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Home My WebLink About05-1494 By: JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA v. 2005- I Y 1 tt CIVIL TERM ALVERT C. SINGER Defendant CIVIL ACTION. LAW PRAECIPE FOR ISSUANCE OF A WRIT OF SUMMONS TO CURTIS R. LONG, PROTHONOTARY: Please issue a Writ of Summons against the defendant. AL VERT C. SINGER. and enter my appearance on behalf of the plaintiffs, JAMES DROMESHAUSER and FAYE E. DROMESHAUSER. Please direct the Sheriff to serve the defendants as follows: AL VERT C. SINGER 1890 MARY LANE CARLISLE, PA 17013 Respectfully submitted, By: Date: March 16, 2005 To: ALVERT C. SINGER You are hereby notified that James Dromeshauser and Faye E. Dromeshauser, plaintiffs. have commenced an action against you which you are required to defend or a default judgment may be entered against '0" 4~ II p // ~TARY L~ DEP T Date: lr10Ji,c~ ~I ,2005 ~ ~ (:;> ~ OJ- 0\ <!', '^ 0' -- 10" 9.J C) ~') -Ll ~ ~ 41 "3 ,." '~ -:;, ~. ;s- +-- o -it SHERIFF'S RETURN - REGULAR CASE NO: 2005-01494 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DROMESHAUSER JAMES ET AL VS SINGER ALVERT BRIAN BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn accordin to law, says, the within WRIT OF SUMMONS SINGER ALVERT C DEFENDANT was served upon at 1140:00 HOURS, on the 29th day of March at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 ALVERT SINGER by handing to a true and attested copy of WRIT OF SUMMONS e 2005 together with So Answers: -_."c''',?'' #. 7r- S...j>:'.~ ,~<"7~t:;,~f'''' -zA? l /,.... .,;::><';?- '-, - ~.. .. R. Thomas Kline 03/30/2004 MARCUS MCKNIGHT By: , c " 114~) ~1, Deputy Sheriff and at the same time directing His attention to the contents t ereof. Sheriff's Costs: Docketing Postage Affidavit Surcharge 18.00 .37 .00 10.00 .00 28.37 Sworn and Subscribed to before of GRAHAM & MAUER, P.c. By: Ronald M Graham, Esquire Attorney J.D. 64483 The Commons at Valley Forge Suite 22, Box 987 Valley Forge, PA 19482 (610)933-3333 JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, blw : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA : NO. 2005-1494 Plaintiffs vs. AL VERT C. SINGER : CIVIL ACTION - LAW Defendants PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Ronald M. Graham, Esquire as counsel for Plaintiffs James Dromeshauser and Faye E. Dromeshauser. Ronal Attorn Ulre By: Date: l/ - P-l-O c:; ,-. n --I -,- r-;'l u:J ~ .'. JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW AL VERT C. SINGER, Defendants ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter our appearance on behalf of Defendant Alvert C. Singer in the above matter. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP .-:;> Brooks R. Foland, EsqUIre LD. No. 70102 305 North Front Street, 6th Floor POB 999 Harrisburg, PAl 71 08-0999 (717) 255-7626 by: . . ~ CERTIFICATE OF SERVICE / . (11 'f"l" AND NOW, this L day of I LL~1 v of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and .- , 20o?I, Coleen M. Polek, correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Ronald M. Graham, Esq. Graham & Mauer, P.c. The Commons at Valley Forge Suite 22 POB 987 Valley Forge, PA 19482 'Wi~ Co een M. Polek --,.\ -- -(, -;" ~' " ~....'., 'i.....,) f"", <.,; JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW ALVERT C. SINGER, Defendants PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a rule upon Plaintiff to file a Complaint in the above matter within 20 days after service of the rule or suffer a judgment of non pros. THOMAS, THOMAS & HAFER By: r ks R. Foland, Esq. J.D. No. 70102 305 North Front Street Sixth Floor P.O. Box 999 Harrisburg, P A 17108-0999 (717) 255-7626 RULE NOW, [fl ';l 'I IJ... , , 2005, RULE JjSUED AS ABOVE. (~1/)-/;:o ) J . Prothonotary ~: ~ O---r I? _ [! C-yyJ'l?/"Vr~ ~ Deputy ,...-:, r<' ;-.:- .- 0' GRAHAM & MAUER., P.C. By: Ronald M Graham, Esquire Attorney LD. 64483 The Commons at Valley Forge Suite 22, Box 987 Valley Forge, PA 19482 (610)933-3333 JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, hlw : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLV ANlA NO. 2005-1494 Plaintiffs VS. ALVERT C. SINGER : CIVIL ACTION -LAW Defendants NOTICE TO DEFEND ADVISO You bave been sued in Court. If you wish In deti:od against the claims set forth in Ibe fuIlowing peges. you must take action wilbin sixty (60) days after this Complaint and _"" are served, by ""tain8 0 writlal _ persooulIy... by IIllomey and fiIinl! in writing with tho court your dcfa>seo ... objections In the cJaims "" forth against you. You are warned !bat if you fitilln do so the.... may ~ without you and ojudgman may be _ against you by the court without funher -.,. f... ony _ claimed in the <OIIlplaint or fur ony other claim or ",lief ""1_ by the pIaintilI' You may 1098 money or property or other rights important In you. Le ban _ 0'- ""Is 00110. Si USIOd quicre defalderso de estas demondas expuestlIS ""!as poginas sig......... .- tiene (60) dias de pIazo a1 pertir de 10 _ dela demanda y Ia ootificacion. Race falta asentar una com puencia escrita 0 eo peraona 0 con WI abogado y entregar' ala CQ1e en (<luna escrita sua defi::nsas 0 IUS objectime:s alas danandas en cotltra de su penoaa. Sea &Visado que si .- no so defiende, Is corte "'..... medi.... y pUOde contin_1a dcmaoda en CODb'8 suya sin jlI'C\OOl &Visa 0 ootifiea2on. Ademas. Ia corte puede decidir 0 fiMlr del dellOondante y requi<<e que.- cumpla coo lodas!as proYisiooes <Ie _............ Usted puode perder dinero 0 sus propiedades u otros dllJ"OlldJos importantes JllIIB USIOd. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT USTEDDEBE ILEVARESTE DOCUMENTOA SU ABOGAOO ONCE. 11' YOU 00 NOT HA VB A LAWYER OR CANNOT lNMl!DIATAMENTI!. SI USTED NOTIBNE ABOGAOO (0 NO TIBNEDINERO SlJFlClENTE PARA PAGAR A UN AFFORD ONE. GO TO OR TELEPHONE TIlE OFFICE SET ABOGAOO). VAYA ENPERSONA 0 llAME!'OR TELEFONO FORllI BBLOWTOI'INDOur WHERE YOU CAN GIlT LA OFICINANOMBRADA ABAJO PARA A VERlGUAR lEGAL HELP. 1lIIS OFFICE CAN PROVIDll YOU wrrn DONDE SE PUEDE CONSEGUlR ASSlSTENClA lEGAL. ESTA TIlE lNFORMATION ABOur HIRING A LAWYER. THIS OFlClNA PUEDE PROI'ORCIONARLE LA lNFORMACION 0Ff1CE MAYBE ABLE TO PROVIDE yOU wrrn SOBRE CONTRATAR A UN ABOOAOO.. SI USTED NO TIENE INFORMATION A90Uf AGENCmS TIlAT MAY OFFER DINERO SUFlClENTE PARAPAGAR A UN ABOGAOO.ESTA 0FIClNA PUEDE PROPORClONARLE INFORMACtON SOBRE lEGAL SERVICES TO EIlG1BLE PERSONS AT A REDUCED AGENCIAS QUE OFRECEN SEllVICIOS LIlGALES A FEE OR NO FEE. PERSONAS QUE CUMPUlN LOS REQUIllITOS PARA UN HONORARIO REDUCIDO 0 NINGUN HONORARIO. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, P A 17013 717-249-3166 GRAHAM & MAUER, P.C. By: Ronald M. Graham, Esquire Attorney lD. 64483 The Commons at Valley Forge Suite 22, Box 987 Valley Forge, PA 19482 (6]0)933-3333 JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, h/w : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2005-]494 Plaintiffs vs. ALVERT C. SINGER : CIVIL ACTION -1_A W Defendants COMPLAINT I. Plaintiffs James Dromeshauser and Faye E. Dromeshauser are husband and wife and adult individuals who, at all times relevant hereto, resided at 8916 Olde Scotland Road, Shippensburg, Franklin County, Pennsylvania 17257. 2. Defendant Alvert C. Singer, hereinafter "Singer," is an adult individual who, at all times relevant hereto, was believed to reside at 1890 Mary Lane, Carlisl1e, Cumberland County, Pennsylvania 17013. 3. On or about June 1,2003 Plaintiff James Dromeshauser WllS the driver ofa 1993 Honda Accord, which was traveling South on State Route 34 in South Middletown Township, Cumberland County, Pennsylvania. 4. At said time and place, Defendant Singer was the driver of a 1998 Cadillac Deville. 5. Suddenly and without warning Defendant Singer drove into the southbound lane of State Route 34 in an effort to make a left turn in order to proceed northbound on State Route 34 from Marsh Drive. 6. At all times relevant hereto, the intersection of Marsh Drive and State Route 34 was controlled by a stop sign for traffic proceeding eastbound on ~lTSh Drive. 7. Defendant Singer's failure to stop and/or remain stopped, in accordance with the stop sign controlling his path of travel, caused a near head on collision between the car driven by Defendant Singer and the car driven by James Dromeshauser. 8. Said collision resulted in serious and permanent injuries and damages to Plaintiffs James Dromeshauser and Faye E. Dromeshauser. COUNT I - NEGLIGENCE PLAINTIFF JAMES DROMESHAUSER v. ALVERT C. SINGER 9. Paragraphs 1 through 8 of this Complaint are incorporated herein by reference as if set forth at length. 10. Defendant Singer was negligent, careless and negligent per se in the operation of said motor vehicle for the following reasons which include: a. Failure to properly operate, manage and control said motor vehicle; b. Disregarding the rights, safety and position of other vehicles on the road including the vehicle driven by Plaintiff James Dromeshauser; c. Failure to keep a proper look out; d. Failure to remain a safe and clear distance away from other vehicles; e. Failure to abide by appropriate statutes, rules and re:gulations of the road; ( Failure to stop and/or remain stopped in time to avoid a collision with other vehicles including that vehicle operated by Plaintiff James Dromeshauser; g. Failure to apply the brakes in a timely manner; h. Failure to control said motor vehicle in a reasomLble and prudent fashion; 1. Operating, steering and controlling said motor vehicle in a careless and negligent manner; J. Failing to avoid the occurrence complained of; k. Failing to observe the roadway and/or the vehicles thereon; I. Failure to remain alert at the wheel; m. Failure to obey a traffic signal in the form of a stop sign; n. Operating said motor vehicle at an inappropriate und/or excessive rate of speed under the circUfilstanceS then prevailing; o. Failure to alter his course to avoid a collision; p. Failing to yield the right of way; q. Negligence per se; and r. Failure to comply with 75 Pa.C.S. 3323 et seq. 11. As a direct and proximate result of the negligence, carelessness and negligence per se of Defendant Singer and not due to any act or failure to act on the part of Plaintiff James Dromeshauser, said Plaintiff suffered great pain, lumbar spine injuries including aggravation of pre-existing lumbar spine iItiuries at L5-S I and IA-5, as well as, disc bulging with irregular posterior annulus margin at IA-5 and L5-S1 with significant loss of disc space height and facet hypertrophy, stretching of the lumbar nerve roots with pain, limited range of motion in the back and lower extremities, fractured sternum, low back and leg pain requiring the implantation of an electrical stimulation device, muscle spasms, sacroilitis with sacroliliac joint dysfunction and facet syndrome in the lower lumbar region, decreased sensation ov'~r the right foot, knee and thigh, posterior thigh pain and pain in the right foot and toes, as well as, abnormal gait, headaches, loss of life's pleasures, depression, emotional distress, scarring and injuries to his nerves and nervous system and an increased susceptibility to future injury some or all of which are or may be permanent in nature. 12. Plaintiff James Dromeshauser's injuries, some of which required surgical repair, have resulted in serious impairment of bodily functions. 13. As a direct and proximate result of the negligence, carelessness and negligence per se of Defendant Singer, Plaintiff James Dromeshauser has been and may continue to be in the future unable to attend to his usual habits, customs, vocation and/or enjoyment oflife. 14. As a direct and proximate result of the negligence, carelessness and negligence per se of Defendant Singer, Plaintiff James Dromeshauser has been in the past and may continue to be in the future, required to undergo medical and medically related tre,atments and procedures. 15. As a direct and proximate result of the negligence, carelessness and negligence per se of Defendant Singer, Plaintiff James Dromeshauser has been in the past and/or may be in the future, required to spend great sums of money for medical, surgical and medically related treatment and procedures as a result of his injuries. 16. As a direct and proximate result of the negligence, carelessness and negligence per se of Defendant Singer, Plaintiff James Dromeshauser has in the past and may in the future suffer a loss of earnings and/or earning capacity. 17. Plaintiff James Dromeshauser is entitled to recover damag,es under the full tort option provided by the motor vehicle financial responsibility law, 75 Pa.C.SA ~]701 et seq. WHEREFORE, Plaintiff James Dromeshauser demands judgment in his favor and against Defendant Alvert C. Singer in an amount which exceeds the jurisdictional limit requiring arbitration referral by local rule plus interests, costs, delay damages and such other remedies as this Court may deem just and reasonable. COUNT n - NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS FAYE E. DROMESHAUSER v. ALVERT C. SINGER 18. Paragraphs 1 through 17 of this Complaint are incorponlted herein by reference as if set forth at length. 19. At all times pertinent hereto, in particular, from the time of the said collision until the present, Plaintiff Faye E. Dromeshauser was present to observe, hear and be aware of the events which took place during and as a result of said motor vehicle collision which seriously injured her husband, Plaintiff James Dromeshauser. 20. Plaintiff Faye E. Dromeshauser was present to observe the impact and infliction of injury upon her husband Plaintiff James Dromeshauser. 21. As a result of observing, hearing and being present for and aware of the negligent, careless and negligent per se acts of Defendant Singer as set forth herein, Plaintiff Faye E. Dromeshauser has suffered and will continue to suffer mental anguish, anxiety, emotional upset, psychological and functional injury and damages including depression, sleeplessness, nightmares, nervousness, headaches, nausea, stress, shock, mental pain, humiliation and other physical and psychological disorders, which have or may in the future require medical attention, as well as psychological and emotional counseling, including the administration of depression and/or anxiety ameliorating medications, the full extent of which is not yet known, and some or all of which may be permanent in nature. 22. Plaintiff Faye E. Dromeshauser has been or may be required to expend money to treat said conditions which were caused by Defendant Singer's negligenl:e, carelessness and negligence per se as set forth herein. 23. As a direct and proximate result of Defendant Singer's negligence, carelessness and negligence per se, Plaintiff Faye E. Dromeshauser has suffered pain and suffering, emotional distress, fmancialloss, loss oflife's pleasures, humiliation and other injuries and damages as set forth herein. WHEREFORE, Plaintiff Faye E. Dromeshauser hereby demands judgment in her favor and against Defendant Alvert C. Singer in an amount which exc,eeds the jurisdictional limit requiring arbitration referral by local rule plus interests, costs, dday damages and such other remedies as this Court may deem just and reasonable. COUNT m - WSS OF CONSORTIUM PLAINTIFF FAYE E. DROMESHAUSER v. ALVERT C. SINGER 24. Paragraphs I through 23 of this Complaint are incorporated herein by reference as if set forth at length. 25. At all times pertinent hereto, Plaintiff James Dromesha~er and Faye E. Dromeshauser were husband and wife and residing together at the same address. 26. Due to the negligence, carelessness and negligence per se of Defendant Singer, Plaintiff Faye E. Dromeshauser has been deprived and may in the future lx~ deprived of the companionship, support, services and consortium of her husband Plaintiff James Dromeshauser. 27. Due to the negligence, carelessness and negligence per se of Defendant Singer, Plaintiff Faye E. Dromeshauser has paid and/or may be required to pay in tll1e future for the medical treatment of her husband's injuries. 28. Due to the negligence, carelessness and negligence per se of Defendant Singer, Plaintiff Faye E. Dromeshauser has been or may in the future be deprived of the household services of her husband Plaintiff James Dromeshauser. WHEREFORE, Plaintiff Faye E. Dromeshauser hereby demands judgment in her favor and against Defendant Alvert C. Singer in an amount which ex,ceeds the jurisdictional limit requiring arbitration referral by local rule plus interests, costs, delay damages and such other remedies as this Court may deem just and reasonable. By: ----- ~, Esquire . Plaintiffs b" J-1/D5 Date: VERIFICA nON I, Faye Dromeshauser, hereby state that I am the Plaintiff in this Action and verify that the statements made in the foregoing document are true and oorrect to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa. e.s. Section 4904 relating to unsworn falsification to authorities. ;!~efJ:;~~ VERIFICATION I, James Dromeshauser, hereby state that I am the Plaintiff in this Action and verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. 1 understand that the statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. " GRAHAM & MAUER, P.C. By: Ronald M. Graham, Esquire Attorney J.D. 64483 The Commons at Valley Forge Suite 22, Box 987 Valley Forge, PA 19482 (6] 0)933-3333 JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, b/w : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2005-]494 Plaintiffs vs. AL VERT C. SINGER : CIVIL ACTION- LAW Defendants CERTIFICATE OF SERVICE: I, Ronald M. Graham, Esquire, hereby certify that on thi(]5J day of June, 2005, a true and correct copy of the foregoing Complaint was sent via first class US Mail, postage pre-paid to the following counsel of record: Brooks R. Foland, Esquire Thomas, Thomas & Hafer, LLP 305 North Front Street, 6'" Floor P.O. Box 999 Harrisburg, PA 17108 GRAHAM & UER,P.C. r By: '\( \ ~ aharn, Esquire o .';-:;: "::-;'" :~ '" C~ = c.n (- = ["'- I o -'1 ..... ::r: rn:D r- -om 0'[ =-j~,! .(---'1 9C1 Of11 ,4 ~ :0 _1: W .&:"" JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW ALVERT C. SINGER, Defendants CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas with copies of the subpoenas attached thereto was mailed or delivered to each party at least twenty (20) days in advance of this Certificate; 2. No objection to the subpoenas have been made; and 3. The subpoenas which will be served are identical to the subpoenas which are attached to this Notice. Respectfully submitted, - Date: L ,2/"1 -V ~ p B. BROO S R. FOLAND, ESQUIRE 305 N. Front Street, P.O. B Harrisburg, PA "1710 (717) 237-7141 Attomey for Defendant JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plain tiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-141~4 vs. CIVIL ACTION - LAW AL VERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Nationwide Insurance Company Attn: Claims Department 1000 Nationwide Drive Harrisburg, P A 171 05 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of the entire claims file concerning James Dromeshauser; DOB: 06/18/53: Policy No. 5837C6882l5 at: Thomas. Thornas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. P A 171 08-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing tile ~ngs sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE: m~ih ;21., ::l. ^^", Seal of e Court Deputy JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plain tiffs IN THE COURT OF COMMON PLEAS CUMBERLA.ND COUNTY, PENNSYLVANIA NO.2005-14!I4 vs. CIVIL ACTION - LAW ALVERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Carlisle Regional Medical Center Attn: Custodian of Records 246 Parker Street, P.O. Box 310 Carlisle, P A 17013 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of any and all medical records. medical reports. medical bills. diagnostic studies. notes. ambulance TRIP sheet. and correspondence concerning James Dromeshauser: DOB: 06/18/53 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together witll the certificate of compliance, to th,~ party making this request at the address listed above. You have the right to seek in advance, ~l1e reasonable cost of preparing the copies or producing tile things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE: fYl';;J~ ;:Jl,. J r:,c.5 Seal oft e Court '-- AND NOW, this CERTIFICATE OF SERVICE !2fl~y~~ , :;~005, I, Kate A. Wilhelm, a ---., Paralegal in the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by plac:ing a copy of the same in the United States Mail, first class, postage prepaid, to the following: Ronald M. Graham, Esquire Graham & Mauer, P.C. The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, PA 19482 fit1iJ Ka(e . Wilhe m, Paralegal ~ o ~? -,..~.^, ,.., n'\: --; ""'j \);. c; "5^" ,;'.:-.' ~::c: 'J:"C" -,,,. ::;; ~ '-- c .- I ......l 3. -0 :>: Q. ~ ",f2 -ol1:", -uO (.:J.b ...-,--r, :1:""!) 0- ---Q .,::-t.. t~3 10 '''' o ('0' ~ JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW ALVERT C. SINGER, Defendants CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas with copies of the subpoenas attached thereto was mailed or delivered to each party at least twenty (20) days in advance of this Certificate; 2. No objection to the subpoenas have been made; and 3. The subpoenas which will be served are ide~ntical to the subpoenas which are attached to this Notice. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP Date: 1-/;' /os BY:~ \ ~- BROOKS R. FOLAND, ESQUIRE 305 N. Front Street, P.O. Box 999 Harrisburg, PA 17108 (717) 237-7141 Attorney for Defendant JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW AL VERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Robert E. Sheep, M.D. Chambersburg Medical Building 120 North 7th Street, Suite 206 Chambersburg, P A 17201 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of any and all medical records. medical reports. medical bills. diagnostic studies. notes. and correspondence concerning James Dromeshauser: DOB: 06/18/53 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to tlu: party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108"0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant ~ DATE:Jlfil" q .::l~r Seal of the Court ~~~Q. prothonotary/Cle. r~ ivis'o/ ~o::,..&'P. ""f1~fL eputy JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-14'14 vs. CIVIL ACTION - LAW AL VERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Shippensburg Health Services Attn: Custodian of Records 46 Walnut Bottom Road Shippensburg, P A 17257 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of any and all medical records. medical reports. medical bills. dialffiostic studies. notes. and correspondence concerning James Dromeshauser: DOB: 06/18/53 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWlNG PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, HalTisburg, P A 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE:,j.,U.xz- 9 d.r.>OS Seal of the Couh B~HECO;j.2: ~ ./n;:t . . Pro~_/Cl~ ;'.i{i1~ ~ 0, f' f? ~ AA. 'f"'<-J eputy JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-14'~4 vs. CIVIL ACTlION - LAW AL VERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Neurological Specialists Attn: Custodian of Records 757 Norland Avenue, Suite 201 Chambersburg, P A 1720 I Within twenty (20) days after service of fuis subpoena, you are ordered by the court to produce the following documents or things: Complete copies of any and all medical records. medical reoorts. medical bills. diagnostic studies. notes. and correspondence concerning James Dromeshauser: DOB: 06/18/53 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have tile right to seek in advance, fue reasonable cost of preparing the copies or producing the tIlings sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE:JIJ ,v; ~ ~~ Seal of fue Court BY~/2COl.!RT. pr~otary/CI rk <:.... a, Deputy lsion -' JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW AL VERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENfS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Hershey Medical Center Attn: Custodian of Records P.O. Box 850 Hershey, P A 17033 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Cornplete copies of any and all medical records. medical reports. medical bills. diagnostic studies. notes. and correspondence concerning James Dromeshauser; DOB: 06/18/53 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, P A 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE:.... )I{'~ 9- )r~ Seal of the CoUrt "-:O~t::/Cler eputy JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO.2005-14!I4 vs. CIVIL ACTION - LAW ALVERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Wide Open MRI Attn: Custodian of Records 405 Phoenix Drive, Unit A Crossroads Park II Chambersburg, PA 17201 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of any and all medical records. medical reports. medical bills. diagnostic studies. notes. ambulance TRIP sheet. and correspondence I~oncerning James Dromeshauser: DOB: 06/18/53 at: Thornas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SLJ13POENA WAS ISSUED AT THE REQUEST OF TIlE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE:, J./.I>&:' 9 ~ r Seal of the Comt JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW ALVERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Chambersburg Pain Services 112 North 7th Street, P.O. Box 6005 Chambersburg, PA 17201 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete cODies of any and all medical records. medical reoorts. medical bills. dialmostic studies. notes. ambulance TRIP sheet. and correspondence concerning James Dromeshauser: DOB: 06/18/53 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to th<: party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order cornpelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE0/1Qf7 q.JDt:J ~ Seal of the Courl , Pro~~oltary/CI. ~ JAMESDROMESHAUSERand FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW AL VERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Kennefu Rictor, M.D. 3730 Scotland Road, P.O. Box 398 Scotland, P A 17354 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of any and all medical records. medical reports. medical bills. diagnostic studies. notes. ambulance TRIP sheet. and correspondence concerning James Dromeshauser; DOB: 06/18/53 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of cornpliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE:" J.u;>P q ")6tJ.S Seal of the Court' JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plain tiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW ALVERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Chambersburg Hospital Attn: Custodian of Records 112 North 7th Street Chambersburg, P A 17201 Within twenty (20) days after service of iliis subpoena, you are ordered by the court to produce the following documents or things: Complete copies of any and all medical records. medical renorts. medical bills. diagnostic studies, notes. ambulance TRIP sheet. and correspondence concerning James Dromeshauser: DOB: 06/18/53 at: Thomas. Thomas & Hafer, LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce iliings requested by this subpoena, together with the certificate of compliance, to the party making iliis request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, wiiliin twenty (20) days after its service, the party serving iliis subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Ni\ME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, P A 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE:" Ju..(;':::- q ..:vy..:><", Sear ofthe Co6ri CERTIFICATE OF SERVICE. AND NOW, this J1~ay ~ ' 2005, I, Kate A. Wilhelm, a Paralegal in the law firm of Thomas, Thomas & Hafer, LL.P, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, first class, postage prepaid, to the following: Ronald M. Graham, Esquire! Graham & Mauer, P.C. The Commons at Valley For~Je Suite 22, P.O. Box 987 Valley Forge, PA 19482 t1 Kate A. Wi! I ,Paralegal r1 ,,,> 0 c:~ c:--_) --n ,-,-, C._ ...... ..,.. (-~,,~ f;i'1# -~ r--: :"-, C.~' 0' G> ',} to) rn r:-? .' I - J1 :'0 , 0- .~ , JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plain tiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 VS. CIVIL ACTION - LAW AL VERT C. SINGER, Defendant JURY TRIAL DEMANDED NOTICE TO PLEAD You are hereby notified to plead to the enclosed Defendant's Answer With New Matter within twenty (20) days from service hereof or a default judgment may be entered against you. DEFENDANTS ANSWER WITH NEW MATTER AND NOW, comes Defendant, Alvert C. Singer, by and through his counsel Thomas, Thomas & Hafer, LLP and files the following Answer With New Matter to Plaintiff's Complaint in support thereof avers as follows: 1. Denied. Defendant is without information or belief as to the truth of the averments of paragraph 1 of Plaintiffs' Complaint and the same are therefore denied and proof thereof is demanded at time of trial. 2. Admitted. 3. Admitted based upon information and belief. 4. Admitted. 5. Denied as stated. It is admitted only that Defendant attempted to make a left hand turn from Marsh Drive onto State Route 34 at or before the time of the collision. Any and all other allegations contained in paragraph 5 are specifically denied and strict proof thereof is demanded at time of trial. 6. Admitted. 7. Denied as stated. It is admitted only that the vehicles being driven by Plaintiff and Defendant collided in the intersection of Marsh Drive and State Route 34. Any and all other allegations contained in paragraph 7 are specifically denied and strict proof thereof is demanded at time of trial. 8. Denied. Defendant is without information or belief as to the truth of the averments of paragraph 8 of Plaintiffs' Complaint and the same are therefore denied and proof thereof is demanded at time of trial. COUNT I - NEGLIGENCE PLAINTIFF JAMES DROMESHAUSER V. ALVERT C. SINGER 9 The Defendant incorporates by reference the answers to Plaintiffs' Complaint as though the same are fully set forth at length herein. 10. (a-r) Denied. The allegations set forth in paragraph 10 are conclusions of law to which no response is required and/or are denied pursuant to Pa.R.C.P. 1029(e). 11. Denied. The allegations set forth in paragraph 11 are conclusions of law to which no response is required and/or are denied pursuant to Pa.R.C.P. 1029(e). 12. Denied. Defendant is without information or belief as to the truth of the averments of paragraph 12 of Plaintiffs' Complaint and the same are therefore denied and proof thereof is demanded at time of trial. 13. Denied. The allegations set forth in paragraph 13 of Plaintiffs' Complaint are conclusions of law to which no response is required and/or are denied pursuant to PaRC.P. 1029(e). 2 14. Denied. The allegations set forth in paragraph 14 of Plaintiffs' Complaint are conclusions of law to which no response is required and/or are denied pursuant to Pa.R.C.P. 1029(e). 15. Denied. The allegations set forth in paragraph 15 of Plaintiffs' Complaint are conclusions of law to which no response is required and/or are denied pursuant to Pa.R.C.P. 1029(e). 16. Denied. The allegations set forth in paragraph 16 of Plaintiffs' Complaint are conclusions of law to which no response is required and/or are denied pursuant to Pa.R.C.P. 1029(e). 17. Denied. The allegations set forth in paragraph 17 of Plaintiffs' Complaint are conclusions of law to which no response is required and/or are denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendant, Alvert C. Singer, respectfully requests that judgment be entered in his favor and against Plaintiffs, James Dromeshauser and Faye E. Dromeshauser. COUNT II - NEGLIGENCE INFLICTION OF EMOTIONAL DISTRESS FAYE E. DROMESHAUSER V. ALVERT C. SINGER 18. The Defendant incorporates by reference the answers to Plaintiffs' Complaint as though the same are fully set forth at length herein. 19. Denied as stated. It is admitted only that based upon information and belief Plaintiff, Faye E. Dromeshauser, was a passenger in the vehicle being operated by her husband, Plaintiff James Dromeshauser, at the time of the collision on or about June 1, 2003. Any and all other allegations contained in 3 paragraph 19 are specifically denied and strict proof thereof is demanded at time of trial. 20. Denied. Defendant is without information or belief as to the truth of the averments of paragraph 20 of Plaintiffs' Complaint and the same are therefore denied and proof thereof is demanded at time of trial. 21. Denied. The allegations set forth in paragraph 21 are conclusions of law to which no response is required and/or are denied pursuant to Pa.R.C.P. 1029(e). 22. Denied. The allegations set forth in paragraph 22 are conclusions of law to which no response is required and/or are denied pursuant to Pa.R.C.P. 1029(e). 23. Denied. The allegations set forth in paragraph 23 are conclusions of law to which no response is required and/or are denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendant, Alvert C. Singer, respectfully requests that judgment be entered in his favor and against Plaintiffs, James Dromeshauser and Faye E. Dromeshauser. COUNT III - LOSS OF CONSORTIUM PLAINTIFF FAYE E. DROMESHAUSER V. ALVERT C. SINGER 24. The Defendant incorporates by reference the answers to Plaintiffs' Complaint as though the same are fully set forth at length herein. 25. Denied. Defendant is without information or belief as to the truth of the averments of paragraph 25 of Plaintiffs' Complaint and the same are 4 therefore denied and proof thereof is demanded at time of trial. 26. Denied. The allegations set forth in paragraph 26 are conclusions of law to which no response is required and/or are denied pursuant to Pa.R.C.P. 1029(e). 27. Denied. The allegations set forth in paragraph 27 are conclusions of law to which no response is required and/or are denied pursuant to Pa.R.C.P. 1029(e). 28. Denied. The allegations set forth in paragraph 28 are conclusions of law to which no response is required and/or are denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, Defendant, Alvert C. Singer, respectfully requests that judgment be entered in his favor and against Plaintiffs, James Dromeshauser and Faye E. Dromeshauser. NEW MATTER 29. The Defendant incorporates by reference the answers to Plaintiffs' Complaint as though the same are fully set forth at length herein. 30. Some or all of Plaintiffs' claims may be barred by the expiration of the applicable statute of limitations. 31. Some of all of Plaintiffs' claims may be barred or reduced by Plaintiffs' own comparative and/or contributory negligence. 32. Some or all of Plaintiffs' claims, injuries and/or damages, if any, may be barred or reduced by the applicable provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 5 33. Some or all of Plaintiffs' damages and/or injuries may be barred or reduced by Plaintiffs' selection of the limited tort option under their personal auto insurance policy. 34. Some or all of Plaintiffs' damages and/or injuries, if any, may have been caused by parties other than answering Defendant. 35. Some or all of Plaintiffs' damages and/or injuries, if any, may have been pre-existing and not caused by the subject motor vehicle accident. WHEREFORE, Defendant, Alvert C. Singer, respectfully requests that judgment be entered in his favor and against Plaintiffs, James Dromeshauser and Faye E. Dromeshauser. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP by: ~-.-/- '\~c~ Brooks R. Foland, Esquire I.D.No.70102 / 305 North Front ~t, 6th Floor POB 999 Harrisburg, PA 17108-0999 (717) 255-7626 ~ ---=> Attorneys for Defendant 370126.1 6 VERIFICATION I, Alvert C. Singer, have read the foregoing Answer with New Matter and hereby affirm that it is true and correct to the best of my personal knowledge, information and belief. This Verification and statement is made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities; I verify that all the statements made in the foregoing are true and correct and that false statements may subject me to the penalties of 18 Pa.C.S. 94904. Ai? -:df!f......, .'.~~, .7 . ;" --:'/"- . -_/">~~" C"'-::- ---,' ,...:, /./<A~/~C. Singer DATE: --,I ~ - / - ') /', '- C? < /' '.../ --:} 7 CERTIFICATE OF SERVICE Q..j.L AND NOW, this 0 day of August, 2005, I, Jennifer C. Anthony, Legal Secretary, of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I sent a true and correct copy of the foregoing document by placing a copy of the same in the United States Mail, postage prepaid, to the following: Ronald M. Graham, Esq. Graham & Mauer, P.C. The Commons at Valley Forge Suite 22 POB 987 Valley Forge, PA 19482 ~L~ Jennifer . Anthony <t 8 ", f.;-; .<' r-.~ ':"-2: ~~~ ~) :t., _...1 ~ --I -< () ~:~ (-ii ....., = = c.ro ". c: "') o -n :r~ ~~-'" ~::, :J _~:Il C).1J -:....0 c'im 'i>! :D -< ..,., ::i r:Y .::- o GRAHAM & MAUER, P.C. By: Ronald M. Graham, Esquire Attorney J.D. 64483 The Commons at Valley Forge Suite 22, Box 987 Valley Forge, PA 19482 (610)933-3333 JAMES DROMESHAUSER and F AYE E. DROMESHAUSER, h/w : IN 1HE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2005-1494 Plaintiffs vs. ALVERT C. SINGER : C~ ACTION- LAW Defendants PLAlNTlFFS' REPLY TO DEFENDANT'S NEW MATTER 29. No response required. 30. Denied. Answering Plaintiffs are advised by counsel and, therefore, aver that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. To the extent, however, a reply may be required, Plaintiffs specifically deny that any of their claims are or may be barred by the expiration of the applicable statute of limitations. To the contrary, Plaintiffs' action was timely filed and served. 31. Denied. Answering Plaintiffs are advised by counsel and, therefore, aver that the allegations contained in the corresponding paragraph of the Defomdant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. To the extent, however, a reply may be required, Plaintiffs specifically deny that any of their claims may be or are barred by or reduced by Plaintiffs own comparative and/or contributory negligence. To the contrary, all of Plaintiffs' claims are based solely upon the carelessness and negligence of Defendant as set forth in Plaintiffs' Complaint which is incorporated herein by reference:. 32. Denied. Answering Plaintiffs are advised by counsel and, therefore, aver that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. To the extent, however, a reply may be required, Plaintiffs specifically deny that any of their claims, injuries and/or damages may be or are barred or reduced by the applicable provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. To the contrary, Plaintiffs are entitled to n:covery under the full tort provision of that law. 33. Denied. Answering Plaintiffs are advised by counsel and, therefore, aver that the allegations contained in the corresponding paragraph of the Defendant's New Matter are automatically deemed denied as conclusions oflaw to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. To the extt:nt, however, a reply may be required, Plaintiffs specifically deny that Plaintiffs damages and/or injuries may be barred or reduced by Plaintiffs' selection of the limited tort option under their personal auto insurance policy . To the contrary, Plaintiffs are entitled to recover under the full tort option of the Pennsylvania Motor Vehicle Insurance Law. 34. Denied. Answering Plaintiffs are advised by counsel anc~ therefore, aver that the allegations contained in the corresponding paragraph of the Deft:ndant's New Matter are automatically deemed denied as conclusions of law to which no responsive pleading is required. Strict proof thereof is demanded at trial, if material. By way of further answer, Plaintiffs, after reasonable investigation, presently lack sufficient knowledge and/or information to admit or deny the remaining allegations contained in the corresponding paragraph of Defendant's New Matter. 35. Denied. Plaintiffs specifically deny that some or all of Plaintiffs' damages and/or injuries may have been or, in fact, were pre-existing and not caused by the subject motor vehicle accident. To the contrary, all claims for damages and injuries advanced by Plaintiffs in their Complaint were proximately caused by the carelessness and negligence of the named Defendant. WHEREFORE, Plaintiffs respectfully request that This Honorable Court enter judgment in their favor and against Defendant Alvert C. Singer. By: // Date: '8 / ') 7, 'D J VERIFICATION L Faye Dromeshauser, hereby state that I am the Plaintiff in this Action and 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 the statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Ja~-€- l)/l{J"Y1LP/J~ Faye DromeshaUSl::r VERIFICATION L James Dromeshauser, hereby state that I am the Plaintiff in this Action and 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 the statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. GRAHAM & MAUER, P.c. By: Ronald M. Graham, Esquire Attorney I.D. 64483 The Commons at Valley Forge Suite 22, Box 987 Valley Forge, PA 19482 (610)933-3333 JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, h/w : IN 1HE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2005-1494 Plaintiffs vs. ALVERT C. SINGER : C~ ACTION.. LAW Defendants CERTIFICATE OF SERVICE I, Ronald M. Graham, Esquire, hereby certifY that on this 1-- J day of August, 2005, a true and correct copy of the foregoing Plaintiffs' Replv to Deferldant's New Matter was sent first class, US Mail, postage pre-paid to the following counsel of record: Brooks R. Foland, Esquire Thomas, Thomas & Hafer, LLP 305 North Front Street, 61h Floor P.D. Box 999 Harrisburg, PA 17108 By: & MAUER, P.C. .------. . Graham, Esquire () c r":> ~2~5 c.T' (0 ,'.j '..->':J \ Q, .-' ~j: -,1- ~~ti\ ~J) ....:~ '~:>, (') ~- -C1 ."" J.C-) '~:""n\ "~I. ',Jt -.,'. (::? -.- - - JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 2005-1494 vs. CIVIL ACTION - LAW ALVERT C. SINGER, Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQmSITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas with copies of the subpoenas attached thereto was mailed or delivered to each party on or about August 18, 2005, to serve subpoenas; 2. Plaintiff does not object to the subpoena and waives the Notice of Intent to Serve a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21. A copy of a letter dated August 31,2005 to Ronald Graham, Esquire confirming his waiver of the notice of intent is attached to this Certificate; 3. The subpoenas which will be served are identical to the subpoenas which are attached to this certificate. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP by: Date: r- 2.-of Brooks R. 0 I.D. No. 70102 305 North Front Street, 6th Floor PO Box 999 Harrisburg, PA 17108-0999 (717) 255-7626 JAMES DROMESHAUSER and FAYE E. DROMESHAUSER. Plain tiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW AL VERT C. SINGER. Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CIGNA, P.O. Box 22325, Pittsburgh, PA 15222-0325 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all wage information. disabilitv slips. disciplinarv actions. short and long term disabilitv policies. documentation regarding pavment of premiums for disability benefits. medical records. claim notices. correspondence. documents. etc.. including but not limited to. vour entire file pertaining to James Dromeshauser; DOB: 06/18/53 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE: flu;}",.:;} ~':}A<:l , Seal of e Cou BY THE COURT: Deputy JAMESDROMESHAUSERand FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW ALVERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dr. Peter Pahapill 4310 Londonderry Road Harrisburg, P A 17109 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all medical records. medical reports. medical bills. diagnostic studies. notes. and correspondence concerning James Dromeshauser: DOB: 06/18/53: SSN 156- 48-1199 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE:!Ju'l .;1.2, ...;)~c; Seal 0 the Court /--:7 1 Prothonotary/Clerk, Civil Div'Ision BY THE COURT: Deputy JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW ALVERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dr. Braun 175 Lancaster Boulevard Mechanicsburg, P A 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all medical records. medical reoorts. medical bills. diagnostic studies. notes. and correspondence concerning James Dromeshauser: DOB: 06/18/53: SSN 156- 48-1199 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE: !Ju~, ~ ,JADe; Seal of he Co BY THE COURT: Deputy JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW AL VERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Telcove, 5095 Ritter Road, Mechanicsburg, P A 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all emplovrnent records. wage information. disabilitv slips. disciplinary actions. short and long term disabilitv policies. health insurance policv. documentation regarding pavrnent of premiums for disabilitv policies. medical records. claim notices. correspondence. documents. etc.. including but not limited to. vour entire file pertaining to James Dromeshauser; DOB: 06/18/53 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE: Hut,. ~.~ I :::)I"Y':;' \' Seal 0 the Court Deputy CERTIFICATE OF SERVICE I, Kate A. Wilhelm, paralegal of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing document on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Ronald M. Graham, Esquire Graham & Mauer, P.C. The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, PA 19482 THOMAS, THOMAS & HAFER, LLP Date: If /7 /Oz;- f {-' <1 c::. -~ .... -oU;l a:; t:-~ ~;;i--. tJ,''J.:. ~C., :r>C) ?':'C J>'<; ::;l ~ (/) ~ ~ ~?:; - :g Cj? Ul o.Q -'~ ~~, (5.((\ "" <fi 0' J.:. o ...., :y. <:? JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW ALVERT C. SINGER, Defendant JURY TRIAL DEMANDED CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant certifies that: 1. A Notice of Intent to Serve Subpoenas with copies of the subpoenas attached thereto was mailed or delivered to each party on or about August 31, 2005, to serve subpoenas; 2. Plaintiff does not object to the subpoena and waives the Notice of Intent to Serve a Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21. A copy of a letter dated September 16, 2005 from counsel for Plaintiff, Ronald Graham, Esquire, confirming his waiver of the notice of intent is attached to this Certificate; 3. The subpoenas which will be served are identical to the subpoenas which are attached to this certificate. Respectfully submitted, by: THOMAS, T~R. LLP ~~-~ Brooks R. FOland,<ESqU;;" ~ I.D. No. 70102 305 North Front Street, 6th Floor PO Box 999 Harrisburg, PA 17108-0999 (717) 255-7626 Date: 1- fl. ~ r U") GRAHAM & MAUER, P.C. AtTORNEY.AT.LAW THE COMMONS AT V ALLI!:Y foRGE SVmI: n, P.D. Box'87 VALLEY FORGEo PA 19481 RONALD M. GitAHAM uSAJ.MA_' (610) 93~JJ33 1.-.2111-O8ll8 FAX (610)9113-0570 1136SUMMHRWOOODRI~ IiARIUSBlJRc, PA.17111 (717) 24O-<<lOO (717)652.1200 .u.m MlJ,lADSCW fIIPI' 2JXY.Io\A .M.urJ!IlOP'&mHEIS~TlOIrf Sent via fax,only to 717-237-7105 September 16, 2005 Kate Wilhelm, Paralegal Thomas, Thomas & Hafer, LLP 305 North Front Street, 6'" Floor P.O. Box 999 Harrisburg, PA 17108 RE: Dromcshauserv. SingeT Cumberland County CCP No: 2005-1494 Your File No: 426-50718 Dear Ms. Wilbelm: I am writing in response to your letter dated August 31, 2005, wherein you request our office to waive the 20-day requirement for serving Subpoenas on the following medical providers: . . Dr. Brian Holmes William Haran, M.D. . Valley Hospital Hospital of Joint Diseases (2 locations) . . Please be advised that I am agreeable to waiving the 20-day requirement fOT service of these Subpoenas. Please allow this letter to also serve as a request that you provide me with all records Subpoenaed in this matter. Ronal G . Thank you. RMG:tmf rd S0l:LLE2LJ: LJ: : 01 :WO<lJ 8E:60 S002-61:::-d3S JAMES DROMESHAUSER and FAYE E. DROMESHAUSER., Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW ALVERT C. SINGER., Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Hospital of Joint Diseases 541 Lexington Avenue New York, NY 10022 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all medical records. medical reports. medical bills. dialmostic studies, notes, and correspondence concerning James Dromeshauser; DOB: 06/18/53 at: Thomas, Thomas & Hafer, LLP. 305 N. Front St., P.O. Box 999. Harrisburg, PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, P A 17108-0999 TELEPHONE: (717) 237- 71 00 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant \1 DATE:. p~~ ~ Seal 0 the Co Deputy JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 VS. CIVIL ACTION - LAW ALVERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Hospital of Joint Diseases 301 East 17th Street New, NY 10003 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of any and all medical records. medical revorts. medical bills, diagnostic studies. notes, and correspondence concerning James Dromeshauser; DOB: 06/18/53 at: Thomas. Thomas & Hafer, LLP, 305 N. Front St.. P.O. Box 999. Harrisburg, PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717)237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant ~) BY THE COURT: DATE: ~ bl'rl-. I f:tt ;:)~c; ~e Co Isio Deputy JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 VS. CIVIL ACTION - LAW ALVERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Hospital of Joint Diseases [20 East 39th Street New, NY 10016 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of any and all medical records. medical reports. medical bills. diagnostic studies. notes. and correspondence concerning James Dromeshauser; DOB: 06/18/53 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant l DATE:~p--I.... / ~, d.tY~ Seal oflthe Court Prothonotary/Clerk, Civi Deputy JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 VS. CIVIL ACTION - LAW ALVERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: William E. Haran, M.D. 767 Fifth Avenue #1 Chambersburg, PA 17201-1282 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Comolete copies of anv and all medical records. medical reports. medical bills. diagnostic . studies. notes, and corresoondence concerning James Dromeshauser; DOB: 06/18/53 at: Thomas. Thomas & Hafer, LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717)237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE: ~E:i:rl- J S' c?!Y\S Seal of the Court' Deputy BY THE COURT: JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 vs. CIVIL ACTION - LAW AL VERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: VaHey Hospital 223 North V:m Di,;m Avenue Ridgewood, NJ 07450 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all medical records. medical reports. medical bills. diagnostic studies. notes. and correspondence concerning James Dromeshauser: DOB: 06/18/53 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St.. P.O. Box 999. Harrisburg. PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999, Harrisburg, PA 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE: \)~t J!; ,JIYJ...$ Seal 0 the Court I BY THE COURT: Prothonotary/Clerk, Ci Deputy JAMES DROMESHAUSER and FAYE E. DROMESHAUSER, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-1494 VS. CIVIL ACTION - LAW AL VERT C. SINGER, Defendants SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Dr. Brian Holmes 1150 Professional Court, Suit<~ C Hagerstown, MD 21740 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Complete copies of anv and all medical. records, medical reports. medical bills. diagnostic studies, notes. and correspondence concerning James Dromeshauser: DOB: 06/18/53 at: Thomas. Thomas & Hafer. LLP. 305 N. Front St., P.O. Box 999. Harrisburg, PA 17108-0999. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Brooks R. Foland, Esquire ADDRESS: P.O. Box 999. Harrisburg, P A 17108-0999 TELEPHONE: (717) 237-7100 SUPREME COURT ID#: 70102 ATTORNEY FOR: Defendant DATE: ~ \t.-;-,-J, I.~ ~/v~S Seal ofltl; Court I Deputy BY THE COURT: Prothonotary/Cle CERTIFICATE OF SERVICE I, Kate A. Wilhelm, paralegal of the law firm of THOMAS, THOMAS, & HAFER, LLP do certify that I served the foregoing document on the following person(s), by depositing the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania addressed as follows: Ronald M. Graham, Esquire Graham & Mauer, P.C. The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, PA 19482 THOMAS, THOMAS & HAFER, LLP Date: f!Wjo)' ~ Kate A. Wilhelm, Paralegal () ~~::-~ ...., c:::> <"""7 c.r"l \~! C"J -.."j. I CJ" o -n :? 1 ";"i ?~ <0 ) \ --' ~~ GRAHAM & MAUE~ P.C. By: Ronald M. Graham, Esquire Attorney ID # 64483 The Commons at Valley Forge Suite 22, P.O. Box 987 Valley Forge, PA 19482 610-933-3333 Attorney for Plaintiff JAMES DROMESHAUSER, and FAYE DROMESHAUSER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY vs, : NO.: 2005-1494 : CIVIL MATTER AL VERT C. SINGER Defendant PRAECIPE TO SETILE. DISCONTINUE & END TO THE PROTHONOTARY: Kindly mark this matter SETTLED, DISCONTINUED AND ENDED. GRAHAM & MAUER, P.c. By: Date: 2_- ff...--()6 .,\ '''!. r<: (_n \,.'j