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Home My WebLink About13-3668 ` Supreme Court of Pennsylvania Court of Common Pleas For Prothonotary Use Only: Civil Cover Sheet Docket No: /n /n County The information collected on this f>rtn is used solely for court adininistralion purposes. This frnrin does not Supplement or replace the filing and service of pleadings or other papers as required by lei' or rules of court. Commencement of Action: S ❑ Complaint 0 Writ of Summons F1 Petition Transfer from Another Jurisdiction ❑ Declaration of Taking E C Lead Plaintiffs Name: Lead Defendant's Name: JASMINE CHESTER TODD SHANNON LEGGE T Dollar Amount Requested: ❑within arbitration limits I Are money damages requested? Yes ❑ No (check one) outside arbitration limits O N Is this a Class Action Suit? ❑ Yes No Is this an MDJAppeal? E] Yes l No A Name of Plaintiff /Appellant's Attorney: ANDREW C. SPEARS, ESQ ❑ C'hcck here if you have no attorney (are a Self-Represented (Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass 7'61-1) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑x Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections Nuisance ❑ Dept. of Transportation Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not include E mass tort) ❑Employment Dispute: Slander /Libel/ Defamation Discrimination C ❑Other: ❑Employment Dispute: Other ❑Zoning Board Other: , 1 ❑ Other: O MASS TORT El Asbestos N ❑ Tobacco ❑ Toxic Tort - DES Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Other: ED Ejectment E] Common Law /Statutory Arbitration B F Eminent Domain /Condemnation ❑ Declaratory Judgment El Ground Rent ❑ Mandamus El Landlord /Tenant Dispute ❑ Non - Domestic Relations El Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: Medical ❑ Other: Fj Other Professional: Updated 1/1/2011 i - 0 � it L Andrew C. Spears �,1, 1 1"k i ��,��,��.� Attorney ID# 87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Lin Road 7013 JUN 25 PM 1:08 Harrisburg, PA 17110 Telephone: (717) 238 -2000 Attornep9 i r" YL f COUNTY ( Fax : (717) 233 -3029 P h NSANIA E -mail: Spears @hhrlaw.com IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA / No. 2013 NPCP l,l t/ I Civil Action (XX) Law ( ) Equity Jasmine Chester Todd Shannon Legge 2206 Cedar Run Dr. 1909 Princeton Avenue Apt C Camp Hill, PA 17011 Camp Hill, PA 17011 versus Plaintiff(s) & Address(es) Defendants) & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue A Writ of Summons in the above - captioned action. X Writ of Summons Shall be issued and forwarded to ( )Attorney (XX)Sheriff Andrew C. Spears Handler Henning & Rosenberg, LLP 1300 Linglestown Road Suite 2 Harrisburg PA 17110 Signature of At orney (717) 238 -2000 Supreme Court ID No. 87737 Name /Address /Telephone No. of Attorney Date: June 20, 2013 Cx %�v, �b3•� a NA WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE -NAMED PLAINTIFF(S) H HA COMMENCED AN ACTION AGAINST YOU. Protho y Date: S '� by Deputy ( ) Check here if reverse is used for additional information PROTHON. - 55 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff THE PROTHON01"Af" Jody S Smith Chief Deputy 2013 JUL 10 AM 9: 49 Richard W Stewart Solicitor OM,F UTT-r.SMEPIry CGUMBERLANO COUN*f Y PENNSYLVANIA Jasmine Chester Case Number vs. 2013-3668 Todd Shannon Legge SHERIFF'S RETURN OF SERVICE 0710512013 06:04 PM-Deputy Shawn Harrison, being duly sworn according t law s rved th r uested Affidavit by , g 0 handing a true copy to a person representing themselves to be Sharon th r,who accepted as "Adult Person in Charge"for Todd Shannon Legge at 1909 Princeton A e ue mp ill Borough, Camp Hill, PA 17011. SH)WN- H N, DEPUTY SHERIFF COST: $45.41 SO ANSWERS, July 08,2013 RbNO R ANDERSON, SHERIFF (C)CoulntySuite Sheriff,Tdeosoft,Inc, Joseph R. D'Annunzio, Esquire I.D. No. 23384 4309 Linglestown Road, Suite 211, Harrisburg,'PA 17112 Attorney for Defendant, c : (717) 901-5002 Todd Legge -oz x". _; Fax: (717) 901-5012 r r D c -- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA *c7 Jasmine Chester c° DO Plaintiffs NO. 2013-3668 1 C-n ry V. CIVIL ACTION - LAW Todd S. Legge, JURY TRIAL DEMANDED Defendant PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Defendant, Todd Legge, in the above-captioned matter. LAW OFFICE OF JOSEPH R. D'ANNUNZIO Date: y L� 7d0/0 BY:�, � 0' Joseph R. D'Annunzio, Esquire Attorney for Defendant CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: Andrew C. Spears, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 Date: t Kimb ly Stielper BY.-Joseph R. D Annunzio Law Office of Joseph R. D Annunzio Identification No. 23384 4309 Linglestown Road, Suite 211 Attorney for Defendant, Todd'Legge Harrisburg,PA 17112 (717) 901-5002 rr Fax: (717) 901-5012 c IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA r CD JASMINE CHESTER, 5;c- Plaintiff NO. 2013-3668 V. CIVIL ACTION - LAW TODD S. LEGGE, JURY TRIAL DEMANDED Defendant PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONORARY/CLERK OF THE SAID COURT-CIVIL DIVISION: Please enter a Rule upon Plaintiff,Jasmine Chester, to file a Complaint against Todd Legge within twenty (20) days hereof or suffer the entry of a Judgment Non Pros. LAW OFFICE OF JOSEPH R. D'ANNUNZIO Date: lf.,j„�!' Lbt� BY: Joseph R. D Annunzio,Esquire Attorney Identification No.: 23384 Attorney for Defendant,Todd Legge RULE TO FILE COMPLAINT AND NOW, this day of , 2013, a rule is hereby granted upon Plaintiff,Jasmine Chester, to file a Comp aint within twenty (20) days after service hereof or suffer the entry of a Judgment Non Pros. PR ONOTA Y/CLERK CERTIFICATE OF SERVICE 1 hereby certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first- class postage prepaid, addressed as follows: Andrew C. Spears,Esquire Handler,Henning&Rosenberg,LLP 1300 Linglestown Road Harrisburg, PA 17110 Date:— 113 KimberlHelper L0 C E Pi,%0 i HON0TA' ,.. i f.3 S E P 12 Plt I. 4 CUMBERLAND COUNTY PENNSYLVANIA Andrew C. Spears(PA 87737) HANDLER,HENNING&ROSENBERG,LLP 1300 Linglestown Road, Suite 2 Harrisburg,PA 17110 Ph. 717.238.2000 Fax 717.233.3029 spears @hhrlaw.com Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JASMINE CHESTER, Plaintiff, V. NO.: 2013-3668 Civil TODD SHANNON LEGGE, Defendant. CIVIL ACTION—LAW COMPLAINT AND NOW comes Plaintiff, Jasmine Chester ("Ms. Chester"), by and through her attorneys, HANDLER, HENNING, & ROSENBERG, LLP, by Andrew C. Spears, Esq., and makes the within Complaint against Defendant, Todd Shannon Legge ("Defendant"), and avers as follows: 1. Ms. Chester is a competent adult individual currently residing at 2206 Cedar Run Drive, Apartment C, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is, upon information and belief, a competent adult individual with a last known address of 1909 Princeton Avenue, Camp Hill, Cumberland County, Pennsylvania. 3. At all times material hereto, Ms. Chester was the owner and operator of a 1997 Mitsubishi Mirage, bearing Pennsylvania registration number HPG6036 ("Plaintiffs Vehicle"). 4. At all times material hereto, Defendant was the owner and operator of a 2001 Subaru Legacy, bearing Pennsylvania registration number HSB5404 ("Defendant's Vehicle"). 5. On July 2, 2011, at approximately 3:24 p.m., Ms Chester was traveling west on State Street near its intersection with South 19th Street, in Camp Hill, Cumberland County, Pennsylvania, and was stopped in order to safely make a left turn. 6. At approximately the same time and place, Defendant's Vehicle was traveling behind Plaintiff's Vehicle, also westbound on State Street, and approaching Plaintiff's Vehicle from the rear. 7. Defendant failed to react safely to Plaintiffs Vehicle lawfully stopping in front of him, and suddenly and violently struck the rear of Plaintiffs Vehicle. 8. As a direct and proximate result of Defendant's negligence, Ms. Chester sustained damages as set forth more specifically below. 9. The occurrence of the aforementioned collision and all the resultant injuries to Ms. Chester are the direct and proximate result of Defendant's negligence, generally and more specifically as set forth below: a. In driving Defendant's Vehicle in careless disregard for the safety of persons or property in violation of 75 Pa. C.S. § 3714; b. In failing to exercise reasonable care in the operation and control of Defendant's Vehicle, in violation of 75 Pa. C.S. § 3714; C. In failing to keep a proper lookout for vehicles lawfully slowing or stopped upon the roadway; d. In failing to be reasonably vigilant to observe Plaintiffs Vehicle 2 lawfully stopped upon the roadway; e. In following another vehicle more closely than was reasonable and prudent, in violation of 75 Pa. C.S. § 3310(a); f. In failing to properly regulate the speed of Defendant's Vehicle so as to prevent a rear-end collision; g. In failing to operate Defendant's Vehicle at a speed at which he could stop within the assured clear distance ahead, in violation of 75 Pa. C.S. § 3361; h. In disregarding the speed of vehicles, the condition of the highway, and the traffic upon the highway, in violation of 75 Pa. C.S. § 3361; i. In failing to have sufficient control of Defendant's Vehicle, which would have allowed the vehicle to be stopped before doing injury to any person or anything likely to arise under the circumstances; j. In failing to operate Defendant's Vehicle at a speed that was safe under the circumstances, in violation of 75 Pa. C.S. § 3361; and k. In failing to be continuously alert, in failing to perceive any warning of danger that was reasonably likely to exist, and in failing to have Defendant's Vehicle under such control that injury to persons or property could be avoided. 10. As a direct and proximate result of Defendant's negligence, Ms Chester has: a. Suffered personal injuries including, but not limited to, head, back, and neck pain, nerve damage, and a bulging disc; 3 b. Suffered a loss of income; C. Undergone medical care for the aforesaid injuries, including but not limited to physical therapy; d. Suffered physical pain, discomfort, and mental anguish to her physical, emotional, and financial detriment and loss; e. Been compelled, in order to effect a cure for the aforesaid injuries, to spend money for medicine and/or medical attention; f. Suffered a loss of life's pleasures to his detriment and loss; and, g. Been hindered from attending to her daily duties and chores, to her detriment, loss, humiliation, and embarrassment. WHEREFORE, Plaintiff, Jasmine Chester, seeks damages from Defendant, Todd Shannon Legge, in an amount in excess of the compulsory arbitration limits of Cumberland County, exclusive of interest and costs. Respectfully submitted, HANDLER,HENNING &ROSENBERG,LLP Date: September , 2013 By: Andrew C. Sp s, uir I.D. No. 87737 1300 Linglestown Road, Suite 2 Harrisburg, PA 17110 (717) 238-2000 Attorneys for Plaintiff, Jasmine Chester 4 VERIFICATION The undersigned hereby verifies that the statements in the foregoing document are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of this lawsuit. The language of the document is of counsel and not my own. I have read the document 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 document are that of counsel, I have relied upon my counsel in making this Verification. The undersigned also understands that the statements made therein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: fa(JYh ester • e Andrew C. Spears Attorney ID# 87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Attorney for Plaintiff(s) Fax : (717) 233-3029 E-mail: Spears @hhrlaw.com JASMINE CHESTER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) NO. 2013-3668 TODD SHANNON LEGGE CIVIL ACTION - LAW Defendant(s) CERTIFICATE OF SERVICE On September 10, 2013, 1 hereby certify that a true and correct copy of Plaintiffs Complaint was served upon the following by depositing same in the United States Mail, in Harrisburg, Pennsylvania: Joseph R. D'Annunzio, Esq. 4309 Linglestown Road Suite 211 Harrisburg, PA 17112 HANDLER, rqNING & ROSENBERG, LLP Dated: e�,1��J Andrew C. S rs FILED-OFFM BY:Joseph R.D'Annunzio sr` THE PROTHONOTARY Law Office of Joseph R.D'Annunzio Identification No.23384 ' 3 S .P 23 APB 11: 29 4309 Linglestown Road,Suite 211 Attorney for Defendant,ToA Legge Harrisburg,PA 17112 'CUMBERLAND COUNTY (717)901-5002 P E N N S Y LVA 141 A (717)901-5012(Fax) jdannunzio@geico.com IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY,PENNSYLVANIA JASMINE CHESTER, Plaintiff NO. 2013-3668 V. CIVIL ACTION -LAW TODD SHANNON LEGGE, JURY TRIAL DEMANDED Defendant NOTICE TO PLEAD TO: Jasmine Chester c/o Andrew C. Spears, Esquire Handler, Henning &Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 You are hereby notified to file a written response to the enclosed Answer and New Matter of Defendant to Plaintiff's Complaint within twenty (20) days from service hereof or a default judgment may be entered against you. LAW OFFICE OF JOSEPH R. D'ANNUNZIO v Date: . .- 2-*/ L /.? By. Joseph R. D'Annunzio, Esquire Attorney for Defendant, BY:Joseph R.D'Annunzio Law Office of Joseph R.D'Annunzio Identification No.23384 4309 Linglestown Road,Suite 211 Attorney for Defendant,Todd Legge Harrisburg,PA 17112 (717)901-5002 (717)901-5012(Fax) jdannunzio@geico.com IN THE COURT OF COMMON PLEAS FOR CUMBERLAND, COUNTY, PENNSYLVANIA Jasmine Chester, Plaintiff NO. 2013-3668 V. CIVIL ACTION - LAW Todd S. Legge, JURY TRIAL DEMANDED Defendant ANSWER AND NEW MATTER OF DEFENDANT,TODD LEGGE,TO PLAINTIFF'S COMPLAINT 1) Admitted only upon information and belief. 2) Admitted. 3) Admitted only upon information and belief. 4) Admitted. 5) Admitted in part and denied in part. It is admitted that on July 2, 2011 at approximately 3:24 p.m., the Plaintiff was traveling west on State Street near the intersection with S. 19th Street in the Borough of Camp Hill, Cumberland County, Pennsylvania. It is denied that the Defendant was stopped in order to safely make a left turn; rather, suddenly and without warning to following vehicles, the Plaintiff stopped and then made a left turn into a business establishment causing the collision. 6) Admitted in part and denied in part. It is admitted that at approximately the same time and place the Defendant's vehicle was traveling behind the Plaintiff's vehicle also westbound on State Street. It is denied that the Plaintiff had stopped safely in an effort to make her turn. 7) Denied. It is denied that the Defendant failed to react safely to the Plaintiff's vehicle lawfully stopping in front of him. To the contrary,the Plaintiff's vehicle did not lawfully stop and her actions were sudden, unexpected and unable to be anticipated. It is denied that the Defendant violently struck the rear of the Plaintiff's vehicle. Rather, a minor collision occurred. 8) Denied that the Defendant was negligent or that his conduct in any way caused or contributed to the injuries or damages allegedly sustained by the Plaintiff. To the contrary, the Defendant exercised all due and reasonable care in the operation of his motor vehicle. After reasonable investigation,the Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments set forth regarding injuries and damages. Accordingly,the averments are deemed denied and strict proof is demanded. 9) Denied as conclusions of law to which no responsive pleading is required. In general, it is denied that the Defendant was negligent or that his conduct in any way caused or contributed to any injuries or damages allegedly sustained by the Plaintiff. To the contrary,the Defendant exercised all due and reasonable care in the operation of his motor vehicle. 10)It is denied that the Defendant was negligent or that his conduct in any way caused or contributed to any injuries or damages allegedly sustained by the Plaintiff. To the contrary,the Defendant exercised all due and reasonable care in the operation of his motor vehicle. After reasonable investigation,the Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments set forth in this paragraph regarding injuries and damages. Accordingly,the averments are deemed denied and strict proof is demanded. WHERFORE, Defendant, Todd Shannon Legge demands that judgment be entered in his favor. NEW MATTER 11)Paragraphs 1-10 are incorporated by reference as if fully set forth herein. 12)At all times relevant to this Complaint and cause of action, the Plaintiff operated her vehicle while traveling westbound on State Street, a public highway in the Borough of Camp Hill, Cumberland County, Pennsylvania. 13)Suddenly and without warning,the Plaintiff stopped and then proceeded into a business establishment located on State Street. 14)The collision referred to in this Complaint and the injuries allegedly sustained by the Plaintiff as a result of that collision,were a direct and proximate result of the negligence, carelessness and recklessness of the Plaintiff, Jasmine Chester, said negligence consisting of the following. a. She brought her vehicle to an abrupt and unexpected stop; b. She stopped her vehicle in the middle of a highway and there was no good reason for her to do so; c. She failed to activate her turn signal to alert the vehicles traveling behind her of her intention to make a turn. d. She failed to have due regard for the rights, safety, and position of other vehicles on the highway including the vehicle operated by the Defendant. e. The Plaintiff failed to exercise due and reasonable care in the operation of her motor vehicle. 15)The Plaintiff is barred from recovering for the injuries and damages claimed because of her contributory negligence which was the direct and proximate cause of this accident. 16)The Plaintiff is barred and/or limited in recovering for her injuries and damages from this accident by virtue of her comparative negligence which was at least as great if not greater than any negligence that can be attributed to the Defendant. 17)The Plaintiff is barred from recovering because she elected or is deemed to have elected the Limited Tort option of insurance and her injuries do not amount to a serious injury as that term is defined under the Pennsylvania Motor Vehicle Financial Responsibility Law and applicable case law. 18)The injuries and damages sustained by the Plaintiff, either in whole or in part, preexisted the occurrence of this accident and so she is barred from recovering for them. 19)The injuries and damages sustained by the Plaintiff may have occurred by an event subsequent to this accident and so she is barred from recovering. WHEREFORE, Defendant, Todd Shannon Legge, demands that judgment be entered in his favor. Respectfully submitted, Date: l �g� ZoJ 7v/3 By:*Joseph R. UAnnunzio, Esquire Attorney for Defendant VERIFICATION Todd Legge states that he is the Defendant in this action, and verifies that the statements made in the foregoing document are true and correct to the best of his knowledge, information and belief. The undersigned states that the statements therein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: 9- /8 ' 3 Signature: —Ws./Legge BY:Joseph R.D'Annunzio Law Office of Joseph R.D'Annunzio Identification No.23384 4309 Linglestown Road,Suite 211 Attorney for Defendant,Todd Legge Harrisburg,PA 17112 (717)901-5002 (717)901-5012(Fax) jdannunzio @geico.com , IN THE COURT OF COMMON PLEAS FOR CUMBERLAND, COUNTY,PENNSYLVANIA JASMINE CHESTER, Plaintiff NO. 2013-3668 V. CIVIL ACTION—LAW Todd S. Legge, JURY TRIAL DEMANDED Defendant CERTIFICATE OF SERVICE I,Kimberly Stielper, do hereby certify that on this QAJ day of d , 2013, I caused a true and correct copy of Defendant,Todd Legge's,Answer and New Matter Addressed to Plaintiff, Jasmine Chester , to be served upon the following person listed below via first class United States mail, postage prepaid: Andrew C. Spears,Esquire Handler, Henning&Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 LAW OFFICE OF JOSEPH R. D'ANNUNZIO BY: Kimberly S ' 1per, Legal Secretary BY: Joseph R. D'Annunzio Law Office of Joseph R. D'Annunzio Identification No. 23384 4309 Linglestown Road, Suite 211 Harrisburg, PA 17112 (717) 901-5002 Fax: (717) 901-5012 Attorney for Defendant, Todd Legge 0`'2` C� c- D�>. J� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY JASMINE CHESTER, Plaintiff NO. 2013-3668 v. CIVIL ACTION - LAW TODD S. LEGGE, JURY TRIAL DEMANDED Defendant CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant, Todd Legge certifies that: 1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each. 2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, 3) No objection to the subpoena has been received, 4) The subpoena which will be served is attached to the notice of intent to serve subpoena. Date: 7// /7) 2.4.1 BY: oseph R. D'Annunzio, Esquire Attorney for Defendant, Legge CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: Andrew C. Spears, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 Date: KimberlCyJStielper LAW OFFICE OF JOSEPH R. D'ANNUNZIO ATTORNEYS AND SUPPORT ASSOCIATES ARE EMPLOYEES OF GOVERNMENT EMPLOYEES INSURANCE COMPANY 4309 Linglestown Road, Suite 211 Harrisburg, PA 17112 Telephone: 717-901-5002 Facsimile: 717-901-5012 June 30, 2014 Andrew C. Spears, Esquire Handler, Henning & Rosenberg, LLP 1300 Linglestown Road Harrisburg, PA 17110 RE: Chester v. Legge Dear Mr. Spears: Enclosed please find a Notice of Intent to Serve Subpoena as well as a proposed copy of the subpoena. Please let me know if you have any objections to the service of this subpoena. If you have any questions, please feel free to contact me. Very truly yours, Joseph R. D'Annunzio JRD/ks cc: Michael Moeller - Claim #0380591620101012 BY: Joseph R. D'Annunzio Law Office of Joseph R. D'Annunzio Identification No. 23384 4309 Linglestown Road, Suite 211 Harrisburg, PA 17112 (717) 901-5002 Fax: (717) 901-5012 Attorney for Defendant, Todd Legge IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JASMINE CHESTER, Plaintiff v. TODD S. LEGGE, Defendant NO. 2013-3668 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Defendant, Todd S. Legge 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 no objection is made the subpoena may be served. Date: 3b Y Joseph R. D'Annunzio, Esquire Attorney for Todd Legge IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JASMINE CHESTER, Plaintiff V. TODD S. LEGGE, Defendant NO. 2013-3668 CIVIL ACTION - LAW JURY TRIAL DEMANDED TO: Pinnacle Health Family Care Mechanicsburg: You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.22 , Certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the subpoena issued on have been produced. Date: Signature Andrew C. Spears Attorney ID# 87737 HANDLER, HENNING & ROSENBERG, LLP 1300 Linglestown Road Harrisburg, PA 17110 Telephone: (717) 238-2000 Fax : (717) 233-3029 E-mail: Spears@hhrlaw.com Attorney for Plaintiff(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JASMINE CHESTER, Plaintiff(s) v. TODD SHANNON LEGGE, Defendant(s) Dated: 2013-3668 Civil Action - Law PRAECIPE Please mark the above captioned matter settled and discontinued. HANDLER.NING & ROSENBERG LLP e Andrew C ars