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HomeMy WebLinkAbout05-6026IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA YOUNG YI LIM 4420 Gettysburg Road, #4 Camp Hill, PA 17011 and CHOON HWAN JO and DONG WON JO, h/w 31 High Haven Place, Apt. TC Baltimore, MD 21236 NO. 0S` 6D)(' CIVIL ACTION e;.I- ?-, vs. JONG DOO LIM a/k/a JUNG DOO LIM a/k/a JONG DOO a/k/a JUNG DOO a/k/a JONG DO a/k/a JUNG DO 4420 Gettysburg Road, #4 Camp Hill, PA 17011 PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue Writ of Summons in the above captioned action. Writ of Summons shall be issued and forwarded to: ( ) Attorney ( X )Sheriff LOUIS I. LIPSKY, ESQUIRE Name of Attorney 1101 Market Street - Suite 2820 Philadelphia. PA 19107 Address (215) 922-6644 Telephone No. Signature of ttorney Supreme Court ID No.46808 Dated: / / // ?/' J % \ ?? .. ? ? v \ d? ? r?}` ? ? [? ( \ 'Y \J?r \.?; ? ? 't 1 r_? . ,? -' ? t ?? "\.} ?7 _? 3. ? _a .t _ ? Y..` ?+ l IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA YOUNG YI LIM 4420 Gettysburg Road, #4 Camp Hill, PA 17011 and CHOON HWAN JO and DONG WON JO, h/w 31 High Haven Place, Apt. TC Baltimore, MD 21236 VS. JONG DOO LIM a/k/a JUNG DOO LIM a/k/a JONG DOO a/k/a JUNG DOO a/k/a JONG DO a/k/a JUNG DO 4420 Gettysburg Road, #4 Camp Hill, PA 17011 SUMMONS TO THE ABOVE NAMED DEFENDANT(S): NO. .9? - G a1G CIVIL ACTION YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU. d1i PR THON Y DATED: l1 oD1 5 BY: DEPUTY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA YOUNG YI LIM and NO. 05-6026 CIVIL CHOON HWAN JO and DONG WON JO, h/w : vs. JONG DOO LIM a/k/a JUNG DOO LIM a/k/a JONG DOO a/k/a JUNG DOO a/k/a JONG DO PRAECIPE TO RE-ISSUE SUMMONS TO THE PROTHONOTARY OF THE SAID COURT: Kindly reissue the attached Summons in Civil Action in the above captioned matter. LIPSKY AND BRANDT BY: LO IS I. LIPSK,ESQUIRE I Zl L?4 1i ATTORNEY FOR PLAINTIFFS DATED: f / .. C1 07 rti A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA YOUNG YI LIM 4420 Gettysburg Road, #4 Camp Hill, PA 17011 and CHOON HWAN JO and DONG WON JO, h/w 31 High Haven Place, Apt. TC Baltimore, MD 21236 VS. JONG DOO LIM a/k/a JUNG DOO LIM a/k/a JONG DOO a/k/a JUNG DOO a/k/a JONG DO a/k/a JUNG DO 4420 Gettysburg Road, #4 Camp Hill, PA 17011 SUMMONS TO THE ABOVE NAMED DEFENDANT(S): NO. CIVIL ACTION YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFFS HAVE COMMENCED AN ACTION AGAINST YOU. DATED: I(- 1 -CAS 9 PROTHONOTARY BY: \I- . /j "?'& DE UT SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-06026 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LIM YOUNG YT VS LIM JONG DOO AKA JUNG D00 LIM R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT LIM JONG DOO AKA JUNG DOO LIM AKA JONG DOO AKA JUNG D00 but was unable to locate Him in his bailiwick. He therefore returns the WRIT OF SUMMONS NOT FOUND , as to the within named DEFENDANT AKA JONG D00 AKA JUNG D00 LIM JONG D00 AKA JUNG DOO LIM 4420 GETTYSBURG ROAD 44 CAMP HILL. PA 17011 DEFENDANT MOVED FROM GIVEN ADDRESS OVER A YEAR AGO.. Sheriff's Costs: So answers:., Docketing 18 .00 Service 14 .40 4,. = `L Not Found 5 .00 R. Thomas KI"ine Surcharge 10 .00 Sheriff of Cumb erland County .00 47 .40 VICTOR LIPSKY 12/05/2005 Sworn and subscribed to before me this 12-1?) day of ?`Qrz.? A. D. O l P otho y SHERIFF'S RETURN - REGULAR CASE NO: 2005-06026 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LIM YOUNG YI VS LIM JONG DOO AKA JUNG DOO LIM ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon LIM JONG DOO AKA JUNG DOO LIM AKA JONG DOO AKA JUNG DOO the DEFENDANT at 2050:00 HOURS, on the 9th day of January , 2006 at 5506BEARCREEK DRIVE MECHANICSBURG, PA 17055 YOUNG YI LIM, WIFE by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.80 Affidavit .00 Surcharge 10.00 .00 36.80 Sworn and Subscribed to before me this -)o day of Jot A.D. Pr not y So Answers: R. Thomas Kline 01/10/2006 VICTOR LIPSKY )Depdty She !f f 06HB-00051 LAW OFFICE OF SNYDER & DORER 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 'T'ELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won Case No.: 05-6026 Jo, h/w, Plaintiffs vs. Jong Doo Lim wVa Jung Doo Lim a/k/a Jong Don IJURYTRIAL DEMANDED a/k/a Jung Don a/k/a Jong Do a/k/a Jung Do, Defendant OF I TO THE PROTHONOTARY: Kindly enter my appearance in the above-captioned matter on behalf of the Defendant, Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do. Respectfully submitted, LAW OFFICE OF SNYDER & DORER By: JoAnn, E. mzel, Esquire Attorney for Defendant Identification No. 55453 Date: April 12, 2006 J6HB-00051 LAW OFFICE OF SNYDER & DORER 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won (Case No.: 05-6026 Jo, h/w, Plaintiffs vs. Jong Doo Lim a/k/a Jung Don Lim a/k/a Jong Don a/k/a Jung Don a/k/a Jong Do a/k/a Jung Do, Defendant TE OF TRIAL DEMANDED JoAnne E. Kinzel, Esquire, hereby certifies that she is the attorney for the Defendant herein, and that she caused a true and correct copy of the attached Entry of Appearance to be served by regular first class mail upon: Louis I. Lipsky, Esquire 1101 Market Street - Suite 2820 Philadelphia, PA 19107 Date: April 12, 2006 JoAnne E: Kmzel, Esgt Attorney or Defendant ?? 06HB-00051 LAW OFFICE OF SNYDER & DORER 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won ase No.: 05-6026 Jo, h/w, Plaintiffs vs. Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant Y TRIAL DEMANDED TO TO THE PROTHONOTARY: Please enter a RULE upon plaintiffs to file a Complaint within 20 days hereof or suffer the entry of a Judgment of Non Pros. Date: April 12, 2006 JoAnne E. lKiniel, Esquire Attorney fdr Defendant RULE TO FILE COMPLAINT AND NOW, this ?2 4 day of I- I , 2006 a RULE is hereby entered upon the Plaintiffs to file a Complai t herein within 20 days after service hereof or suffer the entry of a Judgment of Non Pros. 06HB-00051 LAW OFFICE OF SNYDER & DOWER 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won Case No,: 05-6026 Jo, h/w, Plaintiffs vs. Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant TRIAL DEMANDED OF JoAnne E. Kinzel, Esquire, hereby certifies that she is the attorney for the Defendant herein, and that she caused a true and correct copy of the attached Praecipe for Rule to File Complaint to be served by regular first class mail upon: Louis I. Lipsky, Esquire 1101 Market Street - Suite 2820 Philadelphia, PA 19107 Date: April 12, 2006 l 'A Y---- JoAnne E. Kinzel, Esquire Attorney or Defendant - - ; ? ;•? - ??. LIPSKY AND BRANDT BY: LOUIS I. LIPSKY, ESQUIRE IDENTIFICATION NO. 46808 1101 MARKET STREET - SUITE 2820 PHILADELPHIA, PA 19107 ATTORNEY FOR PLAINTIFFS (215) 922-6644 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA YOUNG YI LIM and NO. 05-6026 CIVIL CHOON HWAN JO and DONG WON JO, h/w : vs. JONG DOO LIM a/k/a JUNG DOO LIM a/k/a JONG DOO a/k/a JUNG DOO a/k/a JONG DO NOTICE TO DEFEND 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 an 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 Bar Association 32 South Bedfor Street Carlisle, PA 17013 717-249-3168 or 800 990-9108 LIPSKY AND BRANDT BY: LOUIS I. LIPSKY, ESQUIRE IDENTIFICATION NO. 46808 1101 MARKET STREET - SUITE 2820 PHILADELPHIA, PA 19107 (215) 922-6644 ATTORNEY FOR PLAINTIFFS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA YOUNG YI LIM and NO. 05-6026 CIVIL CHOON HWAN JO and DONG WON JO, h/w : vs. JONG DOO LIM a/k/a JUNG DOO LIM a/k/a JONG DOO a/k/a JUNG D00 a/k/a JONG DO COMPLAINT IN CIVIL ACTION 1. Plaintiff, YOUNG YI LIM, is an adult individual residing at 5506 Bearcreek Drive, Mechanicsburg, Pennsylvania 17050 and was a passenger in a motor vehicle involved in the accident hereinafter described. 2. Plaintiff, CHOON HWAN JO, is an adult individual residing at 3 High Haven Place, Apt. TC, Baltimore, MD, 21236 and was a passenger in a motor vehicle involved in the accident hereinafter described. 3. Plaintiff, DONG WON JO, is an adult individual residing at 3 High Haven Place, Apt. TC, Baltimore, MD, 21236, and is the husband of Plaintiff, CHOON HWAN J0. 4. Defendant, JONG DOO LIM a/k/a/ JUNG DOO LIM a/k/a/ JONG DOO a/k/a JUNG DOO a/k/a/ JONG DO, is an adult individual residing at 5506 Bearcreek Drive, Mechanicsburg, Pennsylvania 17050 and was the owner and operator of the motor vehicle which was involved in the accident hereinafter described. 5. On or about December 3, 2003, Plaintiffs, YOUNG YI LIM and CHOON HWAN JO, were passengers in a vehicle traveling on Gettysburg Road, driven by Defendant herein, who was proceeding to make a left turn through the intersection onto Wesley Drive in the Municipality of Lower Allen Township in the County of Cumberland, Commonwealth of Pennsylvania, which intersection was controlled by a working traffic signal control device. 6. On the same date and at the same time, a vehicle operated by, Michael Deibert, was traveling in the opposite direction on Gettysburg Road through its intersection with Wesley Drive, in the Municipality of Lower Allen Township in the County of Cumberland, Commonwealth of Pennsylvania, which intersection was controlled by a working traffic signal control device. 7. The vehicle in which Plaintiffs were traveling, operated by Defendant, thereafter proceeded to illegally make a left turn in front of the vehicle driven by Delbert, failing to yield to oncoming traffic, whereby the vehicle was struck by the vehicle driven by Michael Deibert, causing severe personal injuries to Plaintiffs, YOUNG LI LIM and CHOON HWAN JO hereinafter more fully described. 8. The aforesaid accident was caused solely by the negligence, recklessness and wantonness of Defendant herein, and it was in no manner whatsoever due to any act or failure to act on part of Plaintiffs, YOUNG LI LIM and CHOON HWAN 9. The negligence, recklessness and wantonness of Defendant consisted of the following: (a) failure to yield the right of way to an approaching vehicle while executing a left turn; (b) operating said motor vehicle in a careless and reckless manner without due regard for the rights and safety of Plaintiffs; (c) failing to maintain proper and adequate observations of conditions then and there existing; (d) failing to keep said motor vehicle under proper control; (e) violating sections 3322, 3714 and 3736 of the Motor Vehicle Code, 75 Pa.C.S.A., 3322, 3714 and 3736; (f) failing to use due care and otherwise yield to oncoming traffic when making a left turn; (g) negligence as a matter of law for violating the aforesaid statutes; (h) operating said motor vehicle with a reckless disregard for the safety of others lawfully on the highway; (i) failing to use due care under the circumstances as aforesaid; and Q) operating said vehicle without observing and heeding the road and traffic conditions then and there existing. COUNT I - YOUNG YI LIM V. JONG DOO LIM a/k/a JUNG DOO LIM a/k/a JONG DOO a/kla JONG DO 10. The averments set forth in paragraphs 1 through 9, above, are hereby incorporated by reference as though fully set forth at length. 11. By reason of the occurrence described above, Plaintiff, YOUNG LI LIM, sustained injuries in and about her body and extremities which injuries are serious, severe and permanent, and include, but are not limited to, acute severe cervical spine acceleration/deceleration injury, acute thoracic sprain and strain, headaches secondary to trauma, cervical radiculitis, closed facial fracture of the maxillary bone, cephalgia, rotator cuff strain and sprain, injuries to tooth #4 and tooth #5, bruises, contusions and abrasions, and other serious injuries together with severe shock to her nerves and nervous system by reason of which she was rendered sick, sore, lame and disfigured, was made to suffer from serious impairments of bodily functions and was made to undergo great physical pain and mental anguish which she suffered, suffers and will continue to suffer for an indefinite time in the future. 12. As a further result of the Defendant's negligence, Plaintiff, YOUNG LI LIM was prevented from attending to her usual and daily occupations and duties, and thereby may suffer(ed) a loss of earnings and/or impairment of earning capacity which Plaintiff may continue to suffer for an indefinite time in the future. 13. As a further result of Defendant's negligence, Plaintiff, YOUNG LI LIM has been or will be obliged to expend certain sums and incur certain expenses to receive and undergo medical attention and care for the injuries she has suffered and she may be obliged to continue to expend such sums and incur such expenses for an indefinite time in the future. 14. As a direct result of Defendant's negligence, Plaintiff, YOUNG LI LIM has and may hereinafter incur other financial expenses or losses which do or may in the future exceed the amounts she may otherwise be entitled to recover under the law of Pennsylvania. 15. As a further result of this accident, Plaintiff, YOUNG LI LIM has or may suffer a severe loss because of expenses which have been or may be reasonably incurred in obtaining ordinary and necessary services in lieu of those which Plaintiff would have performed, not for income, but for the benefit of herself, if she had not been so grievously injured. WHEREFORE, Plaintiff, YOUNG LI LIM, demands judgment in her favor and against Defendant, JONG DOO LIM a/k/a/ JUNG DOO LIM a/k/a/ JONG DOO a/k/a JUNG DOO a/k/a/ JONG DO and claims damages from the Defendant in an amount not in excess of Fifty Thousand ($50,000.00) Dollars plus costs and delay damages. 16. The averments set forth in paragraphs 1 through 15, above, are hereby incorporated by reference as though fully set forth at length. 17. By reason of the occurrence described above, Plaintiff, CHOON HWAN JO, sustained injuries in and about her body and extremities which injuries are serious, severe and permanent, and include, but are not limited to, cervical sprain and strain, lumbar sprain and strain, thoracic sprain and strain, headaches secondary to trauma, acute cervical spine radiculitis, rotator cuff strain and sprain, shoulder impingement syndrome, bruises, contusions and abrasions, and other serious injuries together with severe shock to her nerves and nervous system by reason of which she was rendered sick, sore, lame and disfigured, was made to suffer from serious impairments of bodily functions and was made to undergo great physical pain and mental anguish which she suffered, suffers and will continue to suffer for an indefinite time in the future. 18. As a further result of the Defendant's negligence, Plaintiff, CHOON HWAN JO was prevented from attending to her usual and daily occupations and duties, and thereby suffered a loss of earnings and/or impairment of earning capacity which Plaintiff may continue to suffer for an indefinite time in the future. 19. As a further result of Defendant's negligence, Plaintiff, CHOON HWAN JO has been or will be obliged to expend certain sums and incur certain expenses to receive and undergo medical attention and care for the injuries she has suffered and she may be obliged to continue to expend such sums and incur such expenses for an indefinite time in the future. 20. As a direct result of Defendant's negligence, Plaintiff, CHOON HWAN JO has and may hereinafter incur other financial expenses or losses which do or may in the future exceed the amounts she may otherwise be entitled to recover under the law of Pennsylvania. 21. As a further result of this accident, Plaintiff, CHOON HWAN JO has or may suffer a severe loss because of expenses which have been or may be reasonably incurred in obtaining ordinary and necessary services in lieu of those which Plaintiff would have performed, not for income, but for the benefit of herself, if she had not been so grievously injured. WHEREFORE, Plaintiff, CHOON HWAN JO, demands judgment in her favor and against Defendant, JONG DOO LIM a/k/a/ JUNG DOO LIM a/k/a/ JONG DOO a/k/a JUNG DOO a/k/a/ JONG DO and claims damages from the Defendant in an amount not in excess of Fifty Thousand ($50,000.00) Dollars plus costs and delay damages. COUNT III- DONG WON JO v. JONG DOO LIM a/k/a JUNG DOO LIM a/k/a JONG DOO a/k/a JONG DO 22. Plaintiff, DONG WON JO, incorporates by reference the averments contained in Paragraphs 1 through 21 above, as though fully set forth herein at length. 23. By reason of the aforesaid, Plaintiff, DONG WON JO, has been and may and probably will in the future be deprived of the assistance, consortium and society of his said wife, all of which has been and probably will be to his great financial damage and loss. WHEREFORE, Plaintiff, DONG WON HO, demands judgment in his favor and against Defendant, JONG DOO LIM a/k/a/ JUNG DOO LIM a/k/a/ JONG DOO a/k/a JUNG DOO a/k/a/ JONG DO, in a sum not in excess of Fifty Thousand ($50,000.00) Dollars plus costs and delay damages. LIPSKY BY: LOUIS 1. LIPSW, ESQUIRE ATTORNEY R PLAINTIFFS VERIFICATION The undersigned hereby verifies that the within Complaint in Civil Action is based on firsthand information and on information furnished to counsel and obtained by him in the course of this lawsuit. The language of the Complaint in Civil Action is that of counsel and not of the affiant. To the extent that the contents of the Complaint in Civil Action are based on information furnished to counsel and obtained by him during the course of this lawsuit, the affiant has relied upon counsel in taking this verification. All statements are founded upon reasonable belief. This verification is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. YO q N I LIM DATED: Qty /Y-- 06 VERIFICATION CHOON HWAN JO, hereby states that she is one of the Plaintiffs in this action and is authorized to take this Verification on behalf of herself and DONG WON JO and verifies that the within COMPLAINT is based on firsthand information and on information furnished to counsel and obtained by him in the course of this lawsuit. The language of the COMPLAINT is that of counsel and not of the affiant. To the extent that the contents of the COMPLAINT is based on information furnished to counsel and obtained by him during the course of this lawsuit, the affiant has relied upon counsel in taking this verification. All statements are founded upon reasonable belief. This verification is made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. C O AN JO :e ? DATED: 0 ? // o C7 ? n . Y N ' CO .. p-r 06HB-00051 LAW OFFICE OF SNYDER & DORER 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won (Case No.: 05-6026 Jo, h/w, Plaintiffs vs. Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo ?IURY TRIAL DEMANDED a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant AND NOW comes the Defendant, Jong Doc Lim, by his attorney, JoAnne E. Kinzel, Esquire, and sets forth the following Answer to the Plaintiffs' Complaint: 1. Paragraph 1 of the Complaint is admitted. 2.-3. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations in paragraphs 2 and 3 of the Complaint. Therefore, said allegations are denied and strict proof is demanded. 4. Paragraph 4 of the Complaint is admitted to the extent that Defendant resides at the address as set forth in paragraph 4 of the Complaint and was the owner/operator of the motor vehicle which was involved in the accident. The allegation that the accident occurred a! "hereinafter described" is denied generally pursuant to Pa. R. C. P. §I029(e). 5. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 5 of the Complaint tha the intersection in question was controlled by a "working" traffic signal. Therefore, said allegations are denied and strict proof is demanded. The remaining allegations in paragraph of the Complaint are admitted. 6. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 6 of the Complaint. Therefore, said allegations are denied and strict proof is demanded. The allegation in paragraph 7 of the Complaint that Defendant made an illegal left turn is denied as a conclusion of law, and is also denied generally pursuant to Pa.R.C.P. §1029(e). It is admitted, however, that Defendant was making a left turn and that a collision occurred between his vehicle and another vehicle. After reasonable investigation, Defendant without knowledge or information sufficient to form a belief as to the truth of the remaining allegations in paragraph 7. Therefore, they are denied and strict proof is demanded. 8.-9. The allegations in paragraphs 8 and 9 of the Complaint, including 9(a) through 90) are denied generally pursuant to Pa. R. C. P. §1029(e). By way of further Answer, paragraph 9(a), (b), (e), (f), (g), (h) and (i) are conclusions of law to which no response is required. COUNT I - YOUNG YI LIM VS. JONG DOO LIM 10. In response to paragraph 10 of the Complaint, Defendant incorporates herein by reference paragraphs 1 through 9 above as though set forth at length. 11.-15. The allegations in paragraphs 11 through 15 of the Complaint that Plaintiff's injuries and damages were the result of Defendant's negligence are conclusions of law to which no response is required. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining allege in paragraphs 11 through 15. Therefore, they are denied and strict proof is demanded. WHEREFORE, Plaintiffs' Complaint should be dismissed with costs in this Defendant's behalf sustained. COUNT II - CHOON HWAN JO VS. JONG DOO LIM 16. In response to paragraph 16 of the Complaint, Defendant incorporates herein by reference paragraphs 1 through 15 above as though set forth at length. 17.-21. The allegations in paragraphs 17 through 21 of the Complaint that Plaintiff's injuries were caused by Defendant's negligence are conclusions of law to which no response i is required. After reasonable investigation. Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining allegations in paragraphs 17 through 21. Therefore, they are denied and strict proof is demanded. WHEREFORE, Plaintiffs' Complaint should be dismissed with costs in this Defendant's behalf sustained. COUNT III - DONG WON JO VS. JOHN DOO LIM 22. In response to paragraph 22 of the Complaint, Defendant incorporates herein by reference paragraphs 1 through 21 above as though set forth at length. 23. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations in paragraph 23 of the Complaint. Therefore, they are denied and strict proof is demanded. WHEREFORE, Plaintiffs' Complaint should be dismissed with costs in this Defendant's behalf sustained. Respectfully submitted, LAW OFFICE OF SNYDER & DORER By: Qk ? JJoAmit- . Kinzel, Esquire Identification No. 55453 Attorney for Defendant Date: June 8. 2006 06HB-00051 LAW OFFICE OF SNYDER & DORER 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won ase No.: 05-6026 Jo, h/w, Plaintiffs VS. JURY TRIAL DEMANDED Jong Don Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant I, Jong Doo Lim , verify that the statements made in the forego Answer of Defendant to Plaintiffs' Complaint, which are within the personal knowledge of undersigned, are true and correct, and as to the facts based on the information of others, undersigned, after diligent inquiry, believe them to be true. And further, this Verification is signed the recommendation of my attorneys, who advise me that the allegations and language in this docum are required legally to raise issues for resolution at trial, by the Court, or by continuing investigat and preparation for trial. I understand that some of these allegations may prove inappropriate al investigation and trial preparation are complete and I leave the determination of these matters to attorneys on their advice. I understand that all statements herein are made subject to the penalties of 18 Pa.C.S.A. relating to unswom falsifications to authorities. Dated: P' 1D? - ZD Ang Doo Lim 06HB-00051 LAW OFFICE OF SNYDER & DORER 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won (Case No.: 05-6026 Jo, h/w, Plaintiffs Vs. ?JURY TRIM. DEMANDED Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant JoAnne E. Kinzel, Esquire, hereby certifies that she is the attorney for the Defendant herein, and that she caused a true and correct copy of the attached Answer of Defendant to Plaintiffs' Complaint to be served by regular first class mail upon: Louis I. Lipsky, Esquire 1101 Market Street - Suite 2820 Philadelphia, PA 19107 Date: June 8, 2006 JoAnne Esquire Attorney for D endant ca ^?' o t ?? °n ?7 ? ?? ? T ., T'1 W t SC `l7 I) ? ?, (`a ?i Cl !7 ^ 1+ L b _' ;- C ,()(DER & DORER .tE, SUTTE 503 /17011 .UMBER: (717) 731-0988 ,iY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won Case No.: 05-6026 Jo, h/w, Plaintiffs VS. Y TRIAL DEMANDED Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant MOTION OF DEFENDANT TO COMPEL PLAINTIFFS' ANSWERS TO DEFENDANT'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS 1. The present action arises from an alleged motor vehicle accident occurring on or about December 3, 2003, on Gettysburg Road and Wesley Drive in Lower Allen Township, Cumberland County, Pennsylvania. 2. The present action was commenced by the filing of a Writ of Summons on or about November 18, 2005. 3. On or about April 12, 2006, Defendant's Interrogatories were served on the Plaintiffs. A copy of said Interrogatories are attached hereto and marked as Exhibit "A". 4. On or about April 12, 2006, Defendant's Re quest for Production of Documents was served on the Plaintiffs. A copy of said Request for Production of Documents is attached hereto and marked as Exhibit "B". 5. On or about June 12, 2006, defense dduhge- l advised Plaintiffs' counsel of her desire to receive answers to the aforesaid discovery. A copy of said correspondence is attached hereto and marked as Exhibit "C". 6. To date, defense counsel has received no response nor objections to the Interrogatories or Request for Production of Documents. 7. Pursuant to the Pennsylvania Rules of Civil Procedure, the Plaintiffs responses to the Interrogatories and Request for Production of Documents are overdue. 8. It is respectfully requested that your Honorable Court issue an Order directing the Plaintiffs to provide responses to the Interrogatories and Request for Production of Documents or impose appropriate sanctions against the Plaintiffs. WHEREFORE, Defendant, respectfully requests that this Honorable Court issue an Order directing the Plaintiffs to respond to Defendant' s Interrogatories and Request for Production of Documents or impose appropriate sanctions against the Plaintiffs. Respectfully submitted, LAW OFFICE OF SNYDER & DORER By. Identi yiaiion No. 55453 Attorney for Defendant Date: July 24, 2006 P-Xh?bi+ 06HB-00051 LAW OFFICE OF SNYDER & DORER 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won ase No.: 05-6026 Jo, h/w, Plaintiffs Vs. Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant Y TRIAL DEMANDED .1-. --- .TORIES ADDRESSED TO: Plaintiffs, Young Li Lim and Choon Hwan Jo and Dong Won Jo, h/w The Defendant propounds the following Interrogatories to be answered under oath pursuant to Pa. R.C.P. 4005, 4006 by the Plaintiffs within thirty (30) days after service. The foregoing Interrogatories are to be regarded as continuing and you are requested to provide, by way of supplementary answers thereto, such additional information as may hereafter be obtained by you, or any person on your behalf, which will augment or otherwise modify any answers now given to the foregoing Interrogatories pursuant to Pa. R.C.P. 4007.4. Such supplemental responses are to be served upon the Defendant seasonably after receipt of such information. 1. PERSONAL INFORMATION: PLEASE PROVIDE THE FOLLOWING INFORMATION FOR EACH PLAINTIFF INVOLVED IN I THIS ACTION: (A) FULL NAME AND ANY PRIOR NAMES USED FROM THE TIME OF THE INCIDENT FOR WHICH THIS ACTION IS BROUGHT. (B) CURRENT ADDRESS-AND ANY PRIOR ADDRESSES USED FROM THE TIME OF THE INCIDENT FOR WHICH THIS ACTION IS BROUGHT. (C) DATE OF BIRTH. (D) SOCIAL SECURITY NUMBER. -4,-! .--i 2. CURRENT EMPLOYMENT: FOR EACH PLAINTIFF PLEASE STATE: (A) CURRENT PLACE OF EMPLOYMENT, POSITION AND LENGTH OF CURRENT EMPLOYMENT; AND (B) THE PLACE OF EMPLOYMENT AND POSITION AT THE TIME OF THE INCIDENT, IF DIFFERENT. - 40 3. INJURIES: DESCRIBE SEPARATELY EACH INJURY EACH PLAINTIFF SUSTAINED IN THE INCIDENT AND THE APPROXIMATE DATE ON WHICH EACH PLAINTIFF RECOVERED FROM EACH SUCH INJURY. 4. HEALTHCARE PROVIDERS: IDENTIFY EACH HEALTH CARE PROVIDER WHO HAS EXAMINED, TREATED OR RENDERED SERVICES TO EACH PLAINTIFF BECAUSE OF THIS INCIDENT, INCLUDING THE DATES OF SUCH SERVICES AND THE CHARGES FOR SAME. 5. MEDICAL EXPENSES AND INSURANCE PAYMENTS: STATE THE TOTAL AMOUNT OF MEDICAL EXPENSES INCURRED BY EACH PLAINTIFF I THAT RELATES TO THIS INCIDENT, THE AMOUNT COMPENSATED BY FIRST PARTY BENEFITS, THE AMOUNT, IF ANY, SUBJECT TO A LIEN OF ANY SORT, THE IDENTITY (INCLUDING THE NAME, ADDRESS, AND POLICY NUMBER OF ANY LIENHOLDER, AND THE AMOUNT CLAIMED TO BE RECOVERABLE AT TRIAL. 6. TERMINATION OF MEDICAL SERVICES: WHEN AND BY WHOM WAS EACH PLAINTIFF LAST EXAMINED OR GIVEN MEDICAL ATTENTION FOR THE INJURIES RECEIVED IN THIS INCIDENT? i- ! ...._... 7. CONTINUATION OF MEDICAL SERVICES: IF THE PLAINTIFF IS STILL BEING TREATED FOR THE INJURIES RECEIVED IN THIS INCIDENT, IDENTIFY BY WHOM AND STATE HOW FREQUENTLY SUCH TREATMENTS ARE BEING GIVEN NOW, THE NATURE OF THE TREATMENT BEING ADMINISTERED, AND THE EXTENT TO WHICH TREATMENT WILL BE REQUIRED IN THE FUTURE. 8. PRIOR CONDITIONS: EXPLAIN ALL PRIOR HEALTH PROBLEMS OR INJURIES AND IDENTIFY THE HEALTH PROVIDERS WHO TREATED EACH PLAINTIFF FOR THOSE INJURIES IN THE LAST SIX (6) YEARS. 9. FAMILY PHYSICIAN: PLEASE STATE THE NAME AND ADDRESS OF YOUR FAMILY PHYSICIAN FOR THE LAST FIVE (5) YEARS. - 10. PRIOR OR SUBSEQUENT ACCIDENTS: IF BEFORE OR AFTER THE INCIDENT WHICH IS THE SUBJECT OF THIS LAWSUIT, ANY PLAINTIFF WAS INVOLVED IN ANY OTHER INCIDENT INVOLVING INJURIES TO ANY PART OF T'. BODY, PLEASE STATE THE TYPE OF INCIDENT INVOLVED AND THE HEALTH CARE PROVIDERS WHO RENDERED TREATMENT FOR THOSE INJURIES. 111. DISABILITY: DOES ANY PLAINTIFF CONTEND THAT HE OR SHE HAS BEEN PERMANENTLY INJURED AS A RESULT OF THIS INCIDENT? IF SO, PLEASE DESCRIBE THE EXACT NATURE OF THE ALLEGED INJURY AND THE IDENTITY OF ANY HEALTH CARE PROVIDER WHO HAS INFORMED ANY PLAINTIFF THAT THE INJURY IS PERMANENT. 12. LOSS OF EARNINGS: IS ANY PLAINTIFF MAKING A CLAIM FOR LOSS OF EARNINGS OR IMPAIRMENT OF EARNING CAPACITY BECAUSE OF THIS INCIDENT? IF SO, THEN PLEASE PROVIDE THE FOLLOWING INFORMATION OF EACH: _-_ EACH-.EMPLOYER, JOR TITLE AND DESCRIPTION OF DUTIES AS WELL AS MONTHLY OR. I WEEKLY RATE OF PAY AT THE TIME OF THIS INCIDENT; (B) THE INCLUSIVE DATES DURING WHICH ANY PLAINTIFF ALLEGES HE OR SHE WAS UNABLE TO WORK AS A RESULT OF THIS INCIDENT AND THE TOTAL AMOUNT OF EARNINGS AND PLAINTIFF LOST BECAUSE OF THIS ABSENCE; (C) THE SOURCE AND AMOUNT OF ANY WAGES OR SALARY RECEIVED SINCE THIS INCIDENT; AND .6 (D) THE DATE ON WHICH ANY PLAINTIFF FIRST RETURNED TO WORK FOLLOWING THE PLAINTIFF HAS WORKED SINCE THE - INCIDENT WITH INCLUSIVE DATES OF EMPLOYMENT, EACH JOB TITLE ANY PLAINTIFF HAS HELD AND EACH MONTHLY OR WEEKLY RATE OF PAY WHICH ANY PLAINTIFF HAS RECEIVED FROM THE DATE OF STARTING WORK AGAIN AFTER THIS INCIDENT UNTIL THE PRESENT TIME. (E) PLEASE PROVIDE A DETAILED DESCRIPTION OF YOUR TYPICAL WORK DAY PRIOR TO THE ACCIDENT. (F) PLEASE LIST THE NAMES, ADDRESSES AND PHONE NUMBERS OF ALL EMPLOYEES WHO WORKED FOR YOU IN THE 5 YEAR PERIOD BEFORE THE ACCIDENT. (G) PLEASE LIST THE NAMES, ADDRESSES AND PHONE NUMBERS OF ALL EMPLOYEES WHO (H) PLEASE LIST THE NAMES, ADDRESES AND PHONE NUMBERS OF ALL EMPOYEES WHO CURRENTLY WORK FOR YOU. 13. IMPAIRED EARNING CAPACITY: IS ANY PLAINTIFF MAKING A CLAIM FOR IMPAIRED EARNING CAPACITY BECAUSE OF THIS INCIDENT? IF YES, PLEASE STATE THE ACTUAL VALUE OF ANY PLAINTIFF'S IMPAIRED EARNING CAPACITY, SETTING OUT THE MANNER IN WHICH SAID VALUE WAS CALCULATED, AND BY WHOM. 114. STATEMENTS: HAS ANY PLAINTIFF OR ANYONE ACTING ON ANY PLAINTIFF'S BEHALF OBTAINED ANY STATEMENTS, REPORTS, MEMORANDUM OR TESTIMONY IN ANY FORM FROM ANY PERSON RELATING TO THIS INCIDENT. IF SO, PLEASE IDENTIFY FROM WHOM THE STATEMENT WAS I TAKEN, THE DATE OF THE STATEMENT AND PROVIDE A COPY IN ANSWER TO THIS 1 INTERROGATORY. 15. WITNESSES: IDENTIFY ANY WITNESS WHO HAS ANY KNOWLEDGE OF OR INFORMATION AS TO THE FACTS PERTAINING TO THIS INCIDENT. ALSO PROVIDE A SUMMARY OF THE INFORMATION WHICH EACH WITNESS HAS CONCERNING THIS INCIDENT. IDENTIFY ALL EXPERTS WHO ANY PLAINTIFF EXPECTS TO CALL AT THE TRIAL OF THIS CASE, AND PURSUANT TO PA R.C.P. 4003.5(A)(1)(B), STATE THE SUBSTANCE OF THE FACTS AND OPINIONS TO WHICH ANY PLAINTIFF'S EXPERT WILL TESTIFY AND THE SUMMARY OF THE GROUNDS FOR EACH OPINION. THE FACTS, OPINIONS AND GROUNDS OF THE EXPERT MAY BE CONTAINED IN AN EXPERT REPORT WHICH MAY BE ATTACHED. SUCH REPORT OR ANSWER TO THIS INTERROGATORY SHOULD BE SIGNED BY ANY PLAINTIFF'S EXPERT. 17. PHOTOGRAPHS, DOCUMENTS AND THINGS: IF ANY PLAINTIFF, OR ANYONE ACTING ON ANY PLAINTIFF'S BEHALF, HAS OR KNOWS OF ANY PHOTOGRAPHS, DIAGRAMS, MEASUREMENTS, SURVEYS OR OTHER DESCRIPTIONS REGARDING OR RELATING IN ANY WAY TO THIS INCIDENT, PLEASE IDENTIFY THOSE ITEMS. IN LIEU OF ANSWERING THE FOREGOING INTERROGATORY, COPIES OF ANY SUCH ITEMS MAY 4 BE PROVIDED AS ATTACHMENT TO THESE ANSWERS. 18. RELATED LAWSUITS: PLEASE IDENTIFY BY CAPTION, DOCKET NUMBER AND COURT ANY OTHER LAWSUITS ARISING FROM THIS INCIDENT OR RELATING TO THE INJURIES CLAIMED BY THE PLAINTIFF IN THIS SUIT, OR IN WHICH ANY PLAINTIFF HAS BEEN INVOLVED. 119. PLEASE IDENTIFY ANY OTHER CLAIMS FILED OR DEMANDS MADE BY ANY PLAINTIFF AGAINST ANYONE OTHER THAN DEFENDANTS IN THIS ACTION FOR ANY DAMAGES OR INJURIES ARISING OUT OF OR RELATED TO THIS INCIDENT. 20. PRIOR CONVICTIONS: HAVE YOU BEEN CONVICTED OR PLED GUILTY TO ANY CRIME WITHIN THE PAST TEN (10) YEARS. IF SO, PLEASE STATE FOR EACH CONVICTION OR PLEA, THE OFFENSE CHARGED, THE COURT CAPTION AND DOCKET, AND THE DISPOSITION AND SENTENCE. -4,-! ._- 21. LIENS: WOULD ANY SETTLEMENT OR VERDICT SECURED BY YOU IN THIS MATTER BE SUBJECT TO ANY FEDERAL LIEN, STATE LIEN, FELA LIEN, WORKMEN'S COMPENSATION LIEN, OR ANY SIMILAR OR OTHER LIEN? IF SO, IDENTIFY THE HOLDER OF THE LIEN, THE AMOUNT OF THE LIEN, THE COSTS OF EXPENSES COVERED BY THE LIEN, AND THE CIRCUMSTANCE UNDER WHICH YOU ARE OR MIGHT BE OBLIGATED TO SATISFY THE LIEN. 1 22. VEHICLE INFORMATION: WITH RESPECT TO ANY POLICY OF MOTOR VEHICLE INSURANCE OF WHICH YOU WERE EITHER A NAMED INSURED OR INSURED AS OF THE DATE OF THE ACCIDENT REFERRED TO IN THE PLAINTIFFS' COMPLAINT, STATE: (A) THE NAME AND ADDRESS OF THE INSURANCE COMPANY ISSUING THE POLICY; (B) THE POLICY NUMBER: (C) EFFECTIVE DATES OF THE POLICY PERIOD; (D) YOUR TORT SELECTION PURSUANT TO 75 PA. C.S.A. §1705; (E) WHETHER YOU WERE A NAMED INSURED OR INSURED UNDER THE POLICY; FOR EACH REGISTERED VEHICLE THAT YOU OWNED AT THE TIME OF THE ACCIDENT, I STATE: (A) THE YEAR, MAKE AND LICENSE PLATE NUMBER(S) OF ALL SUCH VEHICLES; (B) WHETHER SUCH VEHICLE(S) WERE INSURED; AND (C) THE NAME, ADDRESS AND POLICY NUMBER OF THE COMPANY INSURING ALL SUCH VEHICLE(S). Respectfully submitted, LAW OFFICE OF SNYDER & DORER I By: ?1141 / JoAnne E. Kir zil, Esquire Identification No. 55453 Attorney for Defendant Date: April 12, 2006 06HB-00051 LAW OFFICE OF SNYDER & DORER 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won ase No.: 05-6026 Jo, h/w, Plaintiffs VS. Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant Y TRIAL DEMANDED TE OF JoAnne E. Kinzel, Esquire, hereby certifies that she is the attorney for the Defendant herein, and that she caused a true and correct copy of the attached Interrogatories of Defendant Addressed to the Plaintiffs to be served by regular first class mail upon: Louis I. Lipsky, Esquire 1101 Market Street - Suite 2820 Philadelphia, PA 19107 Date: April 12, 2006 l l' JoAnne E. kinzel, Esquire Attorney for Defendant EX hi bi + 5 06HB-00051 LAW OFFICE OF SNYDER & DORER 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won Case No.: 05-6026 Jo, h/w, Plaintiffs VS. JURY TRIAL DEMANDED Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant REQUEST FOR PRODUCTION OF DOCUMENTS OF DEFENDANTS UNDER Pa. R.C.P. 4409 ADDRESSED TO: Plaintiffs. Young Li Lim and Choon Hwan Jo and Dong Won Jo, h/w You are directed to produce the following documents pertaining to the incident, occurrence, or accident described in Plaintiffs' Complaint for inspection and copying at the offices of Snyder & Dorer, 214 Senate Avenue, Suite 503, Camp Hill, PA, 17011, pursuant to Pennsylvania Rule of Civil Procedure 4009: 1. The entire contents of any and all claims and investigation files prepared in this matter, however labeled, excluding references to mental impressions, conclusions or opinions representing the value or merit of the claim or defense, or respecting strategies or tactics in privileged communications from counsel. 2. All statements, memoranda, or writings, whether signed or unsigned, of any and all witnesses, including any and all statements, memoranda, and writings of Plaintiff. 3. All photographs, recordings, films, charts, sketches, graphs and diagrams taken and/or prepared. 4. Reports of, or from, any and all experts who will testify at trial, or whom you expect will testify at trial. 5. All statements concerning this action or its subject matter previously made by any party or witness pursuant to Pa. R.C.P. 4003.4. 6. All bills, receipts, reports, diagnosis (including x-ray and like diagnostic reports) or prognosis and records of any and all medical, physical, psychiatric and/or psychological treatment by any doctor, hospital, psychologist, and psychiatrist, pharmacy or medical facility for any injury, treatment or damage received by Plaintiff for any of the alleged incidents referred to in Plaintiff s Complaint. 7. All bills of any kind incurred by Plaintiff as a result of the alleged incident, occurrence, or accident. 8. All medical records, employer statements, IRS W-2 Forms, and Income Tax Returns (for the preceding five (5) years), lost wages and/or employment records and all other writings, including expert reports, establishing any claim Plaintiff may assert for-losLearnings and lost earning capacity and for any other financial losses. 9. All documents, exhibits, or other tangible physical objects, and/or reports, of any kind whatsoever that will be presented or introduced into evidence at time of trial. Respectfully submitted, LAW OFFICE OF SNYDER & DORER _ JoAnne E. Kinzel, Esquire Attorney'for Defendant Identification No. 55453 Date: April 12, 2006 06HB-00051 LAW OFFICE OF SNYDER & DORER 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won ase No.: 05-6026 Jo, h/w, Plaintiffs Vs. Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant Y TRIAL DEMANDED TE OF JoAnne E. Kinzel, Esquire, hereby certifies that she is the attorney for the Defendant herein, and that she caused a true and correct copy of the attached Request for Production of Documents of Defendant Addressed to the Plaintiffs to be served by regular first class mail upon: Louis I. Lipsky, Esquire 1101 Market Street - Suite 2820 Philadelphia, PA 19107 Date: April 12, 2006 JoAnne E. Kinzel, Esquire Attorney`for Defendant Exhlbi+C LAW OFFICE OF SNYDER & DORER LAN1 OFFICE OF JILL R. SNYDER EmPl(Iccc,ot,Nar um%I& M-urlial [ntiuancr ('oarP.viv!, SNYDER & ANDREII1'S licthlrhrm, PA 1$01- Nor a PaivashiP Wc\furl, PA 15000 SNYDER & D'ANNF•NZIO 214 SENATE AVENUE, SUITE 503 SNYDER & ASSOCIATES Philadelphia, PA 1010' CAMP HILL, PENNSYLVANIA 17011 Plains, PA 18705 SNYDER & VERBEKE ?1 :1 731-0988 SNYDER & SHAFFER CONSHOHOCKEN, PA 19428 FA.\; (?1: ) 731-098 DOYLESTOWN, PA 18901 SNYDER & FLEMING REPLY TO: Greensburg, PA 15601 CAMP HILL DONALD R. DORER PARALEGALS JOANNE E. KINZEL DENISE E. KAUFFMAN LISA S. WOLFGANG Refer to: 06HB-00051 June 12, 2006 Louis I. Lipsky, Esquire 1101 Market Street - Suite 2820 Philadelphia, PA 19107 Re: Young Yi Lim and Choon Hwan Jo and Dong Won Jo, h/w vs. Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do Cumberland County: 05-6026 Dear Mr. Lipsky, Under cover of my letter to you of April 12, 2006, I served Defendant's Interrogatories and Request for Production of Documents Addressed to the Plaintiffs in the above matter, but I have received no responses or objections to same. Kindly advise as to when we may expect full and complete responses to these discovery requests. If I do not hear from you within five (5) days, I will be forced to file a Motion to Compel with the Court. Thank you for your attention to this matter. Sincerely, JoAnne E. Kinzel, Esquire JEK:dek 06HB-00051 LAW OFFICE OF SNYDER & DORER 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won Case No.: 05-6026 Jo, h/w, Plaintiffs vs. JURY TRIAL DEMANDED Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo aWa Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant CERTIFICATE OF SERVICE JoAnne E. Kinzel, Esquire, hereby certifies that she is the attorney for the Defendant herein, and that she caused a true and correct copy of the attached Motion of Defendant to Compel Plaintiffs' Answers to Defendant's Interrogatories and Request for Production of Documents to be served by regular first class mail upon: Louis I. Lipsky, Esquire 1101 Market Street - Suite 2820 Philadelphia, PA 19107 Date: July 24, 2006 E. Kinzel, Esquire for Defendant ;_ r - ' _-+-.i _-{ .... I ?.? 5 06HB-00051 LAW OFFICE OF SNYDER & DORER JUL 2 7 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won Case No.: 05-6026 Jo, h/w, Plaintiffs VS. Jong Don Lim a/k/a Jung Doo Lim a/k/a Jong Doo JURY TRIAL DEMANDED a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant ORDER OF COURT AND NOW, this S{ Day of hu!%ySC 2006, upon consideration of Defendant's Motion to Compel Plaintiff s Answers to Defendant's Interrogatories and Request for Production of Documents, said Motion is hereby GRANTED. The Plaintiffs are hereby ORDERED to provide all documents responsive to Defendant's Interrogatories and Request for Production of Documents within thirty (30) days of service of this Order. BY THE COURT: '? yd T LIPSKY & BRANDT, P.A. BY: LOUIS L LIPSKY, ESQUIRE ATTORNEY FOR PLAINTIFF 1101 MARKET STREET, SUITE 2820 PHILADELPHIA, PA 19107 (215) 922-6644 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Yi Lim Case No.: 05-6026 Plaintiff V. JURY TRIAL DEMANDED Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jung Do a/k/a Jung Do Defendant Louis I. Lipsky, Esquire hereby certifies that he is the attorney for Plaintiff Young Yi Lim herein, and that she caused a true and correct copy of the attached Responses of Plaintiff to Defendant's Request for Production of Documents to be served via first class mail, postage prepaid, upon: JoAnne E. Kinzel, Esquire Law Office of Snyder & Dorer 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Attorneys for Defendant 06ui° s I. Lipsky, E quire Identification No.: 46808 Attorneys for Plaintiff Dated: August 30, 2006 371471.1 8/23/2006 n ? a c ?,, rY, ? r;, r, 'r LT T ? T (?1 ? i ?? i _? J "{'. .?. ? .)'?= \ .' ? ?1?? . f LIPSKY & BRANDT, P.A. BY: LOUIS I. LIPSKY, ESQUIRE ATTORNEY FOR PLAINTIFF 1101 MARKET STREET, SUITE 2820 PHILADELPHIA, PA 19107 (215) 922-6644 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Yi Lim Case No.: 05-6026 Plaintiff V. JURY TRIAL DEMANDED Jong Doc Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jung Do a/k/a Jung Do Defendant Louis I. Lipsky, Esquire hereby certifies that he is the attorney for Plaintiff Young Yi Lim herein, and that she caused a true and correct copy of the attached Answers of Plaintiff to Defendant's Interrogatories to be served via first class mail, postage prepaid, upon: JoAnne E. Kinzel, Esquire Law Office of Snyder & Doter 214 Senate Avenue, Suite 503 Camp Hill, PA 17011 Attorneys for Defendant , , 1'?' a?, s I. Lipsky, Es ire Attorneys for Plaintiff Identification No.: 46808 Dated: August 30. 2006 371420.1 8/29/2006 m •_ --o' rr, ....t 06HB-00051 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won ase No.: 05-6026 Jo, h/w, Plaintiffs VS. JURY TRIAL DEMANDED Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo a/k/a Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant P&AECIPE TO SETTLE, DigcoNTrquE AND END TO THE PROTHONOTARY: Please mark the above-captioned case settled and discontinued. Date: 7 (' -) By: A )/1 Loui . Lipsky, Esquire 1101 Market Street - Suite 2820 Philadelphia, PA 19107 Attorney I.D. #__9 6 opo y Attorney for Plaintiffs 06HB-00051 LAW OFFICE OF SNYDER & DORER 214 SENATE AVENUE, SUITE 503 CAMP HILL, PA 17011 TELEPHONE NUMBER: (717) 731-0988 ATTORNEY FOR DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Young Li Lim and Choon Hwan Jo and Dong Won ase No.: 05-6026 Jo, h/w, Plaintiffs vs. JURY TRIAL DEMANDED Jong Doo Lim a/k/a Jung Doo Lim a/k/a Jong Doo &Wa Jung Doo a/k/a Jong Do a/k/a Jung Do, Defendant TE OF JoAnne E. Kinzel, Esquire, hereby certifies that she is the attorney for the Defendant herein, and that she caused a true and correct copy of the attached Praecipe to Settle, Discontinue and End to be served by regular first class mail upon: Louis I. Lipsky, Esquire 1101 Market Street -Suite 2820 Philadelphia, PA 19107 Date: December 3, 2007 "'JoAnne E. Kinzel, Esquire Attorney for Defendant c° !D -Ti