23. The averments of this paragraph are directed to a Defendant who has been dismissed from this case by Stipulation. A copy of said Stipulation is attached hereto, made a part hereof and marked as Exhibit "N'. Therefore, there is no need to answer same. However, to the extent said Paragraphs aver and/or imply any negligence and/or wrongdoing on the part of Defendant, then same are specifically denied. COUNT III ZACHARY SELLERS v. MAJOK HENRY MAJOK AND THERESA G. McCARR 24. The Answers contained in Paragraphs 1 through 23, inclusive hereof, are incorporated by reference herein as is set forth in their entirety. 25. Denied. The averments of this paragraph state a conclusion of law to which no response is required and they are, therefore, denied. By way of further answer, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of this paragraph and they are, therefore, denied. WHEREFORE, Defendant, Majok Henry Majok, demands judgment in his favor, and against Plaintiffs, Laurie Bixlar and Zachary Sellers, with costs assessed to Plaintiff. NEW MATTER 26. The Answers contained in Paragraphs 1 through 25, inclusive hereof, are incorporated by reference herein as is set forth in their entirety. 27. Plaintiffs' claims, if any, are barred by the applicable statute of limitations. 28. The subject collision and Plaintiffs' alleged damages and/or injuries, if any, were solely, directly and proximately caused by Plaintiffs' own negligent, reckless, and/or careless conduct. 29. Plaintiffs' claims, if any, are barred by the doctrines of contributory and comparative negligence and assumption of the risk. 30. Plaintiffs have failed to state a claim upon which relief can be granted. 31. Plaintiffs' claims, if any, are barred by their failure to mitigate their damages. 32. At all times relevant hereto, Defendant was responding appropriately under the circumstances then existing to a sudden emergency. 33. Plaintiffs are precluded from pleading, introducing into evidence, or recovering any and all monies payable as "required benefits" pursuant to the Pennsylvania Motor Vehicle Financial Responsibility Law, Act of February 12, 1984, 75 Pa. Cons. Stat. §1701 et 34. Plaintiffs' claims, if any, are governed by their tort selection. 35. Plaintiffs' alleged damages, if any, were caused by the negligent, reckless, careless, and willful conduct of others over whom Defendant had no control, for whom he is not legally or otherwise responsible. WHEREFORE, Defendant, Majok Henry Majok, demands judgment in his favor, and against Plaintiffs, Laurie Bixlar and Zachary Sellers, with costs assessed to Plaintiff. Date: /0 /0 070(� MARGOLIS Il ELSTEIN Barry'MM thal ID# 556 2 3510 Trindle Road Camp Hill, PA 17011 717-975-8114 Attorney for Defendant CERTIFICATE OF SERVICE , the undersigned, do hereby certify that I have this (>2 ( day of , 2014, served a true and correct copy of the foregoing upon the person(s) and in the manner indicated below: Tim Shollenberger, Esquire 2225 Millennium Way Enola, PA 17025 Service via United States Postal Service First Class Mail: By: M:\ndir\l Main Street America\20200.4-00043 Bixler v. Majok\Pleadings\Answer.6-12-14.wpd SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY SELLERS, Plaintiffs v. MAJOK HENRY MAJOK and TEREZA G. MACHAR, Defendants O 7tFI p D-0FF irOThONO TA R ZllHHNOV _3 PH CUMBERLAND COU PENNSYLVANIA TY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 13-1672 CIVIL ACTION - LAW JURY TRIAL DEMANDED PLAINTIFFS' REPLY TO NEW MATTER OF DEFENDANT MAJOK HENRY MAJOK AND NOW COME THE PLAINTIFFS, LAURIE BIXLER and ZACHARY SELLERS, by and through their attorney, SHOLLENBERGER AND JANUZZI, LLP, and file their Reply to New Matter of Defendant, MAJOK HENRY MAJOK (hereinafter "Defendant"), and, in support thereof, respectfully represent the following: 26. Paragraphs 1 through 25 of the Plaintiffs Complaint are incorporated herein by reference as if set forth in full. 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. Said averment 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). 34. 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). 35. Said averment is denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, the Plaintiffs respectfully requests that the Defendant's New Matter be dismissed and judgment entered in favor of the Plaintiffs as a matter of law. Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP Attorneys P aintiff Date: off. 31,7.0 If orney . . #3.343 2225 Millennium Way Enola, PA 17025 (717) 728-3200 (717) 728-3400 (fax) SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY SELLERS, Plaintiffs v. MAJOK HENRY MAJOK and TEREZA G. MACHAR, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 13-1672 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 3( day of October, 2014, I hereby certify that a copy of the foregoing Reply to New Matter has been served upon the following, via first class mail, addressed as follows: Barry A. Kronthal, Esquire Margolis Edelstein 3510 Trindle Road Camp Hill, PA 17011 Respectfully Submitted, SHOLLE : ERGER & JANUZZI, LLP Attorney-/ or Plaintiffs By: TIm0 .y A . Sl ltile Ti y A. Shollenberger, Esq. PIaintiff I4, Ja Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. 13 - C6 ?. 7 Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office cry/4v 06' Name (Chairman) Law Firm W/9 --,00F/2- `7' ,$( fi- Address CIA/4 r4- (763 City, Zip 1 S isnature Ma 4-tk tv • '� (c�y Name Jo\,,.,,st bo c -V e Law Finn 6% A,- + Address City, Zip ae /Cdd, Law Firm R/C r p fraViee Vs411. 4et /7� dress 7(04i/14,441.? Award We; the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are a - rded, they shall be separately stated.) °Z_ ti-717(///77/5‹//`fes S00'0 , dd. /DateDate of Hearing: // Y/4- Date of Award: (1 7 / Arbitrator; dissents.--(Insertname-ifappiicabl_'e:)-- Notice of Entry of Award Now, the 7 day of /1/04 -Pr's* 20 ( , at ll (90.T.; the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation Lo be paid upon appeal_: S `'// -. By: Prothonotary Deputy LF THE PROTHONOTARY 2014 NOV -3 AM 11: 03 CUMBERLAND COUNTY PENNSYLVANIA e s4.7 4. o e l.:57arrt/ /4 -env --4/ ;e< pia / /47/4' SHOLLENBERGER & JANUZZI, LLP 2225 Millennium Way Enola, PA 17025 Telephone Number: (717) 728-3200 Fax Number: (717) 728-3400 Attorneys for Plaintiffs LAURIE BIXLER and ZACHARY SELLERS, Plaintiffs v. MAJOK HENRY MAJOK and TEREZA G. MACHAR, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 13-1672 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above -captioned matter "settled, discontinued and ended." Respectfully submitted, SHOLLENBERGER & JANUZZI, LLP S • Ilen • erger, Esquire Counsel for Plaintiff Attorney I.D. #34343 Date: 12, if.lN