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HomeMy WebLinkAbout04-5717WILLIE E. LEWIS, Sr. and JOY : IN THE COURT OF COMMON PLEAS OF LEWIS, his wife, : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff : Civil Action -Law NATHAN S. CURLEN, : No. 04 - S117 hER-Pn Defendant Jury trial demanded. NOTICE 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania Telephone number: (717) 249-3166 WILLIE E. LEWIS, Sr. and JOY IN THE COURT OF COMMON PLEAS OF LEWIS, his wife, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Civil Action -Law NATHAN S. CURLEN, No. ('?{ S71 . 7 ? IU1.l,, Fem. Defendant Jury trial demanded. COMPLAINT AND NOW, comes Plaintiff Willie E. Lewis and Joy Lewis, his wife, by and through his attorneys Schmidt, Ronca & Kramer, P.C., and respectfully avers as follows: 1. Plaintiff Willie E. Lewis, Sr., is an adult individual currently residing at 221 Keystone Drive, Middletown, Pennsylvania 17057. 2. Plaintiff Joy Lewis is an adult individual currently residing at 221 Keystone Drive, Middletown, Pennsylvania 17057. 3. Defendant Nathan S. Curlen is an adult individual currently residing at 423 Shippensburg Road, Apt. 3, Newville, Cumberland County, Pennsylvania 17421. 4. The acts and occurrences giving rise to this cause of action took place at approximately March 15, 2003 at 5:30 p.m., on the Carlisle Pike in Hampden Township, Pennsylvania. 5. At that time, Plaintiff was driving a private passenger motor vehicle north on the Carlisle Pike and was stopped at a traffic light posted at the intersection of that road with Hampden Center Drive. 2 6. At that time, Defendant was also operating a private passenger motor vehicle on the Carlisle Pike and was traveling behind Plaintiff. 7. A collision occurred when Defendant rear-ended Plaintiff. 8. The collision caused the injuries and damages to Plaintiff stated in Count I of this Complaint. COUNT I WILLIE E. LEWIS v. NATHAN S. CURLEN NEGLIGENCE 9. Paragraphs 1 through 8 of this Complaint are incorporated herein by reference and made a part thereof as if set forth in full. 10. The accident was caused solely by the carelessness and negligence of Defendant. 11. The accident was in no way caused or contributed to by Plaintiff. 12. The carelessness and negligence of Defendant consisted of the following: a. inattentiveness; b. failure to observe other vehicles lawfully on the roadway; C. failing to have his vehicle under proper and adequate control; d. failing to apply his brakes in time to avoid the collision with Plaintiff, e. failing to keep his vision clear while operating a motor vehicle; f. driving too fast for conditions; g. failing to operate the vehicle in accordance with existing traffic conditions and controls; h. violating the Pennsylvania Motor Vehicle Code, 75 Pa. C.S. § 3310 (a); 3 i. otherwise violating the Pennsylvania Motor Vehicle Code. 13. As a factual result of the collision caused by Defendant's negligence, Plaintiff has sustained serious injuries believed to be permanent including: a. cervical, thoracic, and lumbar strain; b. cervical radiculopathy; C. headaches; d. invasive treatment procedures; 14. As a factual result of the collision, Plaintiff has been advised, and therefore avers, that the aforementioned injuries may be permanent in nature and affect, and thus, a claim for these injuries is made. 15. As a factual result of the accident, Plaintiff has undergone in the past, and will undergo in the future, great pain and suffering, and thus, a claim for these injuries is made. 16. As a factual result of the accident, Plaintiff has been obliged to spend various sums of money and to incur various expenses for the injuries he has sustained, and may continue to incur the same in the future, and thus, a claim for these losses is made. 17. As a factual result of the accident, Plaintiff has suffered a permanent diminution of his ability to enjoy life and life's pleasures, and thus, a claim for this loss is made. 18. As a factual result of the accident, Plaintiff has suffered an impairment of his future earning capacity, as well as a real loss of wages, and thus, a claim for these losses is made. 4 WHEREFORE, Plaintiff prays for judgment against Defendant in an amount requiring compulsory arbitration. COUNT II JOY LEWIS v. NATHAN S. CURLEN LOSS OF CONSORTIUM 19. Paragraphs 1 through 18 of Plaintiffs' Complaint are incorporated herein by reference and made a part thereof as if set forth in full. 20. As a direct and proximate result of the Defendant, Nathan S. Curlen's, negligence, the Plaintiff, Joy Lewis, has been forced to incur the loss of society, companionship, and services of her husband, Willie E. Lewis, Sr. 21. The Plaintiff, Joy Lewis, will continue to incur the same losses in the future and, thus, a claim for these past and future losses is made. WHEREFORE, the Plaintiff, Joy Lewis, demands judgment against the Defendant, Nathan S. Curlen, in an amount in excess of the amount requiring compulsory arbitration. Respectfully Submitted, SCHMIDT, RONCA & KRAMER, P.C. 'lamer, Esquire ?Gerard C. I.D. No. 44715 209 State Street Harrisburg, Pennsylvania 17109 (717) 232-6300 Attorney for Plaintiff 5 VERIFICATION BASED UPON PERSONAL KNOWLEDGE AND INFORMATION SUPPLIED BY COUNSEL I, Willie E. Lewis, Sr., hereby verify that I am the Plaintiff in the foregoing action and that the attached Complaint is based upon the information which has been gathered by my counsel in preparation of this lawsuit. The language of the Complaint is that of counsel and is not mine. I have read the Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the contents of the Complaint are that of counsel, I have relied upon counsel in making this Verification. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsifications made to authorities. Date: /l-//V - 0 7 W 4 t WILLIE E. LEWI , SR. 6 i '' cl-t crt ( cva (? v 't c.; a - ? c r 0 -;_n i ? 1"7 F:\FILES\DATAFILE\DickinsonCollege7619\Collections\Current\ 174.pra3 Created 1211/04 10:12AM e Revised 12/1/04 10:28AM 7619C.174 David R. Galloway, Esquire MARTSON DEARDORFF WILLIAMS & OTTO 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff V. CLARA G. WESSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-5717 CIVIL ACTION-LAW JURY TRIAL OF TWELVE DEMANDED PRAECIPE TO DOCUMENT SERVICE AND; COST OF SERVICE PURSUANT TO THE PENNSYLVANIA LONG ARM STATUTE I hereby certify that a copy of the Complaint was mailed to Clara G. Wessinger on November 18, 2004, by certified mail, return receipt requested. Attached is the Post Office return receipt signed and dated November 22, 2004, and a copy of the receipt showing the cost of service was $4.88. MARTSON DEARDORFF WILLIAMS & OTTO By David R. Galloway, Esquire I.D. No. 87326 10 E. High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: December 1, 2004 Attorneys for Plaintiff so #0 *0 r: cry. AS e ', 4 . ice" mv)kowo PS Form 3811 Er ,a - - (Domestic "' r H 4 aQ A. AJ E , Ln Poerape 50.83 $ ` p -j- o CerMW F,a U4 postmark o (endom ? OW d) (RE RW" Fee $0.00 ) rn & F x.88 1111E/3004 ees Total postape r'r'I O o 6 L s ------ ?- C3 P- . ---- -- ------ ---- /-' = po9errnro. `?v ----------------- .. cibs sfe ' W144 ss U cJ See Rc?erse for Instructions PS Form 3800, June 2002 V ruu3 3110 0004;5772 7119 Y 1 CERTIFICATE OF SERVICE I, JeanTaylor, an authorized agent of Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Clara G. Wessinger 402 Maryland Dr. Grass Valley, CA 95945 MARTSON DEARDORFF WILLIAMS & OTTO Jean Taylor Ten ta?t High Street Carlisle, PA 17013 (717) 243-3341 Dated: December 1, 2004 -. ?-? ? t i ?_ J r . ?? ?' ? ? ' ' ' T .? (._ . (... e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY CIVIL DIVISION LEWIS, his wife, Plaintiffs, NO. 04-571 i' Civil Term V. PRAECIPE FOR APPEARANCE (Jury Trial Demanded) NATHAN S. CURLEN, Defendant. Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road Lemoyne, PA 17043 (717) 901-5916 #13320 Fn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY CIVIL DIVISION LEWIS, his wife, Plaintiffs, NO. 04-5717' Civil Term V. NATHAN S. CURLEN, (Jury Trial Demanded) Defendant. PRAECIPE FOR APPEARANCE TO: THE PROTHONOTARY Kindly enter the Appearance of the undersigned, Kevin D. Rauch, Esquire, of the law firm of Summers, McDonnell, Hudock, Guthrie & Skeel, L.L.P., on behalf of the Defendant, Nathan S. Curlen, in the above case. JURY TRIAL DEMANDED Respectfully submitted, SUMMERS, MCDONNE:LL, HUDOCK, GUTHRIE & SKEEL L.11-.P. By: a ch, Esquire Counsel for Defendant r 0. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR APPEARANCE has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this day of %L?Az , 2004. Gerard C. Kramer, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17109 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL _ By. r K vi auch, =squire Co nsel for Defendant l J ? Ga IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, CIVIL DIVISION NO. 04-5717 Civil Term V. NATHAN S. CURLEN, Defendant. CERTIFICATE PREREQUISITE TO SERVICE 01= A SUBPOENA PURSUANT TO RULE 4009.22 (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road Lemoyne, PA 17043 (717) 901-5916 #13320 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, CIVIL DIVISION NO, 04-5717 Civil Term V. NATHAN S. CURLER Defendant. (Jury Trial Demanded) CERTIFICATE PREREQUISITE TO 13ERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, this Defendant certifies that: 1. A Notice of Intent to Serve Subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty (20) days prior to date on which the subpoena sought to be served. 2. A copy of the Notice of Intent, including the proposed subpoenas, is attached to this Certificate. 3. No objection to the subpoenas has been received, and 4. The subpoenas which will be served are identical to the subpoenas which are attached to the Notices of Intent to Serve the Subpoenas. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SK?E?EL, L.L.P. Date: BY: ../ 1 / l % F Kevin D. Rauch, Esquire Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, CIVIL DIVISION NO. 04-5717 Civil Term V. NATHAN S. CURL-EN, Defendant. (Jury Trial Demanded) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 First Choice Rehabilitation Specialists Medical To: Gerard C. Kramer, Esquire Kevin D. Rauch, Esquire 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 (20) day notice period is waived or if no object iop is made, the subpoena may be served. l ^ /1 Ny W .r& By: Date: Kevin D. Rauch, Esquire Attorney I. D. No. 83058 1017 Mumma Road Lemoyne, PA 17043 (717) 901-5916 Attorney for Defendant, Nathan S. Curlen COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, File No. 04-.5717 Mail merm v. NATHAN S. CURLEN, Defendant. SUBPOENA TO PRODUCE DOCUMENTS OR TMNGS FOR DISCOVERY PURSUANT TO RULE 4009.22 First Choice Rehabilitation Specialists, 899 South TO: Arlington Ave., Harrisburg, PA 17109 (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 Explanation of'Required Records. at 1017 Mumma Road, Suite 300, Lemoyne, PA 17043 . You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies orpioducing 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. THLS SUBPOENA WAS ISSUED AT TBE REQUEST OF THE FOLLOWING PERSON: NAME: Kevin D. Rauch, Esquire ADDRESS: Summers, MCDonnell, Hudock, TELEPHONE:17y 7) g01_r;g16 SUPREME COURT Ib # 8 3 0 5 8 ATTORNEI'FOR Defendant Date: ?.J ?Q'r 1 (.2 , a6n's Seal of-the Court C n??p Deputy Guthrie & Skeel BY THE COURT. Prothonotary, Civil Division EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: First Choice Rehabilitation Specialists 899 South Arlington Avenue Harrisburg, PA 17109 RE: Willie E. Lewis, Sr. - All hospital records (including nurses records and progress notes) - Transcribed hospital records - Clinician office chart notes - Medical records needed for continuity - Dental records - Most recent five-year history - Physical therapy records - Laboratory reports - Emergency & urgency care notes - Pathology reports - Billing statements - X-rays, MRls CT Scans - Diagnostic imaging reports - All reports IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, CIVIL DIVISION NO. 04-5717 Civil Term V. NATHAN S. CURLEN, Defendant. (Jury Trial Demanded) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 J. Ying, Williams, M.D. Medical To: Gerard C. Kramer, Esquire Kevin D. Rauch, Esquire 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 (20) day notice period is waived or if no objection is made, the subpoena may be served. Date: By: ev auch, Esquire Attorney I.D. No. 83058 1017 Mumma Road Lemoyne, PA 17043 (717) 901-5916 Attorney for Defendant, Nathan S. Curlen COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, File No. (,14_5717 t';U.il merm v. NATHAN S. CURLEN, Defendant. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 J. Ying, Williams, M.D., 699 South Arlington Avenue, TO: Arlington Professional Ctr., Harrisburg, PA 17109 (Name ofPerson 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 Explanation of Required Records. at 1017 Mumma Road, Suite 300 PA 17043 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party malting 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: Kevin D. Rauch Esquire ADDRESS:Summers McDonnell, Hudock, Guthrie & Skeel TELEPHONE: f 7 SUPREME COURT ID # ATTORNEY FOR: _? Date: 0. 1, --) gn?s Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: J. Ying Williams, M.D. 899 South Arlington Avenue Arlington Professional Center Harrisburg, PA 17109 RE: Willie E. Lewis, Sr, - All hospital records (including nurses records and progress notes) - Transcribed hospital records - Clinician office chart notes - Medical records needed for continuity - Dental records - Most recent five-year history - Physical therapy records - Laboratory reports - Emergency & urgency care notes - Pathology reports - Billing statements - X-rays, MRls CT Scans - Diagnostic imaging reports - All reports IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, CIVIL DIVISION NO. 04-5717 Civil Term V. NATHAN S. CURLEN, Defendant. (Jury Trial Demanded) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Holy Spirit Hospital To: Gerard C. Kramer, Esquire Medical Kevin D. Rauch, Esquire 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 (20) day notice period is waived or if no objection is made, the subpoena may be served. /„ /i / Date: Attorney I. D. No. 83058 1017 Mumma Road Lemoyne, P.A 17043 (717) 901-5916 Attorney for Defendant, Nathan S. Curlen COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, V. File NO.__04-_';717 r'iyil Term NATHAN S. CURLEN, Defendant. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Holy Spirit Hospital, 503 n. 21st St., Camp Hill, PA 17011 (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 Explanation of Required Records. at 1017 Mumma Road, Suite 300, Lemoyne, PA 17043 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAAIE: Kevin D. Rauch, Esquire ADDRESS: Summers. McDonnell Hudock, 1613 Mumma Road,,_ Suite Inn TELEP O ,:(713) gn1_Sg16 SUPREME COURT_ ID # 8 3 0 5q ATTORN FOR n fandnn _ Date. dry l? ?Cx3 S Seal of the Court Guthrie & Skeel BY THE COURT: 6"7, 2 Prothonotary, Civil Dj; EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: Holy Spirit Hospital 503 N. 21St Street Camp Hill, PA 17011 RE: Willie E. Lewis, Sr. - All hospital records (including nurses records and progress notes) - Transcribed hospital records - Clinician office chart notes - Medical records needed for continuity - Dental records - Most recent five-year history - Physical therapy records - Laboratory reports - Emergency & urgency care notes - Pathology reports - Billing statements - X-rays, MRIs CT Scans - Diagnostic imaging reports - All reports IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, V. NATHAN S. CURLEN, Defendant. CIVIL DIVISION NO. 04-5717 Civil Term (Jury Trial Demanded) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Scott Mueller, M.D./Frederickton Health Center To: Gerard C. Kramer, Esquire Medical Kevin D. Rauch, Esquire 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 (20) day notice period is waived or if no objectigy? is made, the subpoena may be served. 2z Date: By: Ke4n1T Rauch, Esquire Attorney I.D. No. 83058 1017 Mumma Road Lemoyne, PA 17043 (717) 901-5916 Attorney for Defendant, Nathan S. Curlen COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, File No. 04-5777 riv;7 Term V. NATHAN S. CURLEN, Defendant. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 Scott Mueller, M.D., Frederickton Health Center, 2025 Technology TO: Parkway, Suite 205, Mechanicsburg, PA 17050 (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 Explanation of Required Records. at 1017 Mumma Ro< , Suite 300, Lemoyne, PA 17043 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party malting 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. TMS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Kevin D. Rauch, Esquire ADDRESS: Summers. McDonnell, Hudock, Guthrie & Skeel ,1,(117 Mumma Rr2ad3 Suite -400 17043 TELEP O :(717) gnl_5g1F SUPREME COURT ID # a 30 5 8 ATTORNEY FOR: _6efendant Date• 1 0 Seal ofthe Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: Scott Mueller, M.D. Frederickton Health Center 2025 Technology Parkway, Suite 205 Mechanicsburg, PA 17050 RE: Willie E. Lewis, Sr. - All hospital records (including nurses records and progress notes) - Transcribed hospital records - Clinician office chart notes - Medical records needed for continuity - Dental records - Most recent five-year history - Physical therapy records - Laboratory reports - Emergency & urgency care notes - Pathology reports - Billing statements - X-rays, MRIs CT Scans - Diagnostic imaging reports - All reports CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Certificate Prerequisite To Service Of A Subpoena Pursuant To Rule 4009.22 has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this day of February, 2005. Gerard C. Kramer, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17109 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. By:_ zo, P Kevin D. Rauch, Esquire Counsel for Defendant ?? _? ?; . , .'_, -- , ?, ?' f. + . ? ? ?.. ? ?_ a r.J __ ?„? WILLIE E. LEWIS, Sr. and JOY LEWIS, his wife, Plaintiff NATHAN S. CURLEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - Law No. 04-5717 Civil Term Jury trial demanded PLAINTIFFS' ANSWER TO NEW MATTER AND NOW, come Willie E. Lewis, Sr. and Joy Lewis, his wife, by and through their attorneys, Schmidt, Ronca & Kramer, P.C. and responds to Defendant's New Matter as follows: 22. Paragraph 22 states a conclusion of law to which no responsive pleading is necessary. 23. Paragraph 23 states a conclusion of law to which no responsive pleading is necessary. 24. Paragraph 24 states a conclusion of law to which no responsive pleading is necessary. 25. Paragraph 25 states a conclusion of law to which no responsive pleading is necessary. WHEREFORE, the Plaintiff requests that the New Matter of the Defendant be dismissed and judgment entered in favor of the Plaintiff. Respectfully Submitted, SCHMIDT, RONCA & KRAMER, P.C. BY 'VIrard C. Kramer Attorney at Law Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiff ATTORNEY VERIFICATION I, Gerard C. Kramer, Esquire, verify that I am attorney of record for the Plaintiff. I verify that the facts contained in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that intentional false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsifications to authorities. /? Date: '42 Z- 6 ,,/G Clerard C. Kramer, Esquire CERTIFICATE OF SERVICE AND NOW, this Pc day of 2005 I, Gerard C. Kramer, Esquire, hereby certify that I have this day served a true and correct copy of the Plaintiffs' Answer to New Matter by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Kevin Rauch, Esquire Summers, McDonnell, Walsh & Skeel 1017 Mumma Road Lemoyne, PA 17043 Attorney for Defendant Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. By: Perard C. Kramer, Esquire 'Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs 1? T CP N W 7z, N .SD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, CIVIL DIVISION NO. 04-5717 Civil Term V. NATHAN S. CURLEN, Defendant. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road Lemoyne, PA 17043 (717) 901-5916 #13320 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, CIVIL DIVISION NO. 04-5717 Civil Term V. NATHAN S. CURLEN, Defendant. (Jury Trial Demanded) CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, this Defendant certifies that: 1. A Notice of Intent to Serve Subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty (20) days prior to date on which the subpoena sought to be served. 2. A copy of the Notice of Intent, including the proposed subpoenas, is attached to this Certificate. 3. Opposing counsel waived the twenty (20) day notice requirement in a letter dated March 3, 2005 (A true and correct copy of the correspondence dated March 3, 2005, is attached as Exhibit A) 4. The subpoenas which will be served are identical to the subpoenas which are attached to the Notices of Intent to Serve the Subpoenas. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. C-Ic Date: -J v o? BY: PAZ 9 Kevin D. Rauch, Esquire Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, CIVIL DIVISION NO. 04-5717 Civil Term V. NATHAN S. CURLEN, Defendant. (Jury Trial Demanded) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Becker Chiropractic To: Gerard C. Kramer, Esquire Medical Kevin D. Rauch, Esquire 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 (20) day notice period is waived or if no objection is made, the subpoena may be served. Date:P-G0 By: Kevin D. Rauch squire Attorney I.D. No. 83058 1017 Mumma Road Lemoyne, PA 17043 (717) 901-5916 Attorney for Defendant, Nathan S. Curlen COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WILLIE E LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, File No. 04-5717 Civil Term ,LI NATHAN S. CURLEN, Defendant. SUBPOENA TO PRODUCE DOCUMENTS OR TMNGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TOcBe_c_ker Chiropractic 501 Market St. Lemoyne, PA 17043 (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 Explanation of Required Records. I - at 1017 Mumma Road, Suite 300, Lemoyne, PA 17043. . (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate. of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the. documents or things required by this, subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it TMS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Kevin D Rauch- Escruire ADDRESS `SGfnmers ° McDotinell,'"-Hiidock, Guthrie & Skeel 1O 1- 7,,,'- is Road` Suite 300 Beiuovne -PAi11043 ID# 83058 Dater Sealc BY COURT: EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: Becker Chiropractic 501 Market Street Lemoyne, PA 17043 (717) 763-7711 RE: Willie E. Lewis, Sr. DOB: May 25, 1946 SSN: 172-36-2368 All hospital records (including nurses records and progress notes) Transcribed hospital records Clinician office chart notes Medical records needed for continuity Dental records - Most recent five-year history - Physical therapy records - Laboratory reports - Emergency & urgency care notes - Pathology reports - Billing statements - X-rays, MRIs CT Scans - Diagnostic imaging reports - All reports 209 State Street 1528 Walnut Street, 3rd Floor Harrisburg, Pennsylvania 17101 Philadelphia, PA 19102 717.232.6300 215.790.7303 VOICE FAX 717.232.6467 215.546.0942 FAX LAW www.srklaw.com YSchrnidt, Ronca & Kramer PC Please respond to Harrisburg office. JURY LAWYERS March 3, 2005 Kevin D. Rauch, Esquire Summers, McDonnell, Hudock, et al. 1017 Mumma Road Lemoyne, PA 17043 Re: Lewis v. Curlen No. 04-5717 Civil Term Your File No.: 13320 Dear Kevin: I received your Notice of Intent to serve a Subpoena on Becker Chiropractic. I waive the 20-day requirement with the condition that you send promptly to my attention a copy of any documents you receive in response to the Subpoena. If you have any questions, please feel free to call or write. Very truly yours, SCHMIDT, RONCA & KRAMER, P.C. erard C. Kramer Attorney at Law GCK/det o CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Certificate Prerequisite To Service Of A Subpoena Pursuant To Rule 4009.22 has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this ?t7Z day of March, 2005. Gerard C. Kramer, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17109 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. By: / Y 70 r- Kevin D. Rauch, Esquire Counsel for Defendant 1? ? '1.-1 1 ?, ! ? SHERIFF'S RETURN - REGULAR CASE NO: 2004-05717 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LEWIS WILLIE E SR ET AL VS CURLEN NATHAN S RICHARD HOWELL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CURLEN NATHAN S the DEFENDANT , at 1210:00 HOURS, on the 7th day of December-, 2004 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 NATHAN CURLEN by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.88 Affidavit .00 Surcharge 10.00 .00 36.88 Sworn and Subscribed to before me this day of u?ca?..fft) A. D. i ?.r? 1 Prothonotary So Answers: R. Thomas Kline 12/07/2004 SCHMIDT RONCA KRAM By: C Depu y Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, CIVIL DIVISION NO. 04-5717 Civil Term V. NATHAN S. CURLEN, Defendant. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 1017 Mumma Road Lemoyne, PA 17043 (717) 901-5916 #13320 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, CIVIL DIVISION NO. 04-5717 Civil Term V. NATHAN S. CURLEN, Defendant. (Jury Trial Demanded) CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, this Defendant certifies that: 1. A Notice of Intent to Serve Subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty (20) days prior to date on which the subpoena sought to be served. 2. A copy of the Notice of Intent, including the proposed subpoena, is attached to this Certificate. 3. Opposing counsel waived the twenty (20) day notice requirement in a letter dated April 28, 2005 (A true and correct copy of the correspondence dated April 28, 2005, is attached as Exhibit A) 4. The subpoena which will be served is identical to the subpoena which is attached to the Notice of Intent to Serve the Subpoena. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. Date: BY: 7(&A) i/ riGI, Kevin D. Rauch, Esquire Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIE E. LEWIS, SR., and JOY LEWIS, his wife, Plaintiffs, CIVIL DIVISION NO. 04-5717 Civil Term V. NATHAN S. CURLEN, Defendant. (Jury Trial Demanded) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Traveler's Insurance To: Gerard C. Kramer, Esquire Insurance Kevin D. Rauch, Esquire 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 (20) day notice period is waived or if no objection is made, the subpoena may be served. ?U-1? Date: By: YLa ? _rrv? Kevin D. Rauch, Esquire Attorney I.D. No. 83058 1017 Mumma Road Lemoyne, PA 17043 (717) 901-5916 Attorney for Defendant, Nathan S. Curlen COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WILLIE E. LEWIS, SR., and File No. 04-5717 JOY LEWIS, his wife, Plaintiffs, V. NATHAN S. CURLEN, Defendant - - - - -SUBPOMkTO PRODUCE-DOCUMENTS-OR-T1DXGS- - FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Traveler's Insurance (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 Explanation of Records at 1017 Mumma Road, Suite 300, Lemoyne, PA 17043 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate- of compliance, to the party malting 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 'I -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: Kevin D. Rauch, Esquire ADDRESS: 101 -Mumma uJ e 300 Lemovne. Pennsvlvania 17043 TELEPHONE:. .(717) 9 01 -5916 SUPREME COURT ID# 8 3O 5 8 ATTORNEI'FOR: Defendant Date: 2? L C} ljp S Sell of the Court -t- BY COURT: Prothonotarv. Civil Division y .C EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: Traveler's Insurance RE: Willie E. Lewis, Sr. Policy No. : 015941875 101 1 - A complete copy of the insurance declarations page in effect on March 15, 2003, relating to the above-captioned policy number and your insured, Willie E. Lewis, Sr. LAW Schmidt, Ronca & h a INJURY LAWYERS April 28, 2005 209 State Street Harrisburg, Pennsylvania 17101 717.232.6300 FAX 717.232.6467 www.srklaw.com PC TO 1528 Walnut Street, 3rd Floor Philadelphia, PA 19102 215.790.7303 VOICE 215.546.0942 FAX Affiliated Law Firm - Sheller, Ludwig & Barley, P.C. Philadelphia, PA Kevin D. Rauch, Esquire Summers, McDonnell, Hudock, et al. 1017 Mumma Road Lemoyne, PA 17043 Re: Lewis v. Curlen No. 04-5717 Civil Term Your File No.: 13320 Dear Kevin: I received your Notice of Intent to serve a Subpoena on Traveler's Insurance. I waive the 20-day requirement with the condition that you send promptly to my attention a copy of any documents you receive in response to the Subpoena. If you have any questions, please feel free to call or write. Very truly yours, SCHMIDT, RONCA & KRAMER, P.C. f erard C. Kramer Attorney at Law GCK/det U or ?A , CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Certificate Prerequisite To Service Of A Subpoena Pursuant To Rule 4009.22 has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this Q day of 2005. Gerard C. Kramer, Esquire Schmidt, Ronca & Kramer, P.C. 209 State Street Harrisburg, PA 17109 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. By: IN ; 6? Kevin D. Rauch, Esquire Counsel for Defendant (? ?:. =Y 1 ?? ..t C ?", `'. C7 ?"7 ?; ,. (: i _ 'z) { C.J r SCHMIDT KRAMER PC By: Gerard C. Kramer, Esquire 209 State Street Harrisburg, PA 17101 (717) 232-6300 Fax (717) 232-6467 gkramer@schmidtkramer.com Attorneys for Plaintiffs WILLIE E. LEWIS, Sr. and JOY LEWIS, his wife, Plaintiff NATHAN S. CURLEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : Civil Action -Law : No. 04-5717 Civil Term : Jury trial demanded PLAINTIFFS' PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: Gerard C. Kramer, counsel for the Plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue. 2. The claim of the Plaintiff in the action is unliquidated amount and Plaintiff consents to the $35,000.00 limit of an arbitration award. The Defendant does not have a counterclaim. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: Gerard C. Kramer, Esquire Schmidt Kramer PC 209 State Street Harrisburg, Pa 17109 Kevin Rauch, Esquire Summers, McDonnell, Hudock Guthrie 8. Skeel, LLP 1017 Mumma Road Lemoyne, Pa 17043 WHEREFORE, your Petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. DATED: U 3//O?o By I Respectfully submitted, SCHMIDT KRAMER PC C. Kramer Attorney at Law I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs V CERTIFICATE OF SERVICE AND NOW, this`- day of rljj_Q&?Ak , 2005 I, Gerard C. Kramer, Esquire, hereby certify that I have this day served a true and correct copy of the Plaintiffs' Petition for Appointment of Arbitrators by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Kevin Rauch, Esquire Summers, McDonnell, Walsh 8v Skeel 1017 Mumma Road Lemoyne, PA 17043 Attorney for Defendant Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. By: erard C. Kramer, Esquire Z Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Attorney for Plaintiffs n +a D (Aj JZ? %0 1 SCHMIDT KRAMER PC By: Gerard C. Kramer, Esquire 209 State Street Harrisburg, PA 17101 (717) 232-6300 Fax (717) 232-6467 gkramer@schmidtkramer.com Attorneys for Plaintiffs WILLIE E. LEWIS, Sr. and JOY LEWIS, his wife, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NATHAN S. CURLEN, Defendant Civil Action -Law : No. 04-5717 Civil Term : Jury trial demanded ORDER AND NOW, this ?- day of , 2006 in consideration of the forgoing petition, J.?m sq., . sq., and X-IL"'Isq., are appointed arbitrators in the above-captioned a tion as prayed for. 1: Est951- ?oP`? ?eO?O d Gerox BY THE URT, Cnv1 1 P.J. rr= UJ c?7 es F -- Ci'7 =. f I `._) ,u} t 16,r i en ' Paint f h? I -i U? r ?1 S L Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. 'Dq - 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 with f i Us ature igna e Y O V)-x"- Cr 4V v Name (Chairman) Name ! Name lJ ?l '?'"' VC?VI- lb(Jrl,(/U?y • ??T?r? ?i? 1% avF ? cL? Law Firm Law Firm il.n? ?cC wVCQA-/,r--- au y Address Address 70 1 44 / 74 (city, zip City, Zip 6A-u) (AZv-F- CXJ. A.VErm r Law Firm Ll 4 S. A.4moyf..g S -T Address CA-2.LcsL*- 1 r?or 3 City, zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the CLl A#ollowing award: (Note: If damages for delay are awarded, they shall be separately stat c . Qlru r It 1 -7 -1 Z -7 2 r ^-,j, ,ng A A A i q-t ;.. Atj?-, /, . ;- -A rn? 1, W. z . Arbitrator, dissents. sert name if applicabl Date of Hearing: (fit V Chairman ( ) Date of Award: ? Notice of Entry of Award Now, the -1YL day of _ Janyar --, 206_, at A M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ a90. DO By: Prothonotary Deputy a,IP,d e,r ,? P ?3 ko PLFF Wi the Leu;s1 pocket e o rA YA s a 4 ? o r) fo r ooi ? Y1SES 11 1LC 2'U ?? PUFF 4- 550w-j'° CornpNnsa4c,n ?t- PCA-tn + SoReri,9 Ou) d ? r Corn ?nsCc h t l Tor PLPP -Joy Le- ,s ?V- Ck- 4-c;k:d of .+ ?OMSI,a in of PI-Pp 4- (1,( ' r us+ ? f4 -):?us Coss C) SCHMIDT KRAMER PC BY: Gerard C. Kramer, Esquire Attorney I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Fax No. (717) 232-6467 Attorney for Plaintiff akramex(a),schmidtkramer.com WILLIE E. LEWIS, SR. AND JOY : IN THE COURT OF COMMON PLEAS LEWIS, HIS WIFE, : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff O LA_ 5q ' V. No. NATHAN S. CURLER, Defendant : CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Please mark the above-captioned action settled, discontinued and ended with prejudice. Respectfully submitted, SCHMIDT KRAMER PC BY erard C. Kramer, Esquire Attorney for Plaintiff -10 N ? L14ko t (? ' P aint f Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. ID 4 - (;- I 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 with f i . C S ature a igna e TMIS y Name (Chairman) Name Name 6AW 04?--F 41j, A.VErAj Law Firm Law Firm Law Firm ?:UwWk t&?? - & Ll 4 S, A4#uovcg S'T- Address Address Address 70 1) /?. , A ,Y/. ?0- 7d l / C,9,- s (. ?, ??a rho r 3 City , Zip City,/- Zip city, zip 108 * 1616A 19,880 Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the ollowing award: (Note: If damages for delay are awarded, they shall be separately stat d.). tti i in-it t '1-1 2 -7 2 r A- j A A 4 M?A ?r ??_.. av (P 9 72-,.) Lf- IM -I ) 11 V i??-7 LT?? . Arbitrator, dissents. sert name if applicabl Date of Hearing: 6 0 ? 0 Chairman Date of Award: qo /K . Notice of Entry of Award Now, the -day of _ u , 20_03 _,at 11: 11A.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ J90. 00 (Z 2f9 By: Prothonotary Deputy op d 1. 0, 1 R3 -b PLFF (,?i lily Le-" for DLIIA 01pccice-t - ?1 5 1??C L?-t C b? fkFF ConvP6nsa4Ac?n Pb +S0?ef'It C l r (? Lan1 nSCc? ` ! f ,c, 4r LWT' JoC Le u is ?v- c? 4-t c?- ) aL?d' ¢ 713 "7? in vac- ©t PL-F: ?- /? k i