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HomeMy WebLinkAbout04-5892 WILLIAM P. DOUGLAS, ESQUIRE SUPREME COURT LD. # 37926 DOUGLAS LAW OFFICE 27 WEST HIGH STREET CARLISLE, PA 17013 TELEPHONE (717) 243-1790 EILEEN L. MINNICH and BRUCE E. MINNICH, her husband, and PAMELA J. SHEAFFER and JAMES R. SHEAFFER, her husband v. AUTUMN RICKRODE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P A CIVIL ACTION - LAW NO. 2004- Sg- 4}- JURY TRIAL DEMANDED PRAECIPE TO ISSUE A WRIT OF SUMMONS Dear Mr. Long: Please issue a writ of summons against the defendant, Autumn Rickrode. Dated: November 19, 2004 ~~~ . . ~ . William P. Douglas, Esquire Attorney for Plaintiffs 8 <"" -0 (i~ ~9J ZL' -....L~ (I) ;.t~ ~ -<"': ~c ~c ~ ~~ ~\\ ~ ~ ~ (/', , ~ ~ ~ ~ r--.) (:::) (:::) .&:"' :z: c -< N eN -0 :x Ci? 0"\ ~ ~..... 01-:'-: ~~ :J:-r; O:D Z~ S ~ ~ EILEEN L. MINNICH and BRUCE E. MINNICH, her husband, and PAMELA J. SHEAFFER and JAMES R. SHEAFFER, her husband IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, P A CIVIL ACTION - LAW NO. 2004 - 5?i q J- V. AUTUMN RICKRODE JURY TRIAL DEMANDED WRIT OF SUMMONS To: Autumn Rickrode 46 East Penn Street Carlisle, P A 17013 You are hereby notified that Eileen L. Minnich and Bruce E. Minnich, her husband, and Pamela J. Sheaffer and James R. Sheaffer, her husband, have brought an action against you. r~ R.K~ Proth8notary Dated: November ~ 3 , 2004 ~ WILLIAM P. DOUGLAS, ESQUIRE DOUGLAS LAW OFFICE 27 WEST HIGH STREET CARLISLE, PA 17013 TELEPHONE (717) 243-1790 ATTORNEY FOR PLAINTIFFS (") "'-.3 ~ e:::> ~ ''0 :'i,. ~ ~ cn fP t5 :r ~ it" -.f.! ~~.': '< m.::!J I'\) -hi ~ r:(~- w e36 18 ;j ~=B c ~ e5f~ :2 A\\ =< -c-i ~ 0'\ -< ~ ........... ..... ~ "- ~ ~ -.J () \ ~ ~ ~ ~ .. EILEEN L. MINNICH and BRUCE E. MINNICH, her Husband, -and - : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA No. 2004-5892 PAMELA J. SHEAFFER and JAMES R. SHEAFFER, her husband CIVIL ACTION - LAW : JURY TRIAL DEMANDED Plaintiffs v. AUTUMN RICKRODE, Defendants. PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of undersigned counsel on behalf of Defendant, Autumn Rickrode. By: Richard B. Druby Attorney I.D. # 61 840 E. Chocolate venue Hershey, PA 17033 Tel: 717-533-5406 Fax: 717-533-5717 Attorneys for Defendant Date: Iv!t~!u { I J CERTIFICATE OF SERVICE I, Richard B. Druby, of the law firm ofNestico, Druby & Hildabrand, LLP, hereby certify that on the r:2 I ~ay of December, 2004, a copy of the foregoing document was sent via First Class U.S. Mail, postage paid, to the following: William P. Douglas, Esquire 27 West High Street Carlisle, P A 17013 (") f? ~~i~ ~( ~f-=) )>c z --l -< "-.) = = .r- o ""T1 --I f*i:n r- um :1') 0 Q-L --\0 I-t-; !~) -r1 , . (") c.'5 rn ..-\ "- :-.i:J .< o ,..., ('"') N <XJ -0 :J: ~ w .s:- EILEEN L. MINNICH and BRUCE E. MINNICH, her Husband, -and- : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA No. 2004-5892 PAMELA J. SHEAFFER and JAMES R. SHEAFFER, her husband : CIVIL ACTION - LAW : JURY TRIAL DEMANDED Plaintiffs v. AUTUMN RICKRODE, Defendants. PRAECIPE FOR RULE TO FILE A COMPLAINT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter Rule on the Plaintiffs to file a Complaint within twenty (20) days of service or suffer judgment of non pros. By: Date: 1!o~S ( , chard B. Druby, Es ire Attorney J.D. No. 619 840 East Chocolate Avenue Hershey, Pennsylvania 17033 (717) 533-5406 Attorney for Defendant RULE TO FILE A COMPLAINT To: William P.Douglas, Esquire 27 West High Street Carlisle, P A 17013 You are hereby directed to file a Complaint in the abovt: matter within twenty (20) days of service or non pros will be entered against you. Date: ,j~. IO,.;lf)OS ~~. Prothonotary CERTIFICATE OF SERVICE I, Richard B. Druby, of the law firm ofNestico, Druby & Hildabrand, LLP, hereby certify that on the ~ day of January, 2005, a copy of the foregoing document was sent via First Class U.S. Mail, postage paid, to the following: William P. Douglas, Esquire 27 West High Street Carlisle, P A 17013 .' r . -' o s:: r'~ = = <:..f'\ <- -- ...-; ---) --. o -n -l :'L1:!l P, -nq - f) '--' a~ '--:? ~ o ~ .....i.~.", '.J) W -;;>- :~ DOUGLAS LAW OFFICE 1:1 W.HIGH ST. POB 261 CARLISLE P A 17013 TELEPHONE 717-243-1790 WILLIAM P. OOUGLAS. ESQ. Supreme Court I.D.# 37926 Eileen L. Minnich and Bruce E. Minnich, h/h Pamela J. Sheaffer and James R. Sheaffer, h/h In the Court of Common Pleas of Cumberland County, Pennsylvania Plaintiffs vs No. 04 - 5892 Civil Term Autumn Rickrode Civil action law Jury Trial Demanded Defendant NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACfION WITHIN TWENTY DAYS AFfER 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 OBJECfIONS 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 MAYBE 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 AFJ~ORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Square Carlisle PA 17013 717-249-3166 BY~ DATE: January 26,2005 Complaint 1. The plaintiff, Eileen 1. Minnich and Bruce E. Minnich, her husband, are adult individuals residing at 1844 Pine Road, Newville, Pennsylvania. 2. The plaintiff, Pamela J. Sheaffer and James R. Sheaffer, her husband, are adult individuals residing at 2256 Pine Road, Newville, Pennsylvania. 3. The Defendant, Autumn Rickrode, is an adult individual residing at 46 East Penn Street, Carlisle, Cumberland County,. Pennsylvania. 4. On or about, December 6, 2002, the plaintiff Pamela J. Sheaffer and her passenger Eileen 1. Minnich were traveling east on Old York Road, Dickinson Township, Cumberland County, Permsylvania. 5. At about the same time and place, the defendant was operating her vehicle on Dickinson School Road and failed to stop for the stop sign at the intersection of Old York Road and proceeded to collide with the vehicle occupied by the plaintiffs. 6. The vehicles traveling on Old York Road had the right of way at said intersection. 7. The impact occurred as a direct and proximate result of the defendant's negligence. 8. The defendant was negligent in the following respects: a) failing to maintain a proper lookout; b) failing to drive within the assured clear distance ahead; c) failing to operate her vehicle in a safe and prudent manner; d) failing to stop her vehicle before she collided with the plaintiff. e) failing to obey traffic control devices and yield the right-of-way. Count 1 Eileen L. Minnich v Autumn Rickrode 9. The allegations in paragraphs 1 through 8 are incorporated herein and reference is made thereto. 10. As a direct and proximate result of the negligence of the defendant the plaintiff, Eileen 1. Minnich, was injured. Her injuries, and/ or aggravation of possible pre-existing condition(s), include but are not limited to: a) injury to her nerves and nervous system; b) injury to her spine and supporting structures; c) injury to her legs; d) injury to chest and chestwall; e) cervical sprain/ strain 11. As a result of her injuries, the plaintiff has incurred medical expenses in the past and may continue to incur the same in the future in amounts that may not be covered by the Pennsylvania Motor Vehicle Financial Responsibility Act. 12. As a result of her injuries, the plaintiff has incurred pain and suffering and may continue to incur the same in the future. 13. As a result of her injuries, the plaintiff has incurred aggravation, inconvenience, disability, and a loss of life's pleasures, and may continue to incur the same in the future. 14. As a result of the injuries the plaintiff sustained on December 6,2002, the plaintiff may have lost wages and the plaintiff's economic horizons may be limited. Wherefore it is prayed that judgment be entered in favor of the plaintiff and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. Count 2 Pamela J. Sheaffer v Autumn Rickrode 15. The allegations in paragraphs 1 through 8 are incorporated herein and reference is made thereto. 16. As a direct and proximate result of the negligence of the defendant the plaintiff, Pamela J. Sheaffer, was injured. Her injuries, and/ or aggravation of her pre-existing condition{s), include but are not limited to: a) injury to her nerves and nervous system; b) injury to her spine and supporting structures; c) injury to her knee 17. As a result of her injuries, the plaintiff has incurred medical expenses in the past and may continue to incur the same in the future in amounts that may not be covered by the Pennsylvania Motor Vehicle Financial Responsibility Act. 18. As a result of her injuries, the plaintiff has incurred pain and suffering and may continue to incur the same in the future. 19. As a result of her injuries, the plaintiff has incurred aggravation, inconvenience, disability, and a loss of life's pleasures, and may continue to incur the same in the future. 20. As a result of the injuries the plaintiff sustained on December 6, 2002, the plaintiff may have lost wages and the plaintiff's economic horizons may be limited. Count 3 Bruce E. Minnich v Autumn Rickrode 21. The allegations of paragraphs 9 through 14, are incorporated herein and reference is made thereto. 22. As a direct and proximate result of the injuries suffered by his wife the plaintiff, Bruce E. Minnich, hereby claims a loss of consortium as a result of her injuries, in that, said injuries may have had a detrimental and substantial impact upon the marriage of the parties. Wherefore it is prayed that judgment be entered in favor of the plaintiff and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. Count 4 James R. Sheaffer v Autu.mn Rickrode 23. The allegations of paragraphs 15 through 20, are incorporated herein and reference is made thereto. 24. As a direct and proximate result of the injur'ies suffered by his wife the plaintiff, James R. Sheaffer, hereby claims a loss of consortium as a result of her injuries, in that, said injur'ies may have had a detrimental and substantial impact upon the marriage of the parties. Wherefore it is prayed that judgment be entered in favor .of the plaintiff and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. January 26, 2005 ~~~tted William P. Douglas, ~ Attorney for Plain;~t\ AFFIDAVIT I hereby swear or affirm that the foregoing is true and correct to the best of my knowledge and/or information and belief. This is made subject to the penalties of 18 Pa.C.S.A. ~4904 relating to unsworn falsification to authorities. \/~- William P. Douglas Attom~y for Plaintiffs Date: January 26, 2002 r"--.' ~ '",-:') :Ll""\ '- ?;," :z: f',' ....J ry o -11 .-, -1: ""'"1 h'''::'"~; - m .,"".0 ;')L ;'.,~~() T~?4 ':----10"\ ';~?t '~, o "1] :.< - EILEEN 1. MINNICH and BRUCE E. MINNICH, her Husband, -and- : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2004-5892 PAMELA J. SHEAFFER and JAMES R. SHEAFFER, her Husband, Plaintiffs CIVIL ACTION - LAW JURY TRIAL DEMANDED v. AUTUMN RICKRODE, Defendant, v. PAMELA J. SHEAFFER, Additional Defendant. NOTICE TO DEFEND To: Pamela J. Sheaffer C/o William P.Douglas, Esquire 27 West High Street Carlisle, P A 17013 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 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 NOTICA LE HAN DEMANDADO A USTED EN LA COURTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siquientes, usted tiene viente (20) dias de plazo al partir de Ian fecha de la demanda y la notificacion. U sted debe presentar una apariencia escrita 0 en persona 0 por abogado y archival en la corte en forma escrita sus defensas 0 sus objeciones a law demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacaion y por cualguier queja 0 alivio que es pedido en la peticion de demanda. U sted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TlENE AGOGADO 0 SI NO TIENCE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, V A Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRIT A ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-6200 EILEEN 1. MINNICH and BRUCE E. MINNICH, her Husband, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA -and- No. 2004-5892 PAMELA J. SHEAFFER and JAMES R. SHEAFFER, her Husband, Plaintiffs CIVIL ACTION - LAW JURY TRIAL DEMANDED v. AUTUMN RICKRODE, Defendant, v. PAMELA J. SHEAFFER, Additional Defendant. NOTICE TO PLEAD TO: Eileen 1. Minnich and Bruce E. Minnich, her husband -AND- Pamela J. Sheaffer and James R. Sheaffer, her husband c/o William P. Douglas, Esquire 27 West High Street Carlisle, PA 17013 You are hereby notified to plead to the enclosed Answer With New Matter and New Matter Crosse/aim within twenty (20) days from service hereof or a default ~P(! /0<) ) / NESTICO, DR~,1& ~,~DAB ND, LLP << . .) tiJ; / Richard B. Druby, . sC/Ui Attorney I.D. No. 61904 840 East Chocolate Avenue Hershey, Pennsylvania 17033 Tel: (717) 533-5406 Fax: (717) 533-5717 Attorney for Defendant 'f judgment may be entered against you. By: Dated: EILEEN 1. MINNICH and BRUCE E. MINNICH, her Husband, .and. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2004-5892 PAMELA J. SHEAFFER and JAMES R. SHEAFFER, her Husband, Plaintiffs CIVIL ACTION - LAW JURY TRIAL DEMANDED v. AUTUMN RICKRODE, Defendant, v. PAMELA J. SHEAFFER, Additional Defendant. DEFENDANT'S ANSWER WITH NEW MATTER AND NEW MATTER CROSSCLAIM PURSUANT TO PA.R.C.P. 2252 (d) I. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 2. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 3. Denied as stated as Defendant's current address is 238 Walnut Bottom Road, Carlisle. 4. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 5. Denied as stated. It is admitted that Defendant was operating her vehicle on December 6, 2002, on Dickinson School Road, near the intersection of Old York Road. As to the remaining allegations of Paragraph No.5, they are denied. 6. Conclusion oflaw, to which no response is required. To the extent a response is required, the allegations of Paragraph NO.6 are denied. 7. Conclusion oflaw, to which no response is required. To the extent a response is required, the allegations of Paragraph No.7 are denied. 8. Conclusion of law, to which no response is required. To the extent a response is required, the allegations of Paragraph No.8, including Subparagraphs a) through e) are specifically denied. WHEREFORE, Defendant demands that Plaintiffs' Complaint be dismissed and that judgment be entered in her favor and against Plaintiffs, plus costs of this action. COUNT] 9. The averments of Paragraphs I through 8 above are incorporated herein by reference. 10. Conclusion oflaw, to which no response is required. To the extent a response is required, the allegations of Paragraph No. 10 are denied. I I. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 12. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 13. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 14. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. WHEREFORE, Defendant demands that Plaintiffs' Complaint be dismissed and that judgment be entered in her favor and against Plaintiffs, plus costs of this action. COUNT 2 15. Paragraphs 1 through 14 above are incorporated herein by reference. 16. Conclusion of law, to which no answer is required. To the extent a response is required, the allegations of Paragraph No. 16 are specifically denied. 17. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 18. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 19. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. 20. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments, and they are therefore denied. WHEREFORE, Defendant demands that Plaintiffs' Complaint be dismissed and that judgment be entered in her favor and against Plaintiffs, plus costs of this action. COUNT 3 21. Paragraphs I through 20 above are incorporated herein by reference. 22. Conclusion oflaw, to which no response is required. To the extent a response is required, the allegations of Paragraph No. 22 are specifically denied. WHEREFORE, Defendant demands that Plaintiffs' Complaint be dismissed and that judgment be entered in her favor and against Plaintiffs, plus costs of this action. COUNT 4 23. Paragraphs 1 through 22 above are incorporated herein by reference. 24. Conclusion of law, to which no response is required. To the extent a response is required, the allegations of Paragraph No. 24 are specifically denied. WHEREFORE, Defendant demands that Plaintiffs' Complaint be dismissed and that judgment be entered in her favor and against Plaintiffs, plus costs of this action. NEW MATTER 25. Paragraphs 1-24 above are incorporated herein by reference. 26. Plaintiffs' claims are barred, in whole or in part, by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 27. Plaintiffs' claims may be barred, in whole or in part, by the selection of a limited tort option on applicable policies of insurance. 28. Plaintiffs' may have failed to mitigate their damages. 29. Defenses reserved pursuant to Pa.R.C.P. 1030(b) and all other defenses not required to be pleaded or hereby reserved. 30. Plaintiffs' claims may be barred, in whole or in part, by the applicable statute oflimitations. 31. If Plaintiffs sustained damages as alleged, which is denied and of which strict proof is demanded, the same were caused by conditions for which Defendant is not responsible and/or the damages were not causally related to this accident. 32. If the Plaintiffs sustained damages as alleged, which is denied and of which strict proof is demanded, the same were caused by persons or parties over whom Defendant had no responsibility, authority or control. 33. At all times relevant hereto, Defendant operated her vehicle with reasonable care and with due regard for the safety of persons and property. 34. The Defendant was faced with a sudden emergency, not of her own making and she is, therefore, not liable for the accident in question. 35. The accident in question was unavoidable. WHEREFORE, Defendant demands that Plaintiffs' Complaint be dismissed and that judgment be entered in her favor and against Plaintiffs, plus costs of this action. NEW MATTER CROSSCLAIM PURSUANT TO PA.R.C.P. 2252 (d) DIRECTED TO PLAINTIFF. PAMELA J. SHEAFFER 36. Paragraphs 1 through 35 are incorporated herein by reference. 37. If it is judicially determined that Plaintiffs, Eileen 1. Minnich and Bruce E. Minnich are entitled to recover, then Defendant herein joins Pamela J. Sheaffer as an additional defendant and avers that she is solely liable to Plaintiffs, Eileen 1. Minnich and Bruce E. Minnich, jointly and severally liable to Plaintiffs, Eileen 1. Minnich and Bruce E. Minnich, or liable over to Defendant for indemnity and/or contribution with respect to Plaintiffs, Eileen 1. Minnich and Bruce E. Minnich's claims. 38. The accident in question was proximately caused by the negligence, carelessness and recklessness of Plaintiff, Pamela 1. Sheaffer, in that she: (a) Failed to maintain a proper lookout; (b) Failed to operate her vehicle in a safe and prudent manner; (c) Failed to obey posted speed limits in violation of75 Pa.C.S.A. 9 3362 and other applicable statutes and/or law; (d) Failed to drive at a safe speed in violation of75 Pa.C.S.A. 93361: (e) Failed to drive so as to stop within the assured clear distance ahead; (f) Failed to stop her vehicle before striking the Defendant's vehicle; and (g) Failed to have her vehicle under proper and adequate control. 39. Accordingly, Defendant joins Plaintiff, Pamela J. Sheaffer as an additional defendant with regard to the claims of Plaintiffs, Eileen L. Minnich and Bruce E. Minnich. WHEREFORE, Defendant herein joins Plaintiff, Pamela J. Sheaffer, as an additional defendant and demands that she be held solely liable to Plaintiffs, Eileen L. Minnich and Bruce E. Minnich, jointly and severally liable to Plaintiffs, Eileen 1. Minnich and Bruce E. Minnich, or liable over to Defendant for indemnity and/or contribution with respect to Plaintiffs, Eileen L. Minnich and Bruce E. Minnich's claims. /./; (/i.< Date: Respectfully Subrnirtitd: NESTICO, DIW"RV & fIlLDABRAND, LLP /x ' // u c/ // i tIc" alx, (: 'J Richard B. DruMy, Attorney I.D. # 61~ 840 E. Chocolate A venue Hershey, PA 17033 Tel: 717-533-5406 Fax: 717-533-5717 Attorneys for Defendant By: Y]':RIFICA TIQN 1. Autumn Rickrode, verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. e.s. ~4904 relating to unsworn falsification to authorities. ;jAiJ)AM. d J1ecrKr&tU Autumn Rickrode Date: ;:< - J..J-; -OS:- CERTIFICATE OF SERVICE I, Richard B. Druby, of the law firm ofNestico, Druby & Hildabrand, LLP, J.,yL hereby certifY that on the / day of February, 2005, a copy of the foregoing document was sent via First Class U.S. Mail, postage paid, to the following: William P. Douglas, Esquire 27 West High Street Carlisle, PAl 7013 // v / /'. . c (V, . Richard B. Df1,iby / /' j ,I / .I '70 :3 z- ~ "'1'\ ~\ CP (0 ~ -0 :;;:: (;l -0 = SHERIFF'S RETURN - REGULAR CASE NO: 2004-05892 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MINNICH EILEEN L ET AL VS RICKRODE AUTUMN JODY SMITH , Sheriff or Deputy Sheriff of Cumberland County/Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon RICKRODE AUTUMN the DEFENDANT , at 1120:00 HOURS, on the 9th day of December, 2004 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to AUTUMN RICKRODE a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 .00 .00 10.00 .00 28.00 ~7~(2(./~.._. ~ ...r ....,~.,.:., ~""..~)-,:~~:.~,,:~,!/ I tI..".--,!.,.o_""-''"- - -"- R. Thomas Kline 12/09/2004 WM DOUGLAS LAW OFFICE Sworn and Subscribed to before By: "'ceLL! J rvLG-t~ Deputy Sheriff ~ me this -1..... day of , .. ., / \., ~7 .;l{J'6j A.D. r\ a ~ .--' \..~, I Po~ 1I~ prothonotaryi - . Johnson, Duffie, Stewart & Weidner By: Jefferson J. Shipman, Esquire I.D. No. 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 e-mail: jjs@jdsw.com (717) 761-4550 EILEEN L. MINNICH and BRUCE E. MINNICH, her husband, and PAMELA J. SHEAFFER and JAMES R. SHEAFFER, her husband, Plaintiffs Attorney for Def ndant IN THE COURT OF COM ON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 04-5892 Civil Term CIVIL ACTION - LAW v, AUTUMN RICKRODE, Defendant v. PAMELA J. SHEAFFER, Additional Defendant JURY TRIAL DEMANDED ANSWER OF THE ADDITIONAL DEFENDANT, PAMELA J. SH AFFER, TOCROSSCLAIM OF DEFENDANT AUTUMN RICKRO E AND NOW, comes the Additional Defendant, Pamela J. Sheaffer, b and through her counsel, Johnson, Duffie, Stewart & Weidner, and files the following Answer to the Crossclaim of Defendant, Autumn Rickrode: 36. No response is required. 37. Denied. The averments contained in paragraph 37 are concl sions of law and fact to which no response is required. If a response is deemed to be requir d, the averments contained therein are specifically denied. 38. Denied. The averments contained in paragraph 38, and sub aragraphs (a) through (g), are conclusions of law and fact to which no response is require . If a response is deemed to be required, the averments contained therein are specifically de ied. (a) Denied. To the contrary, Ms. Sheaffer did maintain a proper and careful look-out; (b) Denied. To the contrary, Ms. Sheaffer did operate he vehicle in a safe and prudent manner at all times relevant to this cause of action; (c) Denied. To the contrary, Ms. Sheaffer did obey the p sted speed limit and was in no way in violation of the Pennsylvania Motor Vehicle Co e or any other applicable statutes and/or laws; (d) Denied. To the contrary, Ms. Sheaffer did at all times drive at a safe speed and did not violate any provision of the Pennsylvania Motor V hicle Code: (e) Denied. To the contrary, Ms. Sheaffer did not violate he assured clear distance ahead rule; (f) Denied. To the contrary, Ms. Sheaffer was in no way negligent, careless and/or reckless in allegedly striking the Defendant's vehicle; and (g) Denied. To the contrary, Ms. Sheaffer did have her v hicle under proper and adequate control at all times. 39. Denied. The averments contained in paragraph 39 are concl sions of law and fact to which no response is required. If a response is deemed to be requir d, the averments contained therein are specifically denied. WHEREFORE, the Additional Defendant, Pamela J. Sheaffer, respe ully requests that judgment be entered in her favor and that any and claims being asserted ag inst her be dismissed with prejudice. Respectfully submitted, JOHNSON, DUFFIE, STEWAR & WEIDNER _'1fr<. ~ Jefferson J. Shi man, E quire 1.0. #: 51785 301 Market Street P.O. Box 109 Lemoyne, PA 17043-01 9 e-mail: jjs@jdsw.com Attorneys for Additional efendant DATE: t:j/5/o S- VERIFICATION I, Pamela J. Sheaffer, have read the foregoing Answer to the Crosse aim of Defendant and hereby affirm that it is true and correct to the best of my personal knowl dge, or information and belief. This Verification and statement is made subject to the penalties f 18 Pa. C.S. 94904 relating to unsworn falsification to authorities; I verify that all the state ents made in the foregoing are true and correct and that false statements may subject me to t e penalties of 18 Pa. C.S. 94804. DATE: 245023 'L CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served up n the following counsel of record, by depositing the same in the United States Mail, postag prepaid, in Lemoyne, Pennsylvania, on April 5, 2005: William P. Douglas, Esquire 27 West High Street Carlisle, PA 17013 Attorney for Plaintiffs Richard B. Druby, Esquire Nestico, Druby & Hildabrand, L.L.P. 840 East Chocolate Avenue Hershey, PA 17033 Attorneys for Defendant JOHNSON, DUFFIE, STEWA & WEIDNER ! B~ /l /! . /\..L.U<.- .......'-' 247876 Je erson J. Shipm n, Es uire . . #: 51785 01 Market Street P.O. Box 109 Lemoyne, PA 17043-010 Attorneys for Additional D fendant (; ~) ~::~ ""-.~. ~:~ I 0' 0n ~--:\ -fll r~~ -C~~ '.,.1"--., "()(:} i~:) i-~"~) --", -'i1 {:X ~.~, - en (.:1.) , I{ichard B. Druhy, Esquirc Attorucy LD. No. 61904 NESTICO, ImUHV & HILI)AHRAND, LLI' 840 East Chocolate A venue Hershey, I'A 17033 (717) 533-5406 (717) 533-5717 (facsimile) Attorney for Defendant ............................................................................................ II........................................................ EILEEN L. MINNICH and BRUCE E. MINNICH, hcr II ushand. IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA -and- No. 2004-5892 PAMELA .I. SHEAFFER and JAMES R. SHEAFFER, her hushand C1VIL ACTION - LA W JURY TRIAL DEMANDED Plaintiffs v. AUTUMN RICKRODE, Dcfendants. DEFENDANT'S MOTION TO COMPEL DISCOVERY AND NOW. comes the Defendant hy and through her attorncys. Nestico, Druhy & llildahrand, LLP, and moves this Honorable Court pursuant to Pa. R.C.p. 4019, to enter an ordcr compelling the Plaintiffs to answer Intcrrogatories and rcspond to the Requcst for Production of Documcnts for the rcasons stated bclow: I. Plaintilfs have commcnced this action allcging that Plaintilfs. Eilecn L. Minnich and Paula J. Sheaffer, sustained bodily injury and damagcs as a result of a motor vehicle accident, which occurred on December 6, 2002. 2. Plaintiffs havc also allcgcd that PlaintifTs, Bruce E. Minnich and Jamcs R. ShcafTcr. sulTcd lrom loss of consortium as a result of bodily injury allcgcdly sustaincd by thcir rcspcctive wivcs in thc motor vchiclc accidcnt. which occurrcd on Dcccmbcr 6, 2002. 3. On Fcbruary 24, 2005. Defcndant scrvcd upon Plaintill's Minnichs. Intcrrogatorics and Rcquest for Production. The Interrogatorics are limitcd in numbcr inquiring into rccognized arcas of discovcry and the Request for Production, likewisc, callcd for the production of documents or othcr itcms which may lead to the discovcry of admissible evidence. Copies of the Interrogatories and Rcquest for Production are attached hcrcto as Exhibit '"A" and '"13" respectively. 4. On Fcbruary 24, 2005, Defendant servcd upon Plaintill's ShcaiTcrs, Interrogatories and Request for Production. The Interrogatories are Iimitcd in number inquiring into recognized arcas of discovcry and the Request for Production, likewise, call cd for the production of documcnts or other items which may lead to the discovcry of admissible evidence. Copies of the Interrogatories and Request for Production are attached hereto as Exhibit '"C" and '"0" respectively. 5. On April 12. 2005, not having received any rcsponses to the discovcry. undersigncd counsel forwarded a letter to Plaintilfs' counsel indicating that the discovcry responses were overdue. and allowing an additional sevcn (7) days for the Plaintifl's to respond to the discovery. See undersigned counsel's Iettcr of April 12, 2005, attached hereto as Exhibit "E". 6. To date. Plaintill's havc ncither answercd thc Intcrrogatories, produccd the documents, or other items, nor liled any objection within the time allowcd by law. 7. DelCndant cannot properly prepare the def'ense of this action without the information requested of Plainti fTs. 8. Because of Plaintiffs' failure to provide the information, documents and other things requested, it is appropriate for an order to he issued requiring Plaintiffs to comply fully with the discovery rcqucsts, or suiTcr sanctions. including dismissal, for failure to comply, all pursuant to Pa. R.C.p. 4019 and othcr applicahle law. WHEREfORE, Defcndant respcctfully rcqucsts this Honorahle Court entcr an Order requiring PlaintiiTs Minnichs and PlaintifTs SheaiTers to provide full and complete answcrs to Defendant's Interrogatories and to produce fully the documcnts requested in Defendant's Rcquest for Production within ten (10) days of this Ilonorahle Court's ordcr, with sanctions to he placed upon PlaintiiTs. upon furthcr application of the Defendant, if the PlaintiiTs fail to comply with such ordcr. Respectfully Suhmitted. By: HILDABRAND, LLP Dated: if'~~ Richard B. Druby . Attorney J.D. No.6 4 NESTICO, DRUBY & IflLDABRAND. LLP 840 East Chocolate Avenue Hcrshey, P A 17033 (717) 533-5406 (717) 533-5717 (facsimile) Attorney for Defendant Rickrode CERTIFICATE OF SERVICE l, Christiana E. Appleby, of the law linn of Nestico, Druby & Ilildabrand, LLP, hcrcby ccrtify that on the day of April, 2005, a copy of the fiJrcgoing doculllcnts was scnt via First Class U.S. Mail. postage paid, to the following: William P. I)ouglas, F:squire 27 West High Street Carlisle, PA 17013 .Iefferson J. Shipman JOHNSON, DllFFIE, STEW ART & WEIDNER, I'.c. 301 Market Street 1'.0. Box 109 Lemoyne,l'A 17043-0109 Christiana E. Appleby EILEEN L. MINNICH and BRUCE E. MINNICH. her Husband, -and- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2004-5892 PAMELA J. SHEAFFER and JAMES R. SHEAFFER, her husband : CIVIL ACTION - LA W : JURY TRIAL DEMANDED PlaintilTs v. AUTUMN RICKRODE, Defendant INTERROGATORIES OF DEFENDANT ADDRESSED TO PLAINTIFFS MINNICH - SET I TO: Eileen L. Minnich and Bruce E. Minnich, her husband C/O William P. Douglas, Esquire 27 West High Street Carlisle, PA 17013 We are enclosing herewith Interrogatories propounded by Defendant to be answered by Plaintiffs within thirty (30) days from the date of service hereof. with a request that a copy of the answers to served upon counsel for Defendant. These shall be deemed to be continuing Interrogatories. It: between the time of your answers and the time of trial of this case, you or anyone acting on your behalf, learns of any further information not contained in your answers. you shall promptly furnish such information to the undersigned by supplemental answers. By: Date: :; !2<!(v5 ichard B. Druby. Es lire Attorney J.D. No. 619 840 East Chocolate Avenue Hershey, Pennsylvania 17033 Tel: (717) 533.5406 Fax: (717) 533-5717 Attorney for Delendant I>EFINITIONS A. The term "person:' as used herein. means any natural person. partnership. corpol'ation. or other busincss entity and all prcsent and former omccrs. directors. agents. employees. attol'l1eys. and other acting or purporting to act on behalf of such natural person. partnership, corporation, or other business entity, B. The term "document." as used herein. mean the original and all copies of any written, printed, typed. or other graphic matter of any kind or natl1l'e and any other tangible thing in your custody or control, including but not limited to: I, All contracts, agreements, letter agreements. representations. warranties, certiticates, and opinions; 2. All letters or other forms of correspondence or communication. including envelopes and notes, telegrams. cables. telex messages, telex and messages. including reports. notes, notes, notations. and memoranda of or relating to telephone conversations or conferences; 3, All memoranda. reports. test results, financial statemcnts or reports. notes. scripts. transcripts. tabulations. studies. analyses. evaluations. projections, work papers, corporate records or copies thereof. expressions or statements of pol icy, lists. questionnaiJ'es, surveys, charts. gi'aphs, summaries, extracts. statistical statements or records, compilations and opinions or reports of consultants; 4, All desk calendars. appointment books. and diaries; S, All minutes. records, or transcripts of meetings and conferences and lists of persons attending meetings or conferences; 6, All reports and summaries of interviews or negotiations; 7. All books. articles. press releases, magazines. newspapers, booklets, brochures. pamphlets. circulars. bulletins. notices. instructions. and manuals: 8. All motion pictures and photographs (whether developed or undeveloped). tape recordings. microtilms. phonographs. tapes or other records. punch cards, magnetic tapes. discs. data cells. dl'llll1S. print-outs, and other data compilations ti'om which information can be obtained: and 9. Drafts of any documents. revisions of any draft documents, and original or preliminary notes. C. The term "communication," as used herein, means all statements, admissions, denials. inquiries. discussions. conversations. negotiations. agreements, contracts, understandings. meetings, telephone conversations. letter, correspondence, notes, telegrams, telexes, advertisements. or any othel' form of written or verbal intercourse. D. The term "identify," when used with respect to a document, means to state the date, author, addressee, type of document. (e.g., "letter"); to identify its last known custodian and location: and to state the exhibit number of the document if it has been marked during the course of a court proceeding. E. The term "identity." When used with respect to an individual, means to give the person's full name. all known aliases. present or last known business and home addresses and telephone numbers, and present position or business affiliation. F. The term "identity," when used with respect to any other "person:' means to gi ve the person' s official. legal, and formal name or the name under which the person acts or conducts business. the address and telephone number of the person's place of business. professional. commerce. or hOl11e, and the idcntity of the person's principal or chief executive officer or pcrson who occupics the positionl11ost closcly analogous to a chief executive. G, The term "relate(s) to:' as used herein, l11eans constitute(s). rcter(s) to. retlect(s). concern(s). pertain(s) to. or in any way logically or factually conncct(s) with the matter described in the interrogatory, H. The tcrl11 "accident:' as used herein, means the occurrence that forms the basis ofa cause of action or claim for reliefset forth in the complaint or similar pleading. INTERROGATORIES 1. State your age, giving date and place of birth. and state your Social Secul'ity number, and tlillname. ANSWER: 2. DlIring the Jive-year period preccding the accident. were YOll treated for any illness. ailment or condition? If so. give the names and addresses of hospitals. if any. in which YOll were conlide or treated, the names and addresses of attending physicians. the conditions for which YOll were treated. and the date of the same. the length of time sllch condition existed und whcther these conditions existed at the time of the accidcnt. ANSWER: 3. Have you at any time during your lifetime been admitted as a patient in a hospital for any illness. accident. ailment or condition of any nature'? ANSWER: 4. If so. fOI' each sLlch hospitalization. state: (a) The name and address of the hospital: (b) The inclllsive dates of hospitalization: (c) A description of the condition. illness, accident or ailment for which YOLl were hospitalized: (d) A description of the treatment received at the hospital. ANSWER: 5. Did you have any sllrgical opcrations pcrformcd lIpon YOllrself during YOllr lifetime prior to the accident? Ifso. state specifically where and whcnthe same took place. the nature thereot: the names and addresses of the physicians performing the same. whether said conditions were wholly cured. or whethcr listing or permancnt conditions remained atthc time of the aceidcnt. and thc natllrc of any such lasting or permanent condition. ANSWER: 6. Ifyoll have becn hospitalizcd as a rcslIlt ofyollr injurics rcceived in the accident referred to in YOllr Complaint. for each period of hospitalization. state: (a) The name and address of the hospital: (b) The inclllsive dates of hospitalization (c) A description of the injllries for which YOll were hospitalized: (d) A description of the treatment received at the hospital: (e) An itemization of each charge for sllch hospitalization (t) The amount paid and by whom; (g) Whether fllture hospitalizations will be necessary, and if so, the estimate cost. ANSWER: 7. For each doctor or any other medical personnel who examined 01' treated you for injuries received in the accident to in your Complaint. state: (a) His nUl11e. address und speciulty: (b) Each dute of examination and treutment: (c) The type of examination and treatment: (d) An itemization of each charge for such examination and treatment: (e) The amount paid and by whom: (1) Whether future treatments and examination will be necessary, and ifso, the estimated cost. ANSWER: 8. Were YOll ever involved in an accident Pl'evious or subsequcnt to thc accidcnt complaincd of in this action'? (fso. state whcre and when the accidcnt look place: the nature and extcnd of your injuries and conditions I'esulting from such accident: whether or not the nature of these injlll'ies or conditions were tcmporary or pcrmancnt: the names and addresscs of the doctors who attended you and the hospilals where you were con tined or treated. with the date of !i'eatlllent and conl1nelllent, ANSWER: 9. If you have ever tiled an action against any person for damages for pcrson injuries. other than in this action. for each stich action. state: (a) The date, place, name ofcollrt and number and term of the action: (b) The name ofthc pcrson YOll sued: (c) The name. address and telephone number of the attol'l1ey I'eprescnting the person you sued; (d) The name, address and telephone number of the attol'l1ey representing you in the action: (e) A description of the accident in which YOll suffered injllries, inclllding time. date and place: (I) A description of the injuries for which YOll claimed damages: (g) The disposition 01' termination of the action: (h) Whether you received any amount by judgment or settlement. and if so, the amount received and from whom. ANSWER: 10. What was your occupation or bllsincss during the live-ycar pcriod prcccding this accidcnt. the nature of your dutics, thc Icngth oflil11c cngagcd in cach. and thc namcs and addrcsscs of cach cmploycr or busincss and thc addrcss whcre you actually worked in each instance. ANSWER: 11. What were your gross and net eal'l1ings for the live-year pcriod preccding this accident on a wcckly or monthly hasis? ANSWER: 12. Do you have in your posscssion copies of the fedcral income tax rcturns tiling on your behalf fllr each of the tive years preceding this tlccident? Is so. atttlch a copy of etlch return to your answers. ANSWER: 13. Give in detail any and all expenses and losses which you claim resulted fi'Olll the accidellt which forms the basis of this suit, stating the nature of the same. the bills incurred and the addresses of the parties to WhOlll any monies may be owing orwel'e paid, ANSWER: 14. 1.lave YOll or has anyone action in YOllr hehalf obtained !i'om any person or persons any rcport. statcmcnt. mcmorandllm or testimony concerning the aecidcnt involvcd in this callsc of action? Ifso: (a) What is the name and last known address and present whcrctlhollts. if knowll, of cach sllch person? (b) When, where and by whom was etlch slIch report. sttltement. memorandllm or testimony obtained or made? (cl Where is each located? ANSWER: 15. If you are in possession of any photographs of the locale or surrounding area oftbe site of the accidcnt. or any otbcrl11alters or things involved intbis accident. slllte: (a) The daters) when such photographs were taken: (b) The names and addresses oftbe party taking them: (c) The object(s) or subject(s) or the particular site or view each photograph represents; (d) Where lhey were taken; and (e) The present whereabouts of the photographs and the name and addresses of whomsoever is in possession or custody thereof. ANSWER: 16. State whether any plans. drawings. sketches or diagrams exist 01' were made of the site oflhe alleged accident, and ifso. state: (a) The identity of each of said plan. drawing. sketch and diagl'am: (b) The date when each of the same was made; (c) The name and address of the person making the same; (d) The name and address of the person having clIstody of the same, ANSWER: 17. Are YOll prescntly employcd or have you bcen employcd since the accident referred to ill YOllr Complaint? Ifso. state the name and address of your employer or employers. the Icngth of time you have wOI'kcd for each cmployer or employers. including the dates covering sllch employmcnt: your wages or salary ill connection with sllch employment. and set forth in detail how YOllr prescnt physical condition adversely all'ects YOllr ahility to carryon such employmcnt. if in fact it docs. ANSWER: 18, State specitically each and every arca of YOUI' body that was physically injured in the accidcnt referred to in your Complaint. induding a complete description of cach such injury, (a) Set forth specilically which of the above injuries 01' conditions are permanent, if any: (b) Set forth the scope. the extent of medical treatment you have rcccived in connection with each such injury or condition from the time of the accident to the prescnt date, and specify which injuries are still being treated and in what manner. ANSWER: 19. If you still suner pain ti'om any of your injuries and conditions reslilting fromlhe accidcnt refcrred to in your Complaint. state spccif1cally thc frequcncy and nature of the pain and the injuries from which it emanates. ANSWER: 20. What is the nmne and last known address and present whereaboLlts, if known. of each person whom YOLl or anyone acting in your behalfknows or believes to have witnessed said accident'? ANSWER: 21. State the name. present address, and plaee ofcmploymcnt of each person whom YOll intend or expect to call as a witness at the trial of this case. ANSWER: 22. Identify each person whom you expect to call as an expcrt witncss at the trial of this case. As to each witness state: (a) The subject matter on which he is expected to testify. (b) The facts and opinions to which he is expected to testify. (e) A summary of the grounds tor each opinion. (d) Whether the tucts and opinions listed in (b) above are contained in a written repol1. memorandum. or other transcript and if they are. give the name and address of the present custodian of same and state whether YOll will produce the same without the necessity of a motion, (e) If the opinion of any expert listed above is based in whole or in part on any scientitic rule or principle; set torth the said rule or principle. (I) If the opinion of any expert listed above is based in whole or in part on any code. regulation or standard, governmental or otherwise. identity the said code. regulation or standard and speeitically set torth the section relied upon. (g) If the opinion of an)' expert listed above is based in whole or in part UpOl1 any scientitic or engineering textbook or other publication. identity said text or publication. ANSWER: 23. With rcspcct to coch pcrson you expcct to coli as an cxpcJ1 witncss or the trill! of this case. stote: (0) His oge, residence and business oddress. (b) The nome and oddt.css of his prcscnt employer or ifsclt~el11ploycd. the name of the business and his occupation. (c) His educational bockground spccitying colleges attended dates of attcndance. degrccs attaincd, and a detailcd list of all writings prcpared by the expert or in which the expel1 participated in any way whatsoevcr. (d) Spccil1c identitication of all courses attended, seminar attend cd. and othcr activities on thc part of the expert within the past tcn years which were concerned with the subject lor which the expert was retained in this case. (e) The namc and address tor the persons or I1I'111S for whom the individual worked for the last ten years and a detailed description of all duties at eoch placc ofcl11pJoymcnt. Iflhe cxpert was self.employed. state speciticolly and in dctail the description of his duties and responsibilitics. ANSWER: 24. Do you intend to LIse any book. magazine or other writing at the trial of this case? If so. describe the writing in detail as to author. publisher. copyright date, and give the name and address of any known present cLlstodian of said writing. ANSWER: 25. I'l~as~ stat~. in d~tail and without r~f~r~nc~ to your Complaint, how this accid~nt happ~ned. ANSWER: R~sp~ctfully subl1litt~d. HILDABRAND. LLP By: Dat~: ~ I:; (~ 0- v " ichard B. Druby. Es i Attorney J.D. No. 61 840 East Chocolat~ A v~nlle H~rshey, P~nnsylvania 17033 Tel: (717) 533-5406 Fax: (717) 533-5717 Attorney for Def~ndant CERTIFICATE OF SERVICE I. Richard B. Druby. of the law finn of Nestico, Druby & I'lildabrand, LLP. hereby certify that onthed V~ay of February. :2005. a copy of the foregoing doculllent was sent via First Class U.S. Mail. postage paid. to the following: WiIIillm P. Dougllls, Esquire 27 West High Street ClIrlisle, PA 17013 EILEEN L. MINNICH and BRUCE E. MINNICH. her Husband. -and- : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA No. 2004-5892 PAMELA J. SHEAFFER and JAMES R. SHEAFFER. her husband : CIVIL ACTION. LAW : JURY TRIAL DEMANDED Plaintitl's v. AUTUMN RICK RODE, Defendant DEFENDANT'S REQllEST FOR PRODUCTION OF DOClIMF:NTS - SF:T I DIRECTED TO PLAINTIFFS EILF:EN L. MINNICH llnd BIWCE E. MINNICH Pursuant to Pa. Rule of Civil Procedure 4009, you are hereby requested to produce for inspection and copying at the offices of Defendant's counsel. Nestico. Druby & I-lildabrand. LLP. 840 East Chocolate Avenue. Hershey. Pennsylvania. 17033. or at such other location as may be mutllally agreed upon by counsel not later than thirty (30) days aileI' service of these Requests. the following documents. In lieu of the formal schedule production. copies of all requested documents, properly identified by request. may be forwarded to Detimdant's counsel the above address within thirty (30) days aileI' service of these Requests. These Requests are deemed to be continuing Requests. and any documentation or information requested herein which is discovered. obtained or available subsequent to your first response hereto shall be fUl'llished immediately to Defendant's counsel. DEFINITIONS The word "document" 01' "documents" as used in the within Request includes, without limitation or exception. the original and copies of the following items: (Whethcr printed 01' recorded or reproduced by another other mechanical process, or writlen or produced by hand). Agreements, communications, correspondence, telegrams, memoranda. summaries or records of personal conversations or interviews. diaries, reports, graphs, notebooks. note charts. plans, drawings, sketches, maps, summaries or records of meetings or conferences, summaries or reports of investigations or negotiations, opinions or reports of consultants, drafts, letters, any marginal comments appearing on any document, and writings of every kind. This definition shall also be deemed to include any machine-produced document. whether from a computer or not, notes and records of any oral communication and recordings (tape, disk, or other) of oral communications. The word "communication" as used in the within Request shallmetlll any transmission of information by oral. written, pictorial. 01' otherwise perceptible means. including but not limited to. telephone convel'sations. letters, telegrams, and persona conversations. The word "person" as used in the within Request shalll11ean any individual, corporation. partnership, unincorporated association or business entity, DOCUMENTST08EPRODUCED 1. All statements. signed statements. transcripts of recorded statements, or interviews of any person or witness relating to, ref'<:rring to. 01' describing any of the events 01' c1uims described in the Complaint filed in this case. 2. All doclIments prepared by any insurer or representative of Plaintiffs. except Plaintins' llttorneys. during an investigation of the accident 01' any of the events 01' claims described in the Complaint. Such documents shall include any documents made or prepared up to the present time. with the exclusion of mental impressions. conclusions 01' the opinions respecting the value or merit of a claim or defense or respecting strategy or tactics. 3. All photographs of the sccne of the accidcnt or any of the vehicles involved in the accident. 4. All federal. state. and local income tax returns tiled by Plaintiffs during the live years preceding the accidcnt in question. 5. All reports of any experts. 6. Allmedical,'eports. medical and hospital bills, wage loss information and other expenses you are claiming resulting from the accident in question. 7. All reports of any physicians. mental health professionals or vocational specialists pertaining. to Plaintiffs. Date: 8. All dccluJ'(tlion sheets of the Plaintitrs insurance in et1cct at the time of the accident. indicating coverages and whcther Plaintiffs curried the full tort option or limited tort option. J?tf~J j Respectfully submitted. NESTleo. DR~ HILDABRAND, LLP By: Richard B. r y, squi Attorney 1.0. .61904 840 East Chocolate A venue Hershey. Pennsylvania 17033 Tel: (717) 533.5406 Fax: (717) 533-5717 Attomey for Defendant CERTIFICATE OF SERVICF: I. Richal'd B. Druby. of the law firm of Nestico, Druby & Hildabrand, LLP. hereby certity that on the .P-f~y of Febl'llary. :2005, a copy of the foregoing document was sent via First Class U.S. Mail, postage paid. to the following: William P. Douglas, Esquire 27 West High Street Carlisle, PA 17013 - EILEEN L. MINNICH and BRUCE E. MINNICH. her Husband. -and- : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA No. 2004-5892 PAMELA.I. SHEAFFER and .lAMES R. SHEAFFER. her husband : CIVIL ACTION. LA W : .IUR Y TRIAL DEMANDED PlaintitTs v. AUTUMN RICKRODE. Dcfendant INTERROGATORIES OF DEFENDANT ADDRESSED TO PLAINTI FFS SHEAFFER - SET J TO: Pamela J. Sheaffer and James R. Sheaffer, her husband C/O William P. Douglas, Esquire 27 West High Street Carlisle, PA 17013 We are enclosing herewith Interrogatories propounded by Defendant to be answered by PlaintitTs within thirty (30) days li'om the date of service hereol: with a request that a copy of the answers to served upon counsel for Defendant. These shall be deemed to be continuing Interrogatories. If, between the time of your answers and the time of trial of this case. you or anyone acting on your behalf. learns of any further information not contained in your answers, you shall promptly furnish such information to the undersigned by supplemental answers. Richard B. Drub. uire Attorney I.D. No. 61904 840 East Chocolate Avenue Hershey. Pennsylvania 17033 Tel: (717) 533-5406 Fax: (717) 533-5717 Attorney for Defendant Date: ~/~~(Jr DEFINITIONS A. The term "'person:' as used herein, means any natural person, partnership, corporation. or other busincss cntity and all prcscnt and formcr officcrs. directOl's. agents. employees. attol'l1eys. and other acting or purpol.ting to act on bchalfof such natural person. partnership, corporation. or other business entity. B. The term "'document,"' as used herein. mean the original and all copies of any written, printed. typed. or other graphic matter of any kind or nature and any other tangible thing in your custody or control, including but not limited to: 1. All contracts, agreements, letter agreements, representations, warranties. certificates, and opinions; 2. All letters or other forms of correspondence or communication. including envelopes and notes, telegrums, cables. telex messages. telex and messages. including reports, notes. noles. notations, and memoranda of or relating to telephone conversations or conferences: 3. Allmemorandu. reports. test results. tinuncial statements or reports, notes, scripts. transcl'ipts, tabulutions, studics. unalyses. evaluations, projections, work papers, corporute records or copies thereof: expressions or stUlements of policy. lists, questionnaires. surveys, chm.ts. graphs, summaries. extracts. statistical statements or records. compilations and opinions or reports of consultants: 4. All desk calendars. appointment books. and diaries: 5. Allminules. records. or transcripts of meetings and conferences and lists of persons attending meetings or conlerences; 6. All reports and summaries of interviews or negotiations: 7. All books. articles. press releases. magazines. newspapers, hooklets. hrochures. pamphlets. circulars. hulletins. notices. instructiOlls, and manuals; 8. All motion pictures and photographs (whether developed or undeveloped), tape recordings. microtilms. phonographs. tapes or other records, punch cards, magnetic tapes. discs. data cells. drums, print-outs. and other dolo compilations from which information can he ohtained: and 9. Drat!s of any documents. revisions of any drat! documents, and original or preliminary notes. C. The term "communication," as used herein. means all statements, admissions. denials. inquiries. discussions. convel'sations. negotiations. agreements. contracts, understandings, meetings. telephone conversations, letter, correspondence, notes, telegrams. telexes. advertisements. or any other form of written 01' verbal intercourse. D. The term "identity," when used with respect to a document. means to state the date. author. addressee. type of document. (e.g.. "letter"); to identity its last known custodian and location; and to state the exhihit number of the document if it has heenmarked during the course of a court proceeding. E. The term "identity:' When used with respect to an individual. means to give the person's full name. all known aliases. present or last known husiness and home uddresses and telephone numhers, and present position or husiness at1iliation. F. The term "identily:' when used with respect to any other "person:' means to give the person's ot11cial, legal. and formal name or the name under which the person acts or conducts husiness, the address and telephone numher of the person's place of business. professional. commerce. or home. and the identity of the person's principal or chief executive oflicer or person who ()ccupies the positionmosl closely analogous to a chicI' executive. G, The term "relate(s) to,'" as used hel'ein. means conslitule(s). rcfer(s) 10. retlect(s). concern(s). pertain(s) to. or in any way logically or factually connect(s) with the matter descrihed in the interrogatory, H. The term "accident." as used herein, means the occtlrrence that forms the basis of a cause of action or claim for relief set forth in the complaint or similar pleading. INTERROGATORIES 1, State your age, giving date and place of birth, and state your Social Security numher. and full name. ANSWER: 2. During the live-year period preceding the accidcnt. were youlreated for any illness. ailment or condition? If so. give the names and addresses of hospilals. ifany. in which you were conlide or treated. the names and addresses of (lttending physicians. the conditions for which you were lreated, and the date of the somc. the length of time sllch condition existed and whethcr these conditions exisled al the time oflhe accident, ANSWER: 3. I-lave you at any time during YOlll' lifetime been admitted as a palient ill a hospital for any illness. accident. ailment 01' condition of any nature'? ANSWER: 4. If so. I'lli' each such hospitalization. state: (a) The name and address of the hospital: (b) The inclusive dotcs of hospitalization: (c) A description of the condition. illness, accidcnl or oilment for which you were hospitalized: (d) A description of the treatment received at the hospilal. ANSWER: 5, Did you have any surgical operations performed upon yourself during your litelime prior to the accident'? 11'50. state spcciticallywhere and when the same look place. the nature theretll: the names and addresses of the physicians perl()I'ming the same, whether said conditiolls were wholly clll'cd. or whether listing or permanent conditions remoincd at the time of the accident. and the nuture of uny such lasting or permanent condition. ANSWER: 6. If you have becn hospitolizcd as 0 rcsult of your i1\iuries receivcd in the accidcnt referrcd to in your Complaint. jll\' each reriod of hospitalization. stalc: (a) The name and address of the hospilal: (b) The inclusive dales of hospitalization (c) A description of the injuries for which you were hospitalizcd; (d) A description of the treotment rcceived at the hospital: (e) An itemization of each charge for such hospitalization (I) The amount paid and by whom: (g) Whether future hospitalizations will he necessary. and if so. the estimate cost. ANSWER: 7. For each doctor or any othcr mcdical personnel who examined or treated you Il)r injuries received in Ihe occident to in your Complnint. state: (a) His name. addrcss and spccialty: (b) Each dute of examination and treatmcnt: (c) The type ofexllll1ination and treatment: (d) An itcmization of each charge for such examination and treatment: (e) The amount paid and by whom: (I) Whether future treatments and examination will be necessary. and ifso. the estimated cost. ANSWER: 8, Were you evcr involved in an accident previous or subsequent to the accident complained of in this action? I f so. state wherc and when the accident took place: the nature and extend OfYOlll' injurics and conditions rcslIlting from such accidcnt: whethel' 01' not the nature of these injuries 01' conditions were temporary or permancnt: the names and addresses of the doctors who attended you and the hospitals where you were con tined or treated. with the dote of trelllmcnt and confinement. ANSWER: , . 9. If you have ever filed an action against any person for damages jl)r person injuries, other lhan in this action. for' each such oction. state: (a) The date. placc. name of court and number and term oflhe action: (b) The name of the person you sued: (e) The name. oddress and telephone numbcr of the attol'l1ey represcnting the pcrson you sued: (d) The nomc. address and telephone numbcr of the attol'l1ey representing you in the action: (e) A description of the accidcnt in which you sufTered injuries. including time. date and place: (f) A descriptioll of the il1iuries tor which you claimed damages: (g) The disposition or termination of the aClion; (h) Whether you received al'Y amount by judgment or settlement. and if so. the amount received and from whom. ANSWER: 10. What was your occupation 01' busincss dul'ing the five-year period prcceding lhis accident. the nature ofyollr duties. thc Icngth oftimc engaged in each. and the namcs and addrcsses of each employer 01' busincss and thc addt'ess whel'e you actually worked in each instance. ANSWER: ...,.... 11. What were your gross and net earnings for the tive-ycur pcriod preceding this accidcnt on a weckly 01' monthly basis? ANSWER: . . 12. Do YOll have in YOUI' possession copies of the fcderal income lax returns liling on YOllr behalf for each of the live ycars preceding this aecident? Is so, attach a copy of each return to your answers. ANSWER: . . 13. Give in detail any and all expenses and losses which you claim resulted from the accident which lorms the basis oflhis suit. slating the mltllJ'e ofthc samc. the bills inclII'J'ed and the addresses of the parties to whom any monies may be owing or were paid. ANSWER: 14. Have you or has anyone action in your behulf obtained Ii'om any pcrson 01' pcrsons any rcport, slatcment. mcmorandum or tcstimony conccming thc llccidcnt involved in this causc of actkm'? If so: (a) What is the nome and last known address and prescnt whercabouts. if known, of each such person? (b) When. whcre ond by whom was each such report. statement. memorandum or testimony obtained or made'? (c) Where is each locotcd? ANSWER: . . 15. If you are in possession of any photogmphs of the locale or surrounding area of thc site of the accident. or allY othcr J1)i1ltcrs or things involved in this accidcnt. state: (a) The date(s) when stich photographs were wkcn; (b) The nallles and addresses of the party taking lhcm; (c) The object(s) or subject(s) or the particular site or view each photograph represents; (d) Where they wcre taken; and (e) The present whereabouts of the photographs and the name and addresses of whol11soever is in possession or custody thereof, ANSWER: . , . 16. State whcther any plans. dmwings. skctches or diagrams exist 01' were made oflhe sile of the alleged accident. and ifso. state: (a) The identity of each of said plan. drawing. sketch and diagram: (b) The date when each of the same was made: (c) The name and address ofthc person making the same: (d) The name and address of the person having custody of the same. ANSWER: , . 17. Are YOll prescntly employcd 01' have you been employed since the accident I'elcrred to in YOllr Complaint'? If so. sl:HC the name and address of your employer or employers. the length oftimc you have worked fllr each employer or employers. including the dates covering such employment: your wages or salary in connection with such employment. and set forth in dctail how YOLlr prcsent physicul condition advcrsely affects your ahility to carryon such cmployment, ifin fact it docs, ANSWER: . , . 18. State specitically each and every area ot'your body thut was physically injured in (he accident rcferred to in your Complaint. including a complete dcscription of each such injury. (a) Set forth specifically which of the above injurics 01' conditions mc permallent. if any: (b) Set forlh lhe scope. the extent of medical treutment you have received in connection with euch such injury or condition fl'Om the time of the accidellt to the present date. and specily which injuries are still being treated and in what manner. ANSWER: - . . 19, If you still sun"':r pain li'om any ofyolll' injuries and ellllditions resulting ti'ol11 the accident rel"<:rrcd to in your COl11plnint. swte specifically the Ii'cquency and naturc of the pain and the injuries Ii'om which it emanatcs. ANSWER: , . 20. What is the name and last known address and present whel'cabouts. if known. of each person whom you 01' anyone acting in YOllr bchalf knows or believcs to have witnessed said accident'? ANSWER: . . 21. State the name, prcsent address, and place of cmployment of cach person whom you intend or expect 10 cull as a witness at the trial ot'this casc. ANSWER: . . 22. Id.::ntify each pcrson whom you expect to call as un expert witness at the trial of this case. As to each witncss state: (a) The subjectl11altcr on which hc is expected to testify. (b) The facts and opinions to which he is expcctcd to testily. (c) A suml11ary of the grounds for each opinion. (d) Whether the facts and opinions listed in (b) above are contained in a writtcn report. memorandum. or other transcl'ipt and if they are. give the name and address of the present custodian of same and state whether you will produce the same withoLlt the necessity of a motion, (e) If the opinion of any expert listed above is based in whole or in pm1 on any scientitic nile or pl'inciple; set forth the said rule or principle. (I) If the opinion of any expert listed above is based in whole or in pm1 on any code. regulation or standard. govel'l1mental or otherwise. identify the said code. regulation or standard and specifically set fl)rlh the section relied upon, (g) If the opinion of any expert listed above is based in whole or in part upon any scientific or engineering textbook or other publication. identify said text or publication. ANSWER: . . 23. With respect to each person you cxpcctto call as an exper.t witness at thc trial of this case. slatc: (al His age. residcnce and business address. (b) The name and address of his presellt employer or if selI:employed. the name of the business and his occupation, (c) His educational background specifying collcges attended dates of attendance. degrees attained. ond a detailcd list of all writings prepal'ed by the expert or in which the expcrt participated in any way whatsoever, (d) Specific identitication of all cOllrses attended. scminar attended, and othcr activities on the part of the expert within the past ten yem's which were concerned with the subject for which the expert was rctained in this case. (e) The name and address for the persons or tirms for whom the individual worked for the last ten years and a dctailed description of all duties at each place ofemploYl11enl. If the expcrt was sclt:employed, state spccifically and in detail the description of his duties and responsibilities. ANSWER: . . 24. Do you intcnd to use any book. magazine or other writing at the trial of this case? Ifso. describe thc writing in dctail as to author. publishcr. copyright date, and givc the name and addrcss of any known present custodian of said writing. ANSWER: . . 25. PI case state. in dCln;1 and without refcrcnce to your Complaint. how this accident happened, ANSWER: Respectfully submitted. NESTICO. DRUBY~ILDABRAND. LLP By: Date: ;2tl~j- { ichard B. Druby. Attorney I.D. No. 04 840 East Chocolate A venue Hershey. Pennsylvania 17033 Tel: (717) 533-5406 Fax: (717) 533-5717 Attorney for Defendant , .. . CERTIFICATE OF SEIWICE 1. Richard B. Druby. oflhe low firlll ofNestico, Druby & Hildubrand. LLP. hercby certify thut on the 07~ of February, 2005. a copy of the toregoing document was sent via First Class U.S. Mail, postage paid. to the following: William P. Douglas, Esquire 27 West High Street Carlisle, PA 17013 O! ._ . EILEEN L. MINNICH and BRUCE E, MINNICH, her Husband. -and- : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA No. 2004-5892 PAMELA.J. SHEAFFER and .JAMES R. SHEAFFER. her husband : CIVIL ACTION - LAW : .JURY TRIAL DEMANDED Plaintiffs v. AUTUMN RICKRODE. Defendant DEFENDANT'S REQtlEST FOR PRODUCTION OF DOClIMENTS- SET I DIRECTED TO PLAINTIFFS PAMELA .J. SHEAFFER and ,JAMES R. SHEAFFER Pursuant to Pa. Rule of Civil Procedure 4009. you arc hereby requested to produce for inspection and copying at the oflices of Defendant's counsel, Nestico. Druby & Hildabrand, LLP, 840 East Chocolate Avenue. Hershey. Pennsylvania. 17033, or at such other location as may be mutually agreed upon by counsel not later than thirty (30) days aftcrservicc of these Requests, the following documents. In lieu of the formal schedule production. copies of all requested documents. properly identified by request. may be forwarded to Defendant's counsel the above address within thirty (30) days after service of these Requests. These Requests are deemed to be continuing Requests. and any documentation or inlormation rcquested herein which is discovered. obtained or available subsequent to your tirsl response hereto shall be furnished immediately to Defendant's counsel. DEFINITIONS , "" . The word "document" or "documents" as uscd in the within Requcst includes. without limitation or exception. the originul and copies of the lollowing items: (Whethcr printcd or recorded or repl'Oduced by anothcr other mechanical proccss. or written or produced by hand). Agreements. communications, correspondence. telegrams. memoranda. sUlllmaries or records of pcrsonul conversations or interviews. diaries, reports. graphs. notebooks. note chal1s. plans. drawings. sketches. maps. summUl'ies or records of meetings or conferences, summaries or reports of investigations or negotiations, opinions or reports of consultunts. drafts, letters. any marginal comments appearing on any document. and writings of every kind. This definition shall also hc deem cd to include any machine-produced document. whcther from a computer or not. notcs and records of allY ol'al communication and recordings (tape. disk. or other) of oral communications, The word "communication" as used in the within Request shall mean uny transmission of information by oral. written. pictorial. or otherwise perceptible means. including but not limited to. telephone conversations. lettcrs. tclegrams. and pel'sona conversutions, The word "person" as used in the within Request shull mean any individual. corporation. partnership. unincorporatcd association or business entity. . -- . I>OCllMENTS TO BE PROI>lICEI> 1. All stalements. signcd statcments. transcripts of recorded statements. or interviews of any person or witness rel(lting 10. referring to. or describing any of the events or claims deseribed inlhe Complaint tiled in this case, 2. All documents prepared by any insurcr or rcpresentative of Plaintill's. except Plaintiffs' attorneys. during an investigation oflhe accident or any of the events or claims describcd in the Complaint. Such documents shall include any documents made or prcpared up to the present time. with the exclusion of mental impressions. conclusions or the opinions respccting thc value or merit of a claim or defcnse 01' respecting strategy 01' tactics. 3. All photographs of the scene of the accident or any of the vehiclcs involved in the accident. 4. All fedcral. state. and local income tax relurns tiled by Plaintiffs during the live years preceding the accidcnt in qtlestion. 5. All reports of any experts, 6, Alll11edical reports. medical and hospilal bilJs. wage loss information and other expenscs YOll are claiming resulting from the accident in question. 7. All repol'ts of any physicians. mental health professionals or vocational specialists pertaining to Plaintiffs. . .. ... 8. All declaration shcets of the Plaintiffs insurance in effect at the time of the accident. illdieating covcrages and whether Plaintiffs ca\'l'ied the full tort oplion or limitcd tori option, Date: Jt(~ r-- { Respectfully submitted. By: Richard B, ruby Es uire Attorney I.D, No. 904 840 East Chocolate Avenue Hershey. Pennsylvania 17033 Tel: (717) 533.5406 Fax: (717) 533-5717 Attorney for Defendant NESTICO, DRURY & HILDABIUND, LLP ATTORNEYS AT LAW 840 East Chocolate Avenue, Hershey, PA 17033 Phone (717) 533-5406 Fax (717) 533-5717 www.henheypalaw.com Apr il 12, 2005 William P. Douglas. Esquire 27 Wcst High Strect Carlisle, PA 17013 Re: Eileen & Bruee Minnich and Pamela & James Sheaffer Vs: Autumn Rickrode Docket No. 2004-5892 DcaI' Bill: Back on Fcbruary 24, 2005, I had forwardcd discovcry for response by your clients. To dutc, I have not rcccivcd those responses from you. In order to move this matter forward, I would appreciute your providing me with those responses within thc ncxt seven (7) duys. If that presents a problem. pleuse give mc a call. RBD/dhu cc. Jcrrerson J, Shipm~m, Esquire /; V cry truly yours, . ,/' . NESTlCO~~~;~~L?ABRAND' LLP By: /~/ '-- / Richard B. Oruby " t ..., . CERTIFICATE OF SERVICE L Christiana E. Appleby, of the law firm of Nestico, Druby & Ilildabrand. 1,1,1', hcreby .J. '5 -(M c >rtity that on the duy of ApriL 2005, a copy of the forcgoing documcnts was scnt ia First Class U.S. Muil, postage paid, to the following: William I). Douglas, Esquire 27 West High Street Carlisle,I)A 17013 .Jefferson .J. Shipman .JOHNSON, DUFFIE, STEW ART & WEIIJNER, P.c. 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 o fv\;whtJlla t. Qpf-<.h'l Christiana E. Appleby J <...... ;.:: ~ '~<j C:-;'" ~'b:i ..-'" __oj -, - ------..- () C :;:,'" UI' Q)I' "'> '= '= en :boo. .::y -,' N -..J o ..,., 5! Hi:!] :oF.:; ~.nr) u,r .'..~~ :,r: ;[~5f~ .:,:.-t :'t; --c: -:) :::t"; fS5 Q - . . .,.. J' RECEIVED APR 29 ZOOS ~ EILEEN L. MINNICH and BRUCE E. MINNIC! I, hcr Husband, IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA -undo No. 2004.5892 PAMELA J. SHEAFFER and JAMES R, SHEAFFER. her husband : CIVIL ACTION - LA W JURY TRIAL DEMANDED PluintiiTs v. AUTUMN RICKRODE. Defcndants. ORDER AND NOW, this 2,..'! day of , 2005. upon consideration of M"1 pefendant's Motion to Compel Discovery, IT IS HEREBY ORDERED, that PlaintiiI~ shall , rt--ol''''JC +r. 1J'1<-4l1t.. to" , ~:.('u~ ~rovide fun aHd cOllll'lste an3..el:J to. D\..J~J1dUllt"~ luttFr6galerie8 aRe g];)alI fH5\iae those rl'~rllmp'1tg re~lie3teel iH f)e}0RSElF1t"S R0EJl40St fk1r Pr0611etion within 20 days oflhe date thfs- o~er, with sanctions to be imposed upon Plaintiffs upon further application of Dcfendant, " fqr failure of PlaintifTs to comply in full with this Order. .I, ~ fr>"4....f .J, S/;>-/o,~ It~ 6- ~JI ,\ \'S\\~t. \"';- ..\ 0.... ,-' .:0 . .,':\ ."\)\_ .I> .\\\;\. '" V' -,,>,6~': \\'0 . ,) .: ,~, -(, v.), , ..&~ ::.~;'~~?~'. ;\(;/...0 l" / DOUGLAS LAW OFFICE 27W.IDGHST. POB 261 CARLISLE P A 17013 TELEPHONE 717-243-1790 William P. Douglas, Esq. Supreme Ct. ID # 37926 Eileen L. Minnich and Bruce E. Minnich, h/h Pamela J. Sheaffer and James R. Sheaffer, h/h In the Court of Common Pleas of Cumberland County, Pennsylvania Plaintiffs vs No. 04 - 5892 Civil Term Autumn Rickrode Defendant Civil action law Jury Trial Demanded Praecipe to Settle and Discontinue Dear Mr. Long, Please mark the above captioned matter settled and discontinued. Q.\:J William P. Dougl Attorney for PI May 10, 2006 ("') c -offi fT11"'J ---;Y..- ....-.--..- Zr-.' UJJ:- <.. !;=c- -p; i:(? -.......'--j --c Z --I -< l"-.) = = c"" ::it :>- -< o -n ~..,., m- ~~ ?: ::Ft ~~0 om ::;;-I ::0 -< c:> -0 :x w .. w .,..