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Home My WebLink About01-4590PHON~ (717~ 933-8757 FAX (717) 233-5860 ATTORNEY AT LAW 126,.,~.¢,~ STREET HARRISBURG, PA 17101 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. i?i- ~1 5'~0 20,'~ Civil Action - ( X ) Law ( ) Equity. ROLAND WILLIAMS, III and his wife, LISA M. WILLIAMS 2440 BEECH STREET HARRISBURG, PA 17110, Plaintiffs : vs. : : AMY M. WILSON RD 1 BOX 101 KITTANNING, PA 16201, Defendant JURY TRIAL DEMA~NDED PRAECIPE FOR WRIT OF SUMNIONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. X JOSEPH J. DIXON. ESOUIRE 126 STATE STREET __ Writ of Summons shall be issued and for~varded to ( )Attorney (X)Sheriff Signature of A-lt-C'mey HARRISBURG PA 17101 (717)236-8515 Names/Address/Telephone No. Of Attorney Supreme Court ID No. 28290 Date August 1. 2001 WRIT OF SUMMONS TO THE ABOVE-NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. Date: August 1, 2001 ProtbonotaW ~' by ~,~..,,~ ~jt, I 't~.~. ). / Deputy ( )Chcck here if reverse is issued for additional information. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-04590 p COMMONW~EALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WILLIAMS ROL;LND III ET AL VS WILSON AMy M R. Thomas Kline , Sheriff or Deputy Sheriff who being duly Sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: WILSON AMY M but was unable to locate Her in his bailiwick. deputized the sheriff of ARMSTRONG County, serve the within WRIT OF SUMMONS He therefore Pennsylvania, to On Au u__~g_~_~ 17th , 2001 , this office was in receipt of the attached return from ARMSTRONG Sheriff,s Costs: Docketing Out of County Surcharge Armstrong County 18.00 9.00 10.00 27.50 .00 64.50 08/17/2001 JOSEPH DIXON Sworn and subscribed to before me this /?~ day of _ ~,~t A.D. ! / Prothonotary Sheriff of Cumberland County SHERIFF'S RETURN - REGULAR CASE N~: 20~1-04590 T COMMONWEALTH OF PENNSYLVANIA: COUNTY OF Armstrong County ROLAND WILLIAMS III ET AL VS AMY M WILSON AI~ D TARR , Sheriff or Deputy Sheriff of /%rmstrong County , Pennsylvania, who being duly sworn according to law, says, the within PRAECIPE FOR WRIT as served upon WILSON AMYM the DEFENDANT , at ~010:50 Hour, on the l~0th day of August at RD 1 BOX 101 , 2001 .KITTANNINGr PA 16201 , /krmstrong County Pennsylvania, by handing to RUSSELL L WILSON FATHER a true and attested copy of the PRAECIPE FOR WRIT ; and at the same time directing _His attention to the contents thereof. Sheriff's Costs: Docketing 9.00 Service 9.00 Affidavit 2.00 Surcharge .00 7.50 Y Crawf~Sfler/'ff 27.50 08/06/2001 Sworn and subscribed to before me -' P y heriff this~ay of /~,~ ,~/ A.D. o)~ry ' /- I PATTY J, KREIDER, NO1-ARy PUBUC ' ! KITTANNING OORO ARMSTRONG CO ('-'/ · MY COMMISSION EX~IRES 0C1: III 20~)4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL ACTION - LAW ROLAND WILLIAMS, III and his wife, LISA M. WILLIAMS, Plaintiffs AMY M. WILSON, Defendant PENNSYLVANIA TO: Curtis R. NO. 01-4590 2001 JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT Long, Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387 Please enter a Rule upon the Plaintiffs to file a Complaint in the above captioned matter within twenty (20) days of the Rule or suffer a judgment of non pros. EAGER, REINAKER & SPINELLO BY:Geo~Esquire Attorney ~o~__efendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 AND NOW, this ~day of F~40~%~-/~ , 2001, a Rule has been entered upon the Plaintiff as above directed. ~/~P~ro~t ~on-ot a~a~ CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for a Rule to File a Complaint upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 EAGER, REINAKER & SPINELLO BY: I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 EAGER, REINAKER, & SPINELLO ATTORNEYS AT LAW 1347 FRUITVILLE PIK~ LANCASTER, PEf~NSYLVANIA 17601 PHONE (717) 290-7971 FAX (717) 290-7978 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROLAND WILLI/LMS, III and : his wife, LISA M. WILLI/kMS, : Plaintiffs : AMY M. WILSON, : Defendant : NO. 01-4590 2001 JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of George H. Eager of the Law Firm of Eager, Reinaker & Spinello as attorney of record on behalf of Defendant in the above captioned action. EAGER, REINAKER & SPINELLO BY: Attorney~o~ Defendant I.D. No/~z7740 1347 F~ttville Pike Lancaster, PA 17601 (717) 290-7971 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the fore§oing Praecipe for Entry of Appearance upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 EAGER, REINAKER & SPINELLO 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 PHONE (717) 233-8757 12~ STATE ~TREET FAX,(717) 233-5860 HARRISBURG, PA 17101 ATTORNEY AT LAW ROLAND WILLIAMS, II1 and his wife, LISA M. WILLIAMS, Plaintiffs AMY M. WILSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 01-4590 2001 CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, nsted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la torte en forma escrita sns defensas o sus objeciones a las demandas en contra de su persona. Sea avisado gue si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier hueja o alivio gue es pedido en la peficion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para nsted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME FOR TELEFONO A LA OFIC1NA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 /~6seph J. Dixon, Esquire Attorney ID No. 28290 126 State Street Harrisburg, PA 17101 (717) 236-8515 Attorney for Plaintiffs At aforesaid time and place, the Defendant attempted to make a left hand turn from the fight-hand lane and onto Locust Point Road. At said time and place, the Defendant, while making a left-hand mm from the right-hand lane drove her motor vehicle into the Plaintiff's motor vehicle causing the damages described herein. Said collision was due to the negligence and carelessness of the Defendant which includes but is not limited to the following: (a) failure to make a left-hand mm from the proper lane. (b) failure to wait for traffic to clear before making a left-hand mm. (c) failure to make a turn from the proper lane. (d) operating a motor vehicle at an excessive speed under the circumstances. (e) failure to keep a motor vehicle under control. (f) failure to keep proper watch for traffic on the highway. (g) failure to keep alert for the presence of other motor vehicles on the highway. Ca) driving a motor vehicle upon a highway in a manner endangering persons and property in a reckless manner with careless disregard to the rights and safety of others violating the Motor Vehicle Code of the Commonwealth of Pennsylvatfia. Said collision was in no way caused by the actions or conduct of the Plaintiff. As a sole and proximate cause of the accident, the Plaintiff has sustained painful and severe injuries which include but are not limited to: lumbosacral strain sprain, cervical strain sprain, left wrist strain sprain, right ankle strain sprain, thoracic strain sprain, aggravation of low back condition which was previously operated upon, left shoulder sprain, headaches, impairment syndrome of the cervical spine and permanent residual pain pattern symptoms of the cervical 11. 12. 13. 14. 15. spine. By reason of aforesaid injuries sustained by the Plaintiff, Rolland Williams, he has been fomed to incur liability for medical txeatments, medications and similar expenses in an effort to restore himself to health. The total amount of these expenses are unascertained at this time. The Plaintiff has been advised and therefore avers that he will need additional medical care and incur future additional medical expenses. The total nature and amount of these expenses are unascertained at this time. As a result of aforesaid injuries, the Plaintiff has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out daily activities and a loss of life's pleasures and enjoyments. As a result of aforesaid injuries, the Plaintiff continues to be plagued by persistent pain and limitations and therefore avers that his injuries are permanent in nature causing residual problems the remainder of his life. As a result of said injuries, the Plaintiff has suffered a substantial inconvenience in his life and a decrease in the quality of his life. WHEREFORE, the Plaintiff prays this Honorable Court enter judgment against the Defendant in the amount of Twenty Five-Thousand Dollars ($25,000.00), which is an amount in excess of the amount requiring compulsmy arbitration. COUNT 1 LISA h/L WILLIAMS ¥. AMY ~L WILSON 16. Paragraphs 1 through 15 of the Plaintiff's Complaint are incorporated herein by reference and made a part hereof. 3 17. As a result of said injuries sustained her husband, Lisa M. Williams, has been and will be deprived of the assistance, companionship, consortium and society of her husband, all of which has been and will be to her great loss and detriment. WHEREFORE, Plaintiffs pray tiffs Honorable Court enters judgement against the Defendant in an amount in excess of Twenty Five-Thousand ($25,000.00) Dollars, which is an amount in excess of the amount requiring compulsory arbitration. Respectfully submitted, Dated: September 25, 2001 By: ~xon, Esquire Attorney ID No. 28290 126 State Street Harrisburg, PA 17101 (717) 236-8515 Attorney for Plaintiffs VERIFICATION are true and correct. I understand that false statements herein are made subject to the penalty of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document by depositing the same in the United States mail, First Class, postage prepaid, at the following address(es): EAGER, REINAKER & SP1NELLO ATTENTION: GEORGE It. EAGER, ESQUIRE 1347 FRUITVILLE PIKE LANCASTER, PA 17601 By J~OSi~PH j. D~~ ,/' 126 STATE STREET HARRISBURG, PA 17101 (717) 236-8515 ATTORNEY FOR PLAINTIFFS Date: September 25, 2001 EAGER, REINAKER, & SPINELLO ATTO R ,~-.V~ ~T ~.AW 1347 FRUITVILLE PIKE LANCASTER, PENNSYLVANIA 17601 PHONE (717) 290-7971 FAX (717) 290-7978 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL ACTION - LAW ROLAND WILLIAMS, III and : his wife, LISA M. WILLIAMS, : Plaintiffs : Vo AMY M. WILSON, PENNSYLVANIA NO. 01 4590 2001 JURY TRIAL DEMANDED Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served an original of Interrogatories of Defendant Addressed to Plaintiffs upon the person set forth below and in the manner indicated: First class mail, postage pre paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 EAGER, REINAKER & SPINELLO DATE: BY:George Esquire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 EAGER, REINAKER, & SPINELLO ATT~T I~W 1347 FRUI~/ILLE PiKE LANCASTER, PEHNSYLVANIA 17601 PHONE (717) 290-7971 FAX (717) 290-7978 IN THE COURT OF COHMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROLAND WILLIAMS, III and : his wife, LISA M. WILLIAMS, : Plaintiffs : AMY M. WILSON, Defendant NO. 01 4590 2001 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of Defendant's Request for Production and Copying of Documents Set No. 1 Directed to Plaintiffs upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 EAGER, REINAKER & SPINELLO DATE: George ~d Eager~ Esquire Atterney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 {717) 290-7971 EAGER, REINAKER, & SPINELLO ATTORNEYS AT LAW 1347 F.u~i ¥1LLE PIKE LANCASTER, PENNSYLVANIA 17601 PHONE (717) 290-7971 FAX (717) 290-7978 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL ACTION - LAW ROLAND WILLIAMS, III and : his wife, LISA M. WILLIAMS, : Plaintiffs : NO. 01-4590 2001 AMY M. WILSON, : JURY TRIAL DEMANDED Defendant ANSWER AND NOW COMES DEFENDANT AMY M. WILSON, BY AND THROUGH HER ATTORNEY, GEORGE H. EAGER, AND FILES THE FOLLOWING ANSWER: 1.- 4. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e) . 5. Admitted. 6. 15. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e) . WHEREFORE, Defendant asks that judgment be entered in her favor and against the Plaintiffs' Complaint. LISA M. Plaintiffs' on all claims set forth in COUNT I WILLIAMS v. AMY M. WILSON PENNSYLVANIA 16. Paragraphs 1 through 15 inclusive above are incorporated herein by reference and made a part hereof. 17. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e) . WHEREFORE, Defendant asks that judgment be entered in her favor and against the Plaintiffs' on all claims set forth in Plaintiffs' Complaint. EAGER, REINAKER & SPINELLO George H./Eage~, Esquire Attorney for ~efendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 VERIFICATION I, AMY M. WILSON, hereby verify that I am the Defendant in the foregoing action, and that the averments of the foregoing Answers to Plaintiff's Complaint are true and correct to the best of my knowledge, information and belief. To the extent that any of the averments of the Answers to the Complaint are based upon an understanding or application of law, I have relied upon counsel in making this Verification. I understand that I am subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities for any false statements made herein. / CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Answer upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 EAGER, REINAKER & SPINELLO BY: .e/~Ea~e~/--~squire ~e~y'foree~fen~ant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROLAND WILLIAMS, III, and His Wife, LISA M. WILLIAMS, Plaintiffs AMY M. WILSON, Defendant NO. 01-4590-2001 CERTIFICATE PREREQUISITE TO SERVICE OF A sUBpoENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant certify that: (1) (2) (3) (4) a notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, no objection to the subpoena has been received, and the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: George M. Ea~er,~Esquire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL ACTION - LAW ROLAND WILLIAMS, III, and : His Wife, LISA M. WILLIAMS, Plaintiff : NO. VS. : AMY M. WILSON, : Defendant : 01-4590-2001 PENNSYLVANIA NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT AMY M. WILSON 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. GEOR~~ GE H. EAGE/~ ,~ESQUIRE ATTORNEY FOR DEFENDANT COM1VIO~TH OF PENNSYLVANIA COUNTY OF CUM~ERI.~D ROLAND WILLIAMS, III, and his wife, LISA M. WILLIAMS, Plaintiff VS. AMY M. WILSON, Defendant File.No. 01-4590-2001 To: SUBPOENA TO PRODUCE DO~ OR' THIN'C~S FOR DISCOVERY PURSUANT TO RULE 4009 ~. Erie Insurance Group, P.O. Box 2013, Mechanicsburg, PA 17055 W'~hin twenty (20) days after set. ce of this subpoena, you are ordered by the court to produce thefoflow~mgdocumexrtsor~: first party records concerning Plaintiff Roland Williams, III (DOB: t0/3/54) (SSN: 208-42-6999) (Policy No. Q08 180b123 H) ~t 1347 Fruitville Pike~ Lancaster~ Pennsylvania, 17601. (Address) you may deliver or mail legible copies of the doonnents or produce things requested by this snbpo~ together with the certificate of compliance, to the p~, ty mnirlnoo thi~ request at the address listed ~bove. You have the right to seek in advnnce the rensonable cost of preparing the cop/es or producing the th/ngs sought If you fail to produc~ the doc-ments or things required by this subpoena within twenty (20) days after its service, the party sexving thi.~ subpo~-n may seek a cottrt order compelling you to comply with it. TlqT.~ SUBPOENA WAS ISSUI~D AT ~ REQUEST OF TWF. FOLLOWING PERSON: George H. Eager, Esquire N~: Ea~er~ Reinaker & Spinello ADD~'I?.~: 1347 Fruitville Pike Lanc~ster~ PA 17601 ~.I ~KI~HO~: (717) 290-7971 SUPREME COURT ID # ?77An ATTORNEY FOR: Defendant BY ~ COURT: DATE: Semi of tim Court 'Prothonotary/Clerk, Civil Divi~ien ¢OiwMO~~ OF P~N$~VAN~ COUNT~ OF CUMBers,AND ROLAND WILLIAMS, III, and his wife, LISA M. WILLIAMS, Plaintiff VS · AMY M. WILSON, Defendant File .No. 01-4590-2001 SUBPOENA TO PRODUCE DO~ OR FOR DISCOVERY PI./RSUANT TO RULE To: ABF Freight System, P.O. Box 1925~ New w~gston, PA 17013 V~hin twe~,ty (20) days after set.ce of thi.~ subpoena, you are ordered by the court to prodtlcethe fo]]owi~g do~tlmelxts or thln~q: Any and all employment records or reports, etc. & any other information perto~.~ to Plaintiff Roland Will~am% III (DOB-' 10/3/54~ (S'SN: 208-42-6999) ~£ 1347 Fruitville Pike, Lancaster~ P~nn~lvania, 17601. (Addre~) You may deliver or mall leg/ble copies of the doonnents or produce things requested by thi~ subpoena, together with the certificate of compli~nre, to the party ma~ng 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 thin? sunooht If you fail to produce the doo,ments or thin~ required by th[q subpoena wi~hln twenty (20) days after its service, the party serving thl~ ~ubpoena may seek a court order comp~lllnoo you to comply wl/h it. THI~SUBPOENAWASISSUEDATTHEREQUF_~TOFTYIlZ. FOLi,OWiNGPERSON: George H. Eager, Esquire N~: Eager, Reinaker & Spinello ADD~.~: 1347 Fruitville Pike Lancaster, PA 17601 T]~JJ~J~HON]E: (717~ 29Q-7~71 SUPI~COIJ-RTID# 27740 ATTORNEY FOR: Defendant BY ~ cOURT: DATE: Seal of the Court Prothonotary/Clerk, Chn_~ Division I~puty colV~'lo~T~ OF PENNSYLVAt~A COUNTY OF ~ERLA~ ROLAND WILLIAMS, III, and his wife, LISA M..WILLIAMS, Plaintiff vs. AMY M. WILSON, Defendant F~le ,No. 01-4590-2001 SUBPOENA TO PRODUCE DO~ OR FOR DISCOVERY PURSUANT TO R'fTLI~. To: Robert C. Zabinski, D.C., 3028 Market Street, Camp Hill, PA 17011 W'~in twenty (20) days after service of this subpoena, you are ordered by the court to produce the foflo~n~n~ documen~ or thln~: Any and. all first consultation reports, office notes, MI{I,-CT and x-ray fi~ a reports, test resu±ts, pnyslca± therapy £eporcs, nurses' notes and do~cu£~~ o~d~, alot~g with axty ~Ltd all uLlt=~ m~dl~l at 1347 Fruitville Pike. Lancaster. PA 17~.an~ M' wl£±lams, Azz ~: AO/o/'o4) (Addre~) (SSN: 208-42-6999) You may deliver or mall legible copies of the docnnneuts or produce things requested by this subpoona, together with the certificate of compliance, to the pa~-ty malkqn~ thin ~ at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the thln~ suught. If you fail to produce the documents or thin~s required by this subpoena wjthln twenty (20) days after its service, the party serving this subpoena my seek a court order ¢oml~tllng you to comply with it. TI~RSUBPOENAWAS/SSUEDATTm~.REQUESTOFTm~.FOLLOWiNGPERSON: George H. Eager, Esquire N~: EaEer, Reinaker & Spinello ADDRg$S: 1347 Fruitville Pike Lancaster, PA 17601 TI~/'~la~ON~: (7171 290-7971 b-~U~I~COURTI]~# 27740 AZ'FORN~¥FOR: Defendant BY ~ COURT: DATE: Se~l of the Court 'Prothonotary/Clerk, Chdl Division COMMO~TM OF PENNSYLVANI.~ COUNTY OF CUMBERLAND ROLAND WILLIA~MS, III, and his wife, LISA M. WILLIAMS, Plaintiff VS. A/fl M. WILSON, Defendant File ,No. 01-4590-2001 SUBPOENA TO PRODUCE DO~ OR' TILINGS FOR DISCOVERY PURSUANT TO RULE TO: Edmundowicz, Watktn & Freshman Associates, p.c., 2645 North Third Street, Suite 200, Harrisburg', PA 17110 Within twenty (20) days after service of this subpoena, you are ordered by the court to ~roducethe foflowin~ documealtsorthines: Any &~all ·first consultation reports, offico otes,,MRI, CT ag~d~.x-r~z_~i}m~ & re~cs_ iasc resu£ts, physical er p re nurses notes ann doctors oraers alon~ oith any ann ail orner me~ca~ ~eco~s a~d reports concerning Plaintiff Roland M. Williams, III (DOB: 10/3/54) (SSN: 208-42-6999) at 1347 Fruitville Pike, Lancaster, Pennsylvania, 17601. (Address) You may deliver or mall legible copies of the documents or produce thingS requested by this subpoena, together with the certificate of compliance, to the party mnirlnoo 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. ff you fail to produce the documents or things required by this subpoena within twenty ~20) days after its service, the party servin~ this subpoena may seek a court order compelling you to comply with it. SUBPOENA WAS I~SUED AT TILE. REQUEST OF ~ FOLLOWING PERSON: George H. Eager, Esquire /~I)D~S: 1347 Fru~tville Pike Lan~aster~ PA 17601 TIEJ~E~O~E: (717) 290~7971 SUP~ COLrRT ID # 2?740 A~'rORNEYFOR: Defendant BY ~ COURT: DATE: Seal of the Court' Prothonotary/clerk, Civil Division ~..puty COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUlV~ERLAND ROLAND WILLIAMS,' II~I, and his wife, LISA M. WILLIAMS, Plaintiff VS. AMY M. WILSON, Defendant File,No. 01-4590-2001 To: SUBPOENA TO PRODUCE DOCUMENTS OR' THINGS FOR DISCOVERY PURSUANT TO RULE 4009 ~ % Neurological Surgery, Ltd., 920 Century Drive, Me~h~nicsburg, PA 17055-8404 Within twenty (20) days after service of thi.~ subpoena, you are ordered by the court to ~roduce the foHo~dng doon-ents or things:Any and ~11 first consultation reports, office otes,,MRI, CT a~d x-ray $ilms & revorts, cesc results h sxca± n .reports concerning Plaintiff Roland M. Will~mm~. III (DOB: 10/3/54) (SSN: 208-42-~999) ~ 1347 Fruitville Pike, Lancaster, Penns~lvania~ 17601. (Addr ) You may deliver or mall legible copies of the doc,,ments or produce thi, gs requested by thin subpoena, together with the certificate of compliance, to the party mnidng thin request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the thln~s ~ought If you fail to produce the doo,ments or things required by this subpoena within tweuty (20) days after its service, the party serving this subpo~n~ may seek a court order comp~]ling you to comply with it. THq~ SUBPOENA WAS ISSUED AT ~ REQUEST OF ~ FOLLOWING PERSON: George R. Eager, Esquire $~d~: Eager, Reinaker & Spinello ~DDRF_$S: 1347 Frllttvf~1a La~caster, PA 17601 TI?~L~P~OI~: (717) 290-7971 SUPREME COURT ID # 27740 ATTORNEY FOR: Defendant BY ~ COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy coMMoNWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROLAND WILLIAMS~ III, and his wife, LISA M. WILLIAMS, Plaintiff vs. AMY M. WILSON, Defendant lq]e,No. 01-4590-2001 To: SUBPOENA TO PRODUCE DOCUMENTS OR' THINGS FOR DISCOVERY PURSUANT TO RULE 4009 ~ Zabinski Chiropractic Offic.e, 3028 Market Street~ Camp H~ll, PA 17011 W~hlntwenty(20) daysafterservice ofthi~subpocna, you are ordered by thecourtto ~OedUC~3~e fo~owin~docun~atsorth~: Any andall first consultation reports office S ,~_i CT a -~y_~l_L~_ ~ reports c se resu cs ph ical ~'p L~ ~ n~rse~ no'es a~d~cto{s or~ers a~on~ ~it~ any an~ ail o~er me~ca~ ~eco~s a~d reports concerning Plaintiff Roland M. Wtll~amm, III (DOB: 10/3/54) (SSN: 20.8-42-6999) at 1347 Fruitville Pik% Lancaster~ Pmnnuylvania, 17601. (Address) You may deliver or mail legible copies of the doc,mae.ts or produce thin? requested by this subpoena, together with the certificate of compllnnce, to the party ma~ng this request at the address listed above. You have the right to seek in advance the remson~,h~e cost of preparing the copies or producin~ the thln~n sought. ff you fail to produce the docnments or things required by this subpoena withl, twenty (20) days after its service, the party serving this suhpo~n~ may seek a court order compellin~ you to comply ~ith it. TFIT~ SUBPOENA WAS ISSUED AT TW~. REQUEST OF ~ FOLLOWING PF_aX~ON: George H. Eager, Esquire N~: Eager~ Reinaker & Spinello Lancaster. PA 17601 /~.Ll~,l~O~[]~: (717) 290-7971 SUPREME COURT ID # 27740 A~CrORNEY FOR: D e~'endant BY T~ COURT: DATE: Seal of the Court 'Prothonotary/Clerk, Civil Division Deputy CO~V~O~TH OF PEN~SYLYAN-tA COUNTY OF CUMBERLAND ROLAND WILLIAMS, III, and his wife, LISA M..WILLIAMS, Plaintiff VS. AMY M. WILSON, Defendant l~e ,No. 01-4590-2001 SUBPOENA TO PRODUCE DOCUMENTS OR' THINGS FOR DISCOVERY pLrRSUANT TO RULE 4009_~ To: Edwin A. Aquino, M.D., P.C., 845 Sir Thomas Court, Suite 10, Harrisburg, PA 17109 W~hlntwenty(20) daysafterservice ofthi~subpoena, you are ordered bythecourtto ~or~c~e fo~owin~ docun~nts or thin~s: Any and all first c~nsultation reports, office nurse~ no~es a~oc~;l~r~er~ ~$ ~it~e~y£~l~!~er~i~almed~ca~he a~cor~sre urU~and reports concerning Plaintiff Roland M~ Williams, III (DOB: 10/3/54) (SSN: 208-42-6999) a~ 1347 Fruitville Pike, Lancaster~ Pennsylv~nt-, 17601. (Address) You may deliver or umil legible copies of the documents or produce things requested by this subpoena, together with the certificate of comp!!~oce, to the party m~irlng thin 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. ff you fail to produce the doo~ments or things required by this Slllbpoegta w~hln twenty (20) days after its service, the party serving this subpo~-n~ may seek a court order compelling you to comply with it. TI-II~ SUBPOENA WAS ISSUED AT ~ REQUEST OF ~ FOLLOWING PERSON: George H. Eager, Esquire N~: Eager, Reinaker & Spinello Lancaster, PA 17601 ~LI~.I~O1N~: (717) 290-7971 SUPREME COURT ID # 27740 ATTORNEY FOR: Defendant BY TH~ COURT: DATE: Seal of the Court ~rothonotary/Clerk, Civil Division Deputy coMMONWEALTH OF PENNSYLVAN~ COUNTY OF CUMBE~ ROLAND WILLIAMS, III, and his wife, : LISA M. WILLIAMS, Plaintiff : VS. AMY M. WILSON. Defendant · File ,NO. 01-4590-2Q01 SUBPOENA TO PRODUCE DOC-ZrlVIEN'I~ OR' THINC~R FOR DISCOVERY pURSUANT TO RULE 4009.~ To: Anesthesia Assocaites of Pennsylvania~Ltd.~ 207 House Avenue, Suite 102, Camp Hill. PA 17011 Withlntwenty(20) daysafterservice ofthi~subpoena, you are ordered by the court to ~ort°~.,~.f~Oa~q~d~_uwF~or_thin_~gs3, .Any. an0. all $$rst ~on~ulCation re orts office nurse~' no~es a~U~o- ~~ ~~=~ ~=~ ~Y~± ~he~a~¥Pren ~r~ ' cto~ ......... u~ w~ any ano az± other medlca± r~cor~r~H~ reports concerning Plaintiff Roland M. Williams, III (DOB: 10/3/54) (SSN: 208-42-6999) at 1347 vr,,~v~l~ p~a: Lancaster~ Pennsylvania: 17601. (Address) You may deliver or mail legible copies of the documents or produce thlnE~ requested by thi.~ subpo~nn; together with the certificate of compliance, to the party making this request at the addrems listed above. You have the right to seek in ad~ance the reasonnhle cost of preparing the copies or producing the things sought. ff 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 compnllin~ you to comply with it. TI-II~ SUBPOENA WAS ISSUED AT THE REQLrE~T OF ~ FOLLOWING PERSON: George H.'Eager, Esquire N~: Ea~er~ Reinaker & Spinello ADD. S: 1347 Fruitville Pike Landaster. PA 17601 ~I~HO~E: (717~ 290-7971 SUPR]~tIECOURT]I}# 27740 ATTORNEY FOR: Defendant BY ~ COURT: DATE: Seal of the Court ~cothonotary/Clerk, Civil Division Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUM~I~.RLAND ROLAND WILLIAMS, III, and his wife, LISA M. WILLIAMS, Plaintiff VS. AMY M. WILSON, Defendant 01-4590-2001 SUBPOENA TO PRODUCE DOCUMENTS OR' THINGS FOR DISCOVERY PURSUANT TO RULE 4009.~.~. TO: Pinmacle Health-Polyclinic Hospital~ 2601 North Third Street, Harrisburg~ PA 17110 W~thlotwenty(20) daysafterservice ofthlnsubpoena, you are ordered by the court to pro4ucethefoHo~dng docun~mtsor things: An abstract of any and all medical records and films pertaining to Plaintiff Roland Williams, III (DOB: 10/3/54) (SSN ~' 208-42-6999) a£ 1347 Fruitville Pike, Lancaster, Pennsylv~n~m, 17601. (Address) You may deliver or mall leg~31e copies of the documents or produce things requested by thin subpoena, together with the certifi~ of compli~oce, to the party m-irlng thin request at the address listed above. You have the fight to seek in advance the reasonable cost of preparing the copies or producing the thln~ ~Ought. If you fail to produce the doc,,ments or things required by this subpoena within twenty (20) days after its service, the party serving thin subpoena may seek a court order comp~-Iling you to comply with it. T1TI~ SUBPOENA WAS ISSUED AT ~ REQUEST OF ~ FOLLOWING PERSON: George R. Eager, Esquire N~: Easer, Reinaker & Spinello ADDRESS: 1347 Fruitville Pike Lancaster, PA l/0oi TI~I~I~HO1W~: (717) 290-7971 S~ COURT ID # 27740 ATTOP. N-~Y FOR: Defendant BY ~ COURT: DATE: Seal of the Court 'Prothonotary/Clerk, Civil Division Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ROLAND WILLIAMS, III, and his wife, LISA M. WILLIAMS, Plaintiff vs. AMY M. WILSON, Defendant File,No. 01-4590-2001 SUBPOENA TO PRODUCE DOCU1V[ENTS OR' THINGS FOR DISCOVERY PURSUANT TO RULE 4009, 22 To: Magnetic ImaKing Center, 4665 Trindle Road, w,rh~icsbur8, PA 17055 Withlntwenty(20) daysafterservice ofthlnsubpoena, you are ordered bythe courtto produce thefoHowing documents or things: Any and. all films and reports on Plaintiff (DOB: 10/3/54) (SSN: 208-42-6999) at 1347 F~itvtlle Pike: Lancaster: P'annsvlvania. 17601, (Address) You may deliver or marl legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party mn~n~ th/s request at the address listed above. You have the right to seek in advance the reasonable cost of preparln~ the copies or producing the thln~ Sol~oht. If you fail to produce the documents or things required by this subpoena within ~wenty (20) days after its service, the party seawing thin subpoena may seek a court order compelling you to comply with it. Tlqff,~ SUBPOENA WAS ISSUED AT ~ REQUEST OF ~ FOLLOWING PERSON: George H. Eager, Esquire $~: Ea~er, Reindeer & Spinello ADDRESS: 1347 Fruitville Pike Landaster, PA 17601 ~-~L]~O~: (717) ?q0-7971 SUPREME COURT ID # 27740 A~FORNEY FOR: Defendant BY ~ COURT: DATE: Seal of the Court 'Prothonotary/Clerk, Civil Division Deputy coMMONWEALTH OF PENNS~V~4 COUNTY OF ~.RT._O,~ ROLAND WILLIAMS, III, and his wife, : LISA M. WILLIAMS, Plaintiff : : : AMY M. WILSON, Defendant : Fi][e ,No. 01-4590-2001 SUBPOENA TO PRODUCE DOCUMENTS OR TITING,e. FOR DISCOVERY PURSUANT TO RULE 4009 To: Quantum Imaging & Therapeutic Associates, Inc.. 3508 Trindle Rnad. Camm 17011 W~hintwenty(20) daysafterser~ice ofthlssubpoena, you ar e ordered by the court to produce thefo~o~ng doo,mentsor things: Any and all films and reports on Plaintiff (DOB: 10/3/54) '(SSN': 208-42-6999) 1347 Fruitville Pike, Lancaster. Pennsylvania, 17601, (Address) You may deliver or mail legible copies of the documents or produce things requited by this subpoena, together with the certificate of compliance, to the party mnk~lg thin 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 thin subpoena within twenty (20) days after its service, the party serving this subpo~n~ may seek a court order compelling you to comply with it. THIR SUBPOENA WAS ISSUED AT ~ REQLrEST OF ~ FOLLOWING PERSON: George H. Eager, Esquire N~I]~:. Eager, Reinaker & Spinello ADDICt, S: 1347 Pruitville Pike Landaster, PA 17601 'I~,L~PHON~: (717) 290-7971 SId~ COURT lB # 27740 ATTORNEY FOR: Defendant BY ~ COURT: DATE: Seal of the Court Prothonotary/Clerk, Civil Division Deputy CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Notice of Intent to Serve A Subpoena to Produce Documents and Things for Discovery Pursuant to Rule 4009.21 upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 EAGER, REINAKER & SPINELLO Dated: Georg~-H. ~age~///Esquire Attorney for ~fendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena Pursuant to Rule 4009.22 upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 (Attorney for Plaintiff) DATE: EAGER, REINAKER & SPINELLO BY: George ~ Ea~r, Esquire Attorney f~ Defendant I.D. No. ~7740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 ROLAND WILLIAMS, HI, and His wife, LISA M. WILLIAMS, Plaintiff VS. AMY M. WILSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, NO. 01-4590 2001 CIVIL ACTION-LAW JURY TRIAL DEMANDED PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE JUDGES OF SAID COURT: Josel~h J. Dixon, Esouire , counsel for the plaintiff in the above action, respectfully represents that: 1. The above-captionedplaintiffinaCtion is at issue.~.,~rff~^^ ^~ /" -~r'- Oo~j)~ 2. The claim of the the action is :I,~g~__9~. t ~-'-->, The counterclaim of the defendant in the actton is $0.00. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: George H. Ea~er, Esquire of Eager, Reinaker & Spinello WHEREFORE, your petitioner pra~s your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully Submitted, Dated: May 11, 2004 · AND NOW.. "~'~_ action as prayed for. ~E~quire Attorney for Plaintiffs PA Id No. 28290 126 State Street Harrisburg, PA 17101 (717) 236-8515 ORDER OF COURT ,20~J/, ~,con~idey.ation of the foregoing petition, Esq., ,(~ ~~, ,Esq.,and Esq., are appointed arbitrators iff/the above captioned By the Court, ROLAND WILLIAMS III, and His wife, LISA M. WILLIAMS AMY M. WILSON IN RE: ARBITRATION PANEL : IN THE COURT OF" COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW · NO. 01-4590 CIVIL TERM ORDER OF COURT AND NOW, June 7, 2004, the Court having been informed that Richard Mislitsky, Esquire, is unavailable for the above-captioned arbitration hearing, Michael Scherer, Esquire, is appointed in his stead. By the Court, Bradley L. Griffie, Esquire 200 North Hanover Street Carlisle, PA 17013 Court Administrator Plaintiff Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. O / - t'/S~ 0 Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the Urn'ted States and the Constitution of this Commonwealth and that we w/ll discharge the duties of our office with fidelity. Name (Chairman) Law F~ Address Ci~, Zip Name Name Law Firm Law Finn Address Address / ciw, zip ci~, zip' Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following, award: (Note: If damages for delay are awarded, they shall be separately stated.) Date of Hearing: Date of Award: · Arbitrator, dissents. (Insert name if applicable.) (Chaiman) Notice of Entry of Award Now, the ~,~tgt, dayof tl/rOl('~/~, 20/>~ ,at l~.~/~', .~5_.M., the above award was entered upon the docket and notice thereof given by mall to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 60 Prothonotary Deputy ROLAND WILLIAMS, III and his wife, LISA M. WILLIAMS Plaintiffs VS. AMY M. WILSON Defendant PRAECIPE TO IN THE COURT OF COMMON PLEAS CUMBERLAND COUTNY, PENNSYLVANIA NO. 01-4590-2001 CIVIL ACTION - LAW SETTLE, DISCONTINUE AND END Please mark the above-captioned case settled, discontinued and ended. Respectfully submitted, Date: November 29, 2004 Joseph J. Dixon, Esquire Attomey Nc,. 28290 126 State Street Harrisburg, PA 17101 (717) 236-8515 Attorney for Plaintiff