HomeMy WebLinkAbout06-1156SCHMIDT, RONCA & KRAMER, P.C.
By: Scott B. Cooper, Esquire
209 State Street
Harrisburg, Pa 17101
(717) 232-6300
(717) 232-6467
scooper(a srklaw.com Attorney for Plaintiff
DENISE BEARY :IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
V. :No.
AMANDA YEAGER
Defendant :CIVIL ACTION -LAW
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, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
SCHMIDT, RONCA & KRAMER, P.C.
By: Scott B. Cooper, Esquire
209 State Street
Harrisburg, Pa 17101
(717) 232-6300
(717) 232-6467
scoopengsrklaw.com Attorney for Plaintiff
DENISE BEARY :IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
V. :No.
AMANDA YEAGER
Defendant :CIVIL ACTION - LAW
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea
defenderse de las demandas que se presentan mas adelante en las siguientes
paginas, debe tomar accion dentro de los proximos veinte (20) dias despu6s de
la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio
de un abogado una comparecencia escrita y radicando en la Corte por escrito
sus defensas de, y objecciones a, las demandas presentadas aqui en contra
suya. Se le advierte de que si usted falla de tomar acci6n como se describe
anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma
de dinero reclamada en la demanda o cualquier otra reclamacion o remedio
solicitado par el demandante puede ser dictado en contra suya por la Corte sin
mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos
importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA
SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A
CERCA DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO,
ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE
AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO
COSTO A PERSONAS QUE CUALIFICAN.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
SCHMIDT, RONCA & KRAMER, P.C.
By: Scott B. Cooper, Esquire
209 State Street
Harrisburg, Pa 17101
(717) 232-6300
(717) 232-6467
scooper(&srklaw.com Attorney for Plaintiff
DENISE BEARY
Plaintiff,
V.
AMANDA YEAGER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:No. C)L
Defendant :CIVIL ACTION - LAW
COMPLAINT
AND NOW, comes the Plaintiff, DENISE BEARY, by and through
her attorneys, SCHMIDT, RONCA &. KRAMER, P.C. and hereby aver as
follows:
1. Plaintiff, DENISE BEARY, is an adult individual currently
and at all times relevant hereto resides at 916 Maplewood Lane, Enola
Cumberland County, Pennsylvania 17025.
2. Defendant, AMANDA YEAGER, is an adult individual
believed to be currently residing at 5223 Stuart Drive, Mechanicsburg,
Cumberland County, Pennsylvania 17055.
3. The facts which give rise to this cause of action occurred on
or about April 9, 2004 in the 3500 block of Trindle Road, heading west,
1
in Camp Hill Borough, Cumberland County, Pennsylvania at
approximately 5:00 p.m.
4. At the time of the accident, the Plaintiff, DENISE BEARY,
was the owner and operator of a motor vehicle that was traveling east on
Trindle Road.
5. At the aforementioned time and place, Donald Stevens was
traveling directly behind the Plaintiff.
6. At the aforementioned time and place, Defendant, AMANDA
YEAGER, was traveling directly behind Donald Stevens.
7. At the aforementioned time and place, the Defendant,
AMANDA YEAGER, failed to observe that both the Beary and Stevens
vehicles had slowed down and stopped, and was unable to stop her
vehicle in time.
8. Defendant, AMANDA YEAGER, hit Donald Stevens, causing
him to rear-end the Beary vehicle.
9. This chain reaction collision was in no way caused or
contributed to by the Plaintiff and was solely caused by the Defendant for
the reasons set forth below.
10. The accident either caused, aggravated, exacerbated and/or
contributed to the injuries set forth below.
COUNT I
DENISE BEARY v. AMANDA YEAGER
2
11. Paragraphs 1 through 10 of this Complaint are incorporated
herein by reference and made a part thereof as if set forth in full.
12. The negligence, carelessness and recklessness of the
Defendant, AMANDA YEAGER, consisted of including but no limited to
the following:
A. Operating her vehicle at an excessive rate of
speed under the circumstances;
B. Failing to have her vehicle under proper and
adequate control;
C. Failing to apply the brakes in time to avoid the
collision with the Stevens vehicle;
D. Failing to observe the Stevens and Beary
vehicles on the roadway;
E. Failing to operate her vehicle according to
existing traffic weather conditions and/or traffic controls;
F. Failing to keep a reasonable lookout for other
vehicles lawfully on the roadway;
G. Failing to keep a reasonable lookout;
H. Operating her vehicle in a manner not consistent
with the road conditions prevailing at the time;
1. Operating her vehicle in a manner so as to
create a dangerous situation for other vehicles on the
roadway;
3
J. Failing to drive at a speed allowing her to stop
within the assured clear distance ahead;
K. Failing to drive in a manner allowing her to stop
within the assured clear distance ahead;
L. Possibly operating her vehicle under fatigue;
M. Driving too close to the Stevens vehicle;
N. Possibly falling asleep while driving her vehicle;
0. Possibly operating her vehicle under the
influence of a foreign substance;
P. Failing to allow for a proper distance between
her vehicle and the Stevens vehicle;
Q. Operating her motor vehicle in violation of the
Pennsylvania Motor Vehicle Code for careless driving under
§3714, which is negligence per se.
13. As a direct and proximate result of the accident, the Plaintiff
sustained injuries including but not limited to the following:
A. Herniated Disc in Neck
B. Severe Headaches
C. Facial Numbness
14. As the sole and proximate result of the Defendant, AMANDA
YEAGER'S, negligence and the injuries sustained in the accident, the
Plaintiff incurred medical bills and may continue to incur medical bills
4
for treatment in the future and thus, a claim for these medical bills is
made.
15. As the direct and proximate result of the Defendant
AMANDA YEAGER'S, negligence, the Plaintiff has sustained a loss in
wages and may continue to incur lost wages in the future and thus, a
claim for these losses is made.
16. As a direct and proximate result of the Defendant, AMANDA
YEAGER'S, negligence, the Plaintiff has undergone in the past and may
continue to undergo in the future, great pain and suffering and thus, a
claim for these losses is made.
17. As a direct and proximate result of the Defendant, AMANDA
YEAGER'S, negligence, the Plaintiff may have been obliged to spend
various sums of money and incur various expenses for the injuries she
had suffered and may continue to incur the same in the future and thus,
a claim for these losses is made.
18. As a direct and proximate result of the Defendant, AMANDA
YEAGER'S, negligence, the Plaintiff may have suffered a permanent
diminution of her ability to enjoy life and life's pleasures and may
continue to suffer permanent diminution in the future and thus, a claim
for these losses is made.
19. As a direct and proximate result of the Defendant, AMANDA
YEAGER'S, negligence, the Plaintiff may have and may continue to suffer
5
permanent loss of her earning power and capacity and thus, a claim for
these losses is made.
20. As a direct and proximate result of the Defendant, AMANDA
YEAGER'S, negligence, the Plaintiff may have suffered special or general
damages, which may be revealed during discovery and thus, a claim for
these losses is made.
WHEREFORE, the Plaintiff, DENISE BERRY, demands judgment of
the Defendant, AMANDA YEAGER, in an amount in excess of an amount
requiring compulsory arbitration.
Date: 'L/0/Q6
Respectfully submitted,
SCHMIDT, RONCA & KRAMER, P.C.
By: /V
Scott B. Cooper, Esquire
I.D. No. 70242
209 State Street
Harrisburg, PA 17101
(717) 232-6300
(717) 232-6467 Fax
scoopera,srklaw.com
Attorney for Plaintiff
6
VERIFICATION BASED UPON PERSONAL
KNOWLEDGE AND INFORMATION SUPPLIED BY COUNSEL
I, DENISE BEARY, hereby verify that I am the Plaintiff in the
foregoing action and that the attached Complaint is based upon the
information that has been gathered by my counsel in preparation of this
lawsuit. The language of the Complaint is that of counsel and is not
mine. I have read the Complaint, and to the extent that it is based upon
information that I have given to counsel, it is true and correct to the best
of my knowledge, information, and belief. To the extent that the contents
of the Complaint are that of counsel, I have relied upon counsel in
making this Verification.
I understand that intentional false statements herein are made
subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn
falsifications made to authorities.
Date: -1$-06
DENISE BEA Y
U1
f
v
?? II S
( CG I
Johnson, Duffie, Stewart & Weidner
By: Jefferson J. Shipman, Esquire
I.D. No. 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
e-mail: jjs@jdsw.com
(717) 761-4540
DENISE BEARY,
V.
Plaintiff
AMANDA YEAGER,
Defendant
Attorney for Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
NO. 06-1156 CIVIL TERM
JURY TRIAL DEMANDED
NEW MATTER NOTICE
TO: Scott B. Cooper, Esquire
Schmidt, Ronca & Kramer, P.C.
209 State Street
Harrisburg, PA 17101
Attorneys for Plaintiff
You are hereby notified to plead to the enclosed New Matter within twenty (20)
days from the date of service.
JOHNSON, DUFFIE, STEWART & WEIDNER
By
e erson J. Shipman, Esquire
441.D. #: 51785
DATE: .3/ /2 3 /O(o Attorneys for Defendant
271188
Johnson, Duffie, Stewart & Weidner
By: Jefferson J. Shipman, Esquire
I.D. No. 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
e-mail: jjs@jdsw.com
(717) 761-4540
DENISE BEARY,
V.
Plaintiff
AMANDA YEAGER,
Defendant
Attorneys for
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 06-1156 CIVIL TERM
JURY TRIAL DEMANDED
ANSWER TO NEW MATTER
OF DEFENDANT
AND NOW, comes the Defendant, Amanda Yeager, by and through her
counsel, Johnson, Duffie, Stewart & Weidner, and Jefferson J. Shipman, Esquire, and
files the following Answer to New Matter:
1. Admitted upon information and belief.
2. Admitted.
3. Admitted, except as to the direction. It is believed that the vehicles were
traveling east at the time of the accident.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted in part, denied in part. It is admitted that Amanda Yeager was
unable to stop before making contact with the rear of the Stevens vehicle. The
remaining averments of Paragraph 7 are denied as stated.
8. Denied. After reasonable investigation Ms. Yeager is without sufficient
knowledge or information to form a belief as to the truth of the averments contained in
Paragraph 8 and the same are therefore denied.
9. Denied. The averments contained in Paragraph 9 are conclusions
of law and fact to which no response is required.
10. Denied. After reasonable investigation, Ms. Yeager is without sufficient
knowledge or information to form a belief as to the truth of the averments contained in
Paragraph 10 and the same are therefore denied and strict proof demanded at the time
of trial.
COUNTI
NEGLIGENCE
DENISE BEARY v. AMANDA YEAGER
11. Ms. Yeager incorporates herein by reference her answers to Paragraphs 1
through 10 above as though fully set forth herein at length.
12. Denied. The averments contained in Paragraph 12, and subparagraphs
A. through Q. are conclusions of law and fact to which no response is required. If a
response is deemed to be required, the averments contained therein are specifically
denied.
A. Denied. To the contrary, Ms. Yeager was operating her vehicle at
reasonable speed;
B. Denied. To the contrary, Ms. Yeager did have her vehicle under
proper and adequate control;
C. Denied. To the contrary, Ms. Yeager did attempt to apply the
brakes in time to avoid the collision;
D. Denied. To the contrary, Ms. Yeager did observe the vehicles on
the roadway;
E. Denied. To the contrary, Ms. Yeager did operate her vehicle
according to existing traffic/weather conditions and/or traffic controls;
F. Denied. To the contrary, Ms. Yeager did keep a reasonable look-
out for other vehicles on the roadway;
G. Denied. To the contrary, Ms. Yeager was keeping a reasonable
look-out;
H Denied. To the contrary, Ms. Yeager was operating her vehicle
consistent with road conditions;
1. Denied. To the contrary, Ms. Yeager was operating her vehicle in a
reasonable manner;
J. Denied. To the contrary, Ms. Yeager was driving at a safe speed;
K. Denied. To the contrary, Ms. Yeager was driving in a manner
allowing her to stop within the assured clear distance ahead;
L. Denied. To the contrary, Ms. Yeager was operating her vehicle
while she was alert and oriented;
M. Denied. To the contrary, Ms. Yeager was operating at a safe
distance behind the vehicle in front of her;
N. Denied. To the contrary, Ms. Yeager was alert and oriented while
driving her vehicle;
0. Denied. To the contrary, Ms. Yeager was operating her vehicle
while fully alert and oriented and not under the influence of any foreign
substance;
P Denied. To the contrary, Ms. Yeager was attempting to allow for
proper distance between the vehicles; and
Q. Denied. To the contrary, Ms. Yeager was operating her vehicle in a
careful and prudent manner.
13. Denied. After reasonable investigation, Ms. Yeager is without sufficient
knowledge or information to form a belief as to the truth of the averments contained in
Paragraph 13, relating to Plaintiffs alleged injuries, and the same are therefore denied.
14. Denied. The averments contained in Paragraph 14 are, in part,
conclusions of law to which no response is required. After reasonable investigation, Ms.
Yeager is without sufficient knowledge or information to form a belief as to the truth of
the remaining averments contained in Paragraph 14.
15. Denied. The averments contained in Paragraph 15 are, in part,
conclusions of law to which no response is required. After reasonable investigation, Ms.
Yeager is without sufficient knowledge or information to form a belief as to the truth of
the remaining averments contained in Paragraph 15.
16. Denied. The averments contained in Paragraph 16 are, in part,
conclusions of law to which no response is required. After reasonable investigation, Ms.
Yeager is without sufficient knowledge or information to form a belief as to the truth of
the remaining averments contained in Paragraph 16.
17. Denied. The averments contained in Paragraph 17 are, in part,
conclusions of law to which no response is required. After reasonable investigation, Ms.
Yeager is without sufficient knowledge or information to form a belief as to the truth of
the remaining averments contained in Paragraph 17.
18. Denied. The averments contained in Paragraph 18 are, in part,
conclusions of law to which no response is required. After reasonable investigation, Ms.
Yeager is without sufficient knowledge or information to form a belief as to the truth of
the remaining averments contained in Paragraph 18.
19. Denied. The averments contained in Paragraph 19 are, in part,
conclusions of law to which no response is required. After reasonable investigation, Ms.
Yeager is without sufficient knowledge or information to form a belief as to the truth of
the remaining averments contained in Paragraph 19.
20. Denied. The averments contained in Paragraph 20 are, in part,
conclusions of law to which no response is required. After reasonable investigation, Ms.
Yeager is without sufficient knowledge or information to form a belief as to the truth of
the remaining averments contained in Paragraph 20.
WHEREFORE, the Defendant, Amanda Yeager, respectfully requests that
judgment be entered in her favor and that Plaintiff's Complaint be dismissed with
prejudice.
NEW MATTER
By way of additional answer and reply, the Defendant interposes the following
New Matter defenses:
21. That if it should be found that there was any negligence on the part of the
Defendant, which is denied, then in that event any such negligence was not a
substantial factor nor factual cause of the Plaintiffs harm.
22. That the Plaintiff's alleged injuries may have been pre-existing.
23. That the Plaintiff may have failed to mitigate her damages.
24. That the accident, and any alleged injuries, may have been caused by
third parties or entities not presently involved in this action.
25. That the accident, and any injuries allegedly sustained by the Plaintiff,
may have been caused by a sudden emergency and/or intervening superceding cause.
26. That the Plaintiffs action may be barred in whole or in part by the
Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. §1701, et sec.
and by the Limited Tort Option.
WHEREFORE, the Defendant, Amanda Yeager, respectfully requests that
judgment be entered in her favor and that Plaintiffs Complaint be dismissed with
prejudice.
DATE : 3/s 3/
271188
Respectfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
B ' ) / z??K
erson J. Ship an, Esq
uire
e
rneys I.D. #: 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
e-mail: jjs@jdsw.com
Attorneys for Defendant
VERIFICATION
I, Amanda Yeager, have read the foregoing Answer with New Matter and hereby
affirm that it is true and correct to the best of my personal knowledge, or information and
belief. This Verification and statement is made subject to the penalties of 18 Pa. C.S.
§4904 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. §4904.
Amanda Yeager
DATE:
271199 3 1 rte- 1W
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing has been duly served upon the
following, by depositing the same in the United States Mail, postage prepaid, in
Lemoyne, Pennsylvania, on s
Scott B. Cooper, Esquire
Schmidt, Ronca & Kramer, P.C.
209 State Street
Harrisburg, PA 17101
Attorneys for Plaintiff
JOHNSON, DUFFIE, STEWART & WEIDNER
I.D.N: 51785
P.O. Box 109
Lemoyne, PA 17043
717-761-4540
Attorneys for Defendant
271188
('
?. -r
-a
" -'n
1_
r..?
?..1
? _:?
1'
?:
SCHMIDT, RONCA & KRAMER, P.C.
By: Scott B. Cooper, Esquire
209 State Street
Harrisburg, Pa 17101
(717) 232-6300
(717) 232-6467
scooperc(bsrklaw.com Attorney for Plaintiff
DENISE BEARY :IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
V. :No. 2006-01156
AMANDA YEAGER
Defendant :CIVIL ACTION - LAW
PLAINTIFF'S REPLY TO NEW MATTER OF DEFENDANT
AND NOW, comes the Plaintiff, Denise Beary, by and through her
counsel, Schmidt, Ronca, & Kramer, P.C. and Scott B. Cooper, Esquire and
files the following Plaintiffs Reply to New Matter as follows:
21. Paragraph 21 of Defendant's New Matter is a conclusion of law by
which no response is deemed required. By way of further answer if a
responsive pleading is deemed required, the averments in Paragraph 21 are
denied. After reasonable investigation the Plaintiff is without sufficient
knowledge or information as to form a belief as to the truth of the averments
contained in Paragraph 21 and, therefore, the same are denied and strict proof
is demanded thereof at the time of trial.
22. Paragraph 22 of Defendant's New Matter is a conclusion of law by
which no response is deemed required. By way of further answer if a
responsive pleading is deemed required, the averments in Paragraph 22 are
denied. After reasonable investigation the Plaintiff is without sufficient
1
A
knowledge or information as to form a belief as to the truth of the averments
contained in Paragraph 22 and, therefore, the same are denied and strict proof
is demanded thereof at the time of trial.
23. Paragraph 23 of Defendant's New Matter is a conclusion of law by
which no response is deemed required. By way of further answer if a
responsive pleading is deemed required, the averments in Paragraph 23 are
denied. After reasonable investigation the Plaintiff is without sufficient
knowledge or information as to form a belief as to the truth of the averments
contained in Paragraph 23 and, therefore, the same are denied and strict proof
is demanded thereof at the time of trial.
24. Paragraph 24 of Defendant's New Matter is a conclusion of law by
which no response is deemed required. By way of further answer if a
responsive pleading is deemed required, the averments in Paragraph 24 are
denied. After reasonable investigation the Plaintiff is without sufficient
knowledge or information as to form a belief as to the truth of the averments
contained in Paragraph 24 and, therefore, the same are denied and strict proof
is demanded thereof at the time of trial.
25. Paragraph 25 of Defendant's New Matter is a conclusion of law by
which no response is deemed required. By way of further answer if a
responsive pleading is deemed required, the averments in Paragraph 25 are
denied. After reasonable investigation the Plaintiff is without sufficient
knowledge or information as to form a belief as to the truth of the averments
contained in Paragraph 25 and, therefore, the same are denied and strict proof
is demanded thereof at the time of trial.
26. Paragraph 26 of Defendant's New Matter is a conclusion of law by
which no response is deemed required. By way of further answer if a
responsive pleading is deemed required, the averments in Paragraph 26 are
2
denied. After reasonable investigation the Plaintiff is without sufficient
knowledge or information as to form a belief as to the truth of the averments
contained in Paragraph 26 and, therefore, the same are denied and strict proof
is demanded thereof at the time of trial. By way of further answer, Plaintiff had
full tort. (See Declaration Sheet attached as Exhibit "A".)
WHEREFORE, the Plaintiff, Denise Beary, respectfully requests that the
judgment would be entered in her favor and that the Defendant's answer and
new matter would be dismissed without prejudice.
DATE: `ff jib
Respectfully submitted,
SCHMIDT, RONCA & KRAMER, P.C.
By:
Scott B. Cooper, Esquire
I.D.# 70242
209 State Street
Harrisburg, PA 17101
(717) 232-6300
(717) 232-6467 Fax
scooper@srklaw.com
Attorney for Plaintiff
3
EXHIBIT
APR-11-2005 MON 08:44 AM
BLGRPA
ERIE
!32' INSURANCE
GROUP
[7T 100 Ene Ins. Pt
EME0Elre, PA 15530 CONTINUATION NOTICE
AA3222 JOHN LOVE.INSURANCE INC
L„IIL„IIL,,,I d,ll„J?I,,,,dIJ, dl.,I. dl..I„I,,,,IN
DENISE E BEARY
1268 TIMBER VIEW DR
MECHANTCSBURG-PA .17050-9148
FAX NO. P. 02
ERIE INSURANCE EXCHANGE
PIONEER FAMILY AUTO POLICY
07/07/04 TO 07/07/05 007 0706461 N
AS LISTED BELOW
AGENT - JOHN LOVE INSURANCE INC, 307 MAIN ST.
AGENT PHONE - (814) 782-3894 SHIPPENVILLE PA 16254 3907
ITEM 4. AUTOS COVERED
AUTO YR MAKE VIN ST TER SYM RATING CLASS DDP
1 01 KIA SPORTAGE KNDJA723315076463 PA 4F H A3C-M FS30
ITEM 5. INSURANCE IS PROVIDED WHERE A PREMIUM OR INCL IS SHOWN FOR THE
LOWS-
UA
A
S
O
R
COVERAGE. COVERAGES, LIMITS AND L P
EMIU
S ARE A
F
L
ANN
- #1
*****GOOD DRIVER RATES APPLY*****
- THE FULL.TORT OPTION APPLIES TO ALL PRIVATE PASSENGER VEHICLES. ---
$gl
OM//PERSON $30OM/4CC;
LIHODILY-I NJURYC
T 0.9
E
g
E
SOI7M/ACC
Y
E
E
P 12
FIT
B
N
FIRST
PART
- - -- - ---
-
MEDICAL EXPENSE $5M 43
INCOME LOSS $lM/MONTH, $15M MAXIMUM 14
2
ACCIDENTAL DEATH $g5M
FUNERAL BENEFIT $2.5M 2
RAGE
-
UNINSURED MOTORISTS COVE
Eg
//
VERPGEC-STACKED
O
C
R
E
O
`
N 19
S
O
I
D
MO
UNDE
PORIST
SUR
50D INJ A5100M/PERSON $300M//ACC-STACKED
G
- 146
ES
PHYSICAL D MAGE COVERA
COMPREHENSIVE - $50 DED 130
COLLISION - $250 DED 300
OPTIONAL COVERAGES-
ROAD SERVICE 4
TRANSP EXPENSES - COLL $20/DAY, $900/LOSS 12
TOTAL ANNUAL PREMIUM FOR EACH AUTO 893
TOTAL ANNUAL POLICY PREMIUM $ 893
ITEM 6. APPLICABLE POLICY ENDORSEMENTS EXCEPTIONS TO DECLARAJIONS ITEMS
ALL AUTOSAFPU01 04/N, UH 106 05/01, AFONOI 10/98, AFPA03 04/0.
ANTI
MULTI
$1
PASSIVE RESTRAINT DISCOUNT APPLIES - DUAL ATRBAGS AUTO 7
ANTI-LOCK BRAKE DISCOUNT APPLIED AUTO I
**k#*#***k*ir*******k*k#****k****##*k******k*kkk#***kk***#iFk*k****R'X
* THE SURCHARGE FOR THE 05`22/02 ACCIDENT HAS BEEN FORGIVEN
* UNDER ERIE'S FIRST ACCIDENT FORGIVENESS PLAN.
kk**k**kkk*k*k*k*****k*1tk******kk*****k*#*k*****k*****kk*******YC***
EXPLANATION OF ADULT &/OR YOUTHFUL DRIVER RATING CLASS
AUTO 1-FEMALE, SINGLE, AGEM30-340NE WAY
MISCELLANEOUS INFORMATION
vn WFS 06/05/04
APR-11-2005 MON 08:45 AM FAX NO,
04/22/2004 AT 09:41 AM
ERIE INSURANCE GROUP
HARRISBURG OFFICE
P.O. BOX:621
BOILING :SPRINGS, PA 170.07-0621
(717)486-8756 FAX: (717)486-4056
ESTIMATE OF RECORD
P. 03
Req: BORGESON K
010170742947003
WRITTEN BY: C. STEINER #152145 04/22/2004 09:29 AM
ADJUSTER: C. STEINER #152145
INSURED: AMANDA YEAGER
OWNER: DENISE BEARY
ADDRESS: 1268 TIMBERVIEW DR
MECHANICSBURG, PA 17055-0000
EVENING: (717173.7-7787
CELLULAR: (717)645-5756
CLAIM #010170742947003
POLICY #QO7 0706461
DATE OF LOSS: 04/09/2004 AT 05:00 PM
TYPE OF LOSS: PROPERTY DAMAGE
POINT OF IMPACT: 6. REAR
INSPECT MCCAFFERTY COLLISION CENTER
LOCATION: ATT: BODY SHOP
6365 BASHORE RD
MECHANICSBURG, PA 17055
REPAIR MCCAFFERTY COLLISION CENTER
FACILITY: ATT: BODY SHOP
6365 BASHORE RD
MECHANICSBURG, PA 17055
BUSINESS: (717)766-8758
REPAIR-SHOP
BUSINESS: (717)766-8758
10 DAYS TO REPAIR
LICENSE # 233059964
2001 KIA SPORTAGE 4X4 4-2.OL-FT 4D UTV GOLD INT:TAN
VIN: KNDJA723315076463 LIC: SHRTYRN PA PROD DATE: 01/2001 ODOMETER: 54788
AIR CONDITIONING REAR DEFOGGER TILT WHEEL
CRUISE CONTROL INTERMITTENT WIPERS ELEC. INSTRUMENTATION
THEFT-DETERRENT/ALARM REAR WIPER TINTED GLASS
DUAL MIRRORS CLEAR COAT PAINT POWER STEERING
POWER BRAKES POWER WINDOWS POWER LOCKS
POWER MIRRORS AM RADIO FM RADIO
STEREO SEARCH/SEEK CD PLAYER
DRIVER AIR BAG PASSENGER AIR BAG POSITRACTION
CLOTH SEATS BUCKET -SEATS - - - •-
,,$F.ATS,,,
RECLINE/LOUNGE
AUTOMATIC TRANSMISSION 4 WHEEL DRIVE OVERDRIVE
ALUMINUM/ALLOY WHEELS
-
NO OP.-- - QTY EXT. PRICE LABOR PAINT
n DESCRIPTION
1 SEATS
- -
& TRACKS
2* RPR DRIVER SEAT * 110*
3 REAR BODY & FLOOR
4* RPR REAR END PANEL 1.5* 1.0
5 R&I REAR TRIM 4 DOOR BROWN 0.3
6 LIFT GATE
7 REPL LIFT GATE W/REAR WIPER 1 517.10 3.8 2.0
8 AAD FOR CLEAR COAT 0.8
9 ADD FOR UNDERSIDE(COMPLETE) 1.0
I
APR-11-2005 MON 08;45 AM FAX NO, P. 04
Req: BORGESON K
04/22/2004 AT 09:41 AM 010170742947003
ESTIMATE OF RECORD
2001 KIA SPORTAGE 4X4 4-2.0L-Fl 4D UTV GOLD INT:TAN
--------
NO.
-------- --------
OP.
-
-
- -------------------------------
DESCRIPTION
----------
---------------
-
- ------------------------
QTY EXT. PRICE LABOR
------------------------ --------
PAINT
--------
10 --
-
-- -
--
-
ADD FOR CLEAR COAT 0.2
11 REPL NAMEPLATE SPORTAGE 1 24.75 0.3
12 REPL EMBLEM KIA 1 11.05 0.3
13 SPARE TIRE CARRIER
14 REPL SPARE CARRIER 1 616.75 0.7
15 REAR BUMPER
16 0/H REAR BUMPER 1.5
17 REPL BUMPER COVER 4 DOOR 1 349.10 INCL. 2.4
18 OVERLAP MAJOR ADJ. PANEL -0.4
19 ADD FOR CLEAR COAT 0.4
20**. .. REPL. A/M RT ENERGY ABSORBER 4 DOOR 1 42,00 .. _.TN.CL.
21 REPL LT ENERGY ABSORBER. 4 DOOR 1 48.88 INCL.
22 REPL REINFORCE BAR 4 DOOR 1 312.75 INCL.
23# MISCELLANEOUS OPERATIONS 1
24# TRANSPORT TO DIAGNOSE ENGINE 1 85.00 X
PROBLEM
25# FOUR WHEEL ALIGNMENT 1 69.95 T
26# FLEX AGENT 1 6.00 T
27# TINT/MATCH PAINT 1 T 0.5
28# COVER CAR 1 5.00 T 0.2
29# SET UP GUAGE/MESSURE STRUCTURE 1 TS 2.0 S
30# PULL RR UNISODY 1 TS 2.0 S
31# R&I SPARE TIRE TO ACCESS REPAIRS 0.3
N 32# SPIN BALANCE SPARE TIRE 1 9.95 " T
33# CLEAN & DETAIL FOR DELIVERY 1 10.00 T
34# HAZARDOUS WASTE 1 3.00 T
35# COLOR SAND & BUFF 1 T 1.0
36# COVER CAR INTERIOR 1 5.00 T
37 OTHER CHARGES
38#
- TOWING
----------------------------
- 1
----- 150.00
------ -
---------
-------- ---
-
-
SUETOTALS
2
266.28
14.9
7.9
LINE 32 AMERICAN CLASIC-AE'
P205/75R15
10/32 REMAINING TREAD DEPTH
PARTS 1922.36
BODY LABOR 10.9 HRS @$ 40.00/HR 436.00
PAINT LABOR 7.9 HRS @$ 40.00/HR 316.00
STRUCTURAL LABOR 4.0 HRS Q$ 42.00/HR 168.00
PAINT SUPPLIES 7.9 HRS Q$ 20.00/HR 158.00
SUBLET/MISC. 193.90
OTHER CHARGES 150.00
-
-----
---------------------
SUBTOTAL ----- -----.--- ----------
$ -
-
3344.28
SALES TAX $ 3109.28 0 6.0000 186.56
2
APR-11-2005 MON 08;45 AM
FAX NO, P. 05
04/22/2004 AT 09:41 AM Req: BORGESON K
010170742947003
ESTIMATE OF RECORD
2001 KIA SPORTAGE 4X4 4-2.0L-FT 4D UTV GOLD INT:TAN
TOTAL COST OF REPAIRS $ 3530.84
ADJUSTMENTS:
DEDUCTIBLE
0.00
----------------------------------------------------
TOTAL ADJUSTMENTS $ 0.00
NET COST OF REPAIRS $ 3530.84
THIS IS NOT AN AUTHORIZATION TO REPAIR. THE VEHICLE OWNER MUST AUTHORIZE ALL
REPAIRS. ERIE INSURANCE RESERVES THE RIGHT TO REINSPECT ALL SUPPLEMENTS BEFORE
PAYMENT IS MADE. COSTS ABOVE THE APPRAISED AMOUNT MAY BE THE RESPONSIBILITY OF
THE VEHICLE OWNER. THERE IS.NO REQUIREMENT TO USE ANY.SPECIFIED,REPAIR SHOP.
INFORMATION REGARDING REPAIR FACILITIES WHICH WILL BE ABLE TO REPAIR THE
VEHICLE FOR THE APPRAISED AMOUNT MAY BE AVAILABLE FROM ERIE INSURANCE ON
REQUEST.
ABBREVIATIONS WHICH MAY HAVE BEEN USED IN THIS APPRAISAL ARE DEFINED AS
FOLLOWS: D = DISCONTINUED PART, A = APPROXIMATE PRICE, B = BODY LABOR, D =
DIAGNOSTIC, E - ELECTRICAL, F = FRAME, G = GLASS, M = MECHANICAL, P = PAINT
LABOR, S = STRUCTURAL, T = TAXED MISCELLANEOUS, X = NON TAXED MISCELLANEOUS,
ADJ = ADJACENT, A = ALIGN, A/M = AFTERMARKET, BLND = BLEND; CAPA = CERTIFIED.
AUTO PARTS ASSOCIATION, D&R = DISCONNECT AND RECONNECT, EST', ESTIMATE, EXT.
PRICE = UNIT PRICE MULTIPLIED BY THE QUANTITY, INCL = INCLUDED, MISC =
MISCELLANEOUS, NON - ADJ = NON ADJACENT, 0/H = OVERHAUL,'OP. = OPERATION, NO.
LINE NUMBER, QTY = QUANTITY, QUAL RECY =.QUALITY RECYCLED PART, QUAL REPL
QUALITY REPLACEMENT PART, RECOND = RECONDITION, REFN = REFINISH, REPL
REPLACE, R&I REMOVE AND INSTALL, R&R = REMOVE AND REPLACE, RPR - REPAIR, RT
= RIGHT, SECT = SECTION, SUBL = SUBLET, USED = RECYCLED PARTS OF LIKE KIND AND
QUALITY, OR BETTER, E.P.C. = ENVIRONMENTAL PROTECTION CHARGE, LT = LEFT, W/0
WITHOUT, W/ = WITH/, # = MANUEL LINE ENTRY, * = OTHER [ I.E., MOTORS DATABASE
INFORMATION WAS CHANGED], ** = DATABASE LINE WITH AFTERMARKET PART INCLUDED,
N= NOTES ATTACHED TO LINE.
APR-I1-2005 MON 08:46 AM _
co
? h U
N
ffiw
P
aao
Mp
In -cc
W O
o
N C?CO co
a+ CO N
w"oWc°
Q'w
w p7 r
Ye fDT" o
a?,}a
LU h(?
CN co<
r
fH Q
04„ O ?
0>
?Oh
h
°vr?b
W
4 ?! ~
a'
O UWWL I
V/0.
0.
FAX NO,
i
\v i
N, Ub
RFR-11-2005 MON 08:46 AM
FAX NO. P. 07
ITEM 7, EACH AUTO WE INSURE WILL BE PRINCIPALLY GARAGED AT THE ADDRESS SHOWN
IN ITEM 1, UNLESS ANOTHER ADDRESS IS SHOWN BELOW.
ITEM 9. UNLESS A CO-OWNER OR LIENHOLDER IS LISTED BELOW, THE NAMED INSURED
IS THE SOLE OWNER OF EACH AUTO WE INSURE,
LICLARIONRONIIZEDAUTO C IU
CLARION PA6 16214-0746
xxzxxzxz,tzz*zz*xz,rzzzxzx?rxxxxx'W;exxitizxxzfrzxszzzzzzxtzzzzxzzxzz,tzz*zz?****x?c*xxxxxt
DRIVER ST%LICENSE,NUMBFR BIRTH HnATE:.
1 DENISE E BEARY PA 22570131 12/D1/71
ACCIDENTS/VIOLATIONS SL[BJ CT TO DEFENSIVE DRIVER PLAN (DDP)
DENISE E BEARY FAF 05/2202.
YOUR COLLISION COVERAGE AND DEDUCTIBLE APPLY TO PRIVATE PASSENGER
AUTOS YOU OR A RESIDENT RELATIVE RENT FOR 45 DAYS OR LESS. THIS IS
SUBJECT TO LIMITS, TERMS AND CONDITIONS IN THE POLICY.
BY THE._ GENERAL
IRST-PARTY
COVERAGES IN
T YOUR REQUEST
MUM REQUIRED COVERAGES AND LIMITS FOR
MITED TORT OPTION MAY NOT BE AVAILABLE
# g1
BODILY INJURY PROPERTY BENEFgg'IT SACC
FIRST PART MEDICAL/EXPENSE $5M 26
907 0706461
BELOW ARE ANNUAL PREMIUMS FOR THE MINI
LIMITED TORT, PLEASE NOTE THAT THE LI
ON CERTAIN VEHICLES.
ATTORNEY VERIFICATION
I, Scott B. Cooper, Esquire, verify that I am attorney of record for the
Plaintiff, Denise Beary. I verify that the facts contained in the foregoing
Plaintiff's Reply to Defendant's New Matter are true and correct to the best of
my knowledge, information and belief.
I understand that intentional false statements herein are made subject to
the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsifications to
authorities.
Date: )1"9 '
Z41V
Scott B. Cooper
CERTIFICATE OF SERVICE
AND NOW, this 3rd day of April, 2006, I hereby certify that I have, this
day, caused a copy of the foregoing Plaintiffs Reply to Defendants New Matter to
be served by deposit in the United States mail, postage prepaid, at Harrisburg,
Pennsylvania, addressed as follows:
First Class Mail:
Jefferson Shipman, Esquire
Johnson Duffle
301 Market Street
Lemoyne, PA 17043-1628
SCHMIDT, RONCA & KRAMER, P.C.
V
By:
Scott B. Cooper, Esquire
I.D.# 70242
209 State Street
Harrisburg, PA 17101
(717) 232-6300
(717) 232-6467 Fax
scooper@srklaw.com
Attorney for Plaintiff
ATTORNEY VERIFICATION
I, Scott B. Cooper, Esquire, verify that I am attorney of record for the
Plaintiff, Denise Beary. I verify that the facts contained in the foregoing
Plaintiff's Reply to Defendant's New Matter are true and correct to the best of
my knowledge, information and belief.
I understand that intentional false statements herein are made subject to
the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsifications to
authorities.
Date: 3 h 6
Scott B. Cooper
CERTIFICATE OF SERVICE
AND NOW, this 3rd day of April, 2006, I hereby certify that I have, this
day, caused a copy of the foregoing Plaintiff's Reply to Defendants New Matter to
be served by deposit in the United States mail, postage prepaid, at Harrisburg,
Pennsylvania, addressed as follows:
First Class Mail:
Jefferson Shipman, Esquire
Johnson Duffie
301 Market Street
Lemoyne, PA 17043-1628
SCHMIDT, RONCA & KRAMER, P.C.
By:
Scott B. Cooper, Esquire
I.D.# 70242
209 State Street
Harrisburg, PA 17101
(717) 232-6300
(717) 232-6467 Fax
scooper@srklaw.com
Attorney for Plaintiff
? ?? lT
?? ? a
'; n
C?
f?? L
Johnson, Duffle, Stewart & Weidner
By: Jefferson J. Shipman, Esquire
I.D. No. 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
e-mail: Bs@jdsw.com
(717) 761-4540
Attorneys for
Defendant
DENISE BEAKY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
AMANDA YEAGER,
Defendant
CIVIL ACTION - LAW
NO. 06-1156 CIVIL TERM
JURY TRIAL DEMANDED
TO: Scott B. Cooper, Esquire
Schmidt, Ronca & Kramer, P.C.
209 State Street
Harrisburg, PA 17101
Attorneys for Plaintiff
As a prerequisite to service of a subpoena for documents and things
pursuant to Rule 4009.22, Defendant hereby certifies that::
(1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas
attached thereto, was mailed, via Certified Mail, or delivered to each party at least
twenty days prior to the date on which the subpoenas were sought to be served;
(2) A copy of the Notice of Intent including the proposed subpoenas, is
attached to this Certificate;
(3) No objection to the subpoenas has been received, the twenty day waiting
period was waived; and
(4) The subpoenas to be served are identical to the subpoenas attached to
the Notice Of Intent.
DUFFIE, STEWART & WEIDNER
n
Jefferson J. Shipman, Esquire
Attorney I.D. No. 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
Telephone (717) 761-4540
Attorneys for Defendant
Date: 5-1/,;1166
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing has been duly served upon the
following, by depositing the same in the United States Mail, first class, postage prepaid,
in Lemoyne, Pennsylvania, on r 11 d?j
Scott B. Cooper, Esquire
Schmidt, Ronca & Kramer, P.C.
209 State Street
Harrisburg, PA 17101
Attorneys for Plaintiff
JOHNSON, DUFFIE, STEWART & WEIDNER
By
I.D. #: -51785
P.O. Box 109
Lemoyne, PA 17043
717-761-4540
Attorneys for Defendant
Johnson, Duffle, Stewart & Weidner Attorneys for
By: Jefferson J. Shipman, Esquire Defendant
I.D. No. 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
e-mail: hs@jdsw.com
(717) 761-4540
DENISE BERRY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
AMANDA YEAGER,
Defendant
CIVIL ACTION - LAW
NO. 06-1156 CIVIL TERM
JURY TRIAL DEMANDED
TO: Scott B. Cooper, Esquire
Schmidt, Ronca & Kramer, P.C.
209 State Street
Harrisburg, PA 17101
Attorneys for Plaintiff
PLEASE TAKE NOTICE that Defendants intend to serve three subpoenas
identical to the ones that are attached to this notice. You have twenty (20) days from the date
listed below in which to file of records and serve upon the undersigned objections to the
subpoenas. If no objection is made, the subpoenas may be served.
JOHNSON, DUFFIE, STEWART & WEIDNER
ByV
Jeffe on . Shipman, Esquire
Atto eys I.D. #: 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
DATE: Attorneys for Defendant
Ala /Q(?
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing has been duly served upon the
following, by depositing the same in the United States Mail, certified mail, postage
prepaid, in Lemoyne, Pennsylvania, on f)- ID /6(0
Scott B. Cooper, Esquire
Schmidt, Ronca & Kramer, P.C.
209 State Street
Harrisburg, PA 17101
Attorneys for Plaintiff
, DUFFIE, STEWART & WEIDNER
By
Jeffefson J. Shipman,'Esquire
I.D. #: 51785
P.O. Box 109
Lemoyne, PA 17043
717-761-4540
Attorneys for Defendant
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Denise Beery,
Plaintiff
vs. File No. 06-1156
Amanda Yeager,
Defendant
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Liberty Mutual Insurance Company
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce
the following documents or things: any and all records, correspondence. reports and medical records
rnnaniinn r1laim kin wPgon9d99A7nn• rlnio of A"irloni _ AnDir" mnwAinn rlnnino Ranni r)r)R-
at Johnson. Duffle. Stewart & Weidner. 301 Market Street. P.O. Box 109. Lemoyne. PA 17043.
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: Jefferson J. Shipman. Esquire
ADDRESS: 301 Market Street
Lemoyne. PA 17043
TELEPHONE: 717-761-4540
SUPREME COURT ID #: 51785
ATTORNEY FOR: Defendant
BY THE COURT:
Prothonotary/C
ivil Di ' ion
011,
Deputy
DATE: Qpfa? I Z ?U(o
Seel of the Court
(Eff. 7/97)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Denise Beery,
Plaintiff
vs. File No. 06-1156
Amanda Yeager,
Defendant
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: HCR Manor Care. Inc.
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to. produce
the following documents or things: any and all records, correspondence, reports and medical records
regarding Claim No. 2003069167: Date of Accident - 815103 regarding Denise Beery DOB: 12/1/71
SSN: 176-48-5350
at Johnson Duffle Stewart & Weidner. 301 Market Street. P.O. Box 109. Lemoyne. PA 17043.
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: Jefferson J. Shipman. Esquire
ADDRESS: 301 Market Street
Lemoyne. PA 17043
TELEPHONE: 717-761.4540
SUPREME COURT ID #: 51785
ATTORNEY FOR: Defendant
BY THE COURT:
dZ% J
Protho otary/CJarl , ivil Divi ' n
Deputy
DATE: l.
Seal of the Court
(Eff. 7/97)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Denise Beery,
Plaintiff
vs. File No. 06-1156
Amanda Yeager,
Defendant
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Geico General Insurance Company
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce
the following documents or things: any and all records correspondence reports and medical records
at Johnson. Duffle. Stewart & Weidner, 301 Market Street P.O. Box 109, Lemoyne PA 17043.
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: Jefferson J. Shipman. Esouire
ADDRESS: 301 Market Street
Lemoyne. PA 17043
TELEPHONE: 717-761-4540
SUPREME COURT ID #: 51785
ATTORNEY FOR: Defendant
DATE:
Sea of the Court'
BY THE COURT:
Prothon tary/Cle $l Divis' n
Deputy
(Eff. 7/97)
o
c m
_
f
b =T
>m
y:.::' G)
N D
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01156 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BEARY DENISE
VS
YEAGER AMANDA
ROBERT BITNER
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
YEAGER AMANDA the
DEFENDANT at 1855:00 HOURS, on the 2nd day of March , 2006
at 5223 STUART DRIVE
MECHANICSBURG, PA 17055
by handing to
ROBERT NEASE, GRANDFATHER, ADULT IN CHARGE
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.68
Postage .39
Surcharge 10.00
.00
38.07
Sworn and Subscribed to before
me this 21aH day of
bo (o A. D.
Proth otary
So Answers:
?0e ? le
R. Thomas Kline
03/03/2006
SCHMIDT RONCA KRAMER
?
Deputy Sheriff
v
r'
0*9/Qvj
*4Z
DENISE BEARY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2006-01156
AMANDA YEAGER, CIVIL ACTION - LAW
Defendant
PRAECIPE FOR WITHDRAWAL AND ENTRY OF APPEARANCE
Please withdraw the appearance of Scott B. Cooper, Esquire, on behalf of
Plaintiff, Denise Beary, in the above-captioned action.
Respectfully submit ed,
By:
Scott B. Cooper, Esquire
ID No. 70242
SCHMIDT RONCA & KRAMER, PC
209 State Street
Harrisburg PA 17101
(717) 232-6300
Please enter the appearance of Richard E. Freeburn, Esquire on behalf of
Plaintiff, Denise Beary in the above-captioned action.
Respectfully submitted,
By: I
Richard'E. Fre _eburn, Esquire
ID No. 30965
FREEBURN & HAMILTON, PC
4415 North Front Street
Harrisburg, PA 17110
(717) 671-1955
Date: 10/25/06
.?-'
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Praecipe has
been duly served on the following this 25th day of October, 2006, by placing the
same in the U.S. First Class Mail, postage prepaid, at Harrisburg, Pennsylvania,
addressed as follows:
Jefferson J. Shipman, Esquire
JOHNSON DUFFIE STEWART & WEIDNER, PC
PO Box 109
Lemoyne PA 17043
Scott B. Cooper, Esquire
SCHMIDT RONCA & KRAMER, PC
209 State Street
Harrisburg PA 17101
BY:
Georgiane J. H s, Assistant to
Richard E. Freeburn, Esquire
Attorney I.D. #30965
FREEBURN & HAMILTON
4415 North Front Street
Harrisburg, PA 17110
(717) 671-1955
Dated: 10/25/06 Attorney for Plaintiff
C
n
_
w t '? l?
Johnson, Duffie, Stewart & Weidner
By: Jefferson J. Shipman, Esquire
I.D. No. 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
e-mail: jjs@jdsw.com
(717) 761-4540
DENISE BEARY,
V.
Attorneys for
Defendant
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
AMANDA YEAGER,
Defendant
CIVIL ACTION - LAW
NO. 06-1156 CIVIL TERM
JURY TRIAL DEMANDED
CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
TO: Richard E. Freeburn, Esquire
Freeburn Hamilton
4415 North Front Street
Harrisburg, PA 17110
As a prerequisite to service of a subpoena for documents and things
pursuant to Rule 4009.22, Defendant hereby certifies that:
(1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas
attached thereto, was mailed, via Certified Mail, or delivered to each party at least
twenty days prior to the date on which the subpoenas were sought to be served;
(2) A copy of the Notice of Intent including the proposed subpoenas, is
attached to this Certificate;
(3) No objection to the subpoenas has been received, the twenty day waiting
period was waived; and
(4) The subpoenas to be served are identical to the subpoenas attached to
the Notice Of Intent.
By
DATE : rl l ! ?161
JOHN
, DUFFIE, STEWART & WEIDNER
Jeffefon J. Shipman, Esquire
Attorneys I.D. #: 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
e-mail: jjs@jdsw.com
Attorneys for Defendant
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing has been duly served upon the
following, by depositing the same in the United States Mail, first class, postage prepaid,
in Lemoyne, Pennsylvania, on 7 111 U?
Richard E. Freeburn, Esquire
Freeburn Hamilton
4415 North Front Street
Harrisburg, PA 17110
Attorneys for Plaintiff
JOHNSON, DUFFIE, STEWART & WEIDNER
By
Jeffer 7nJ-.Shipman, Esquire
I.D. #: 51785
P.O. Box 109
Lemoyne, PA 17043
717-761-4540
Attorneys for Defendant
Johnson, Duffle, Stewart & Weidner
By: Jefferson J. Shipman, Esquire
I.D. No. 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
e-mail: jjs@jdsw.com
(717) 761-4540
DENISE BERRY,
Plaintiff
Attorneys for
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
AMANDA YEAGER,
Defendant
CIVIL ACTION - LAW
NO. 06-1156 CIVIL TERM
: JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
TO: Richard E. Freeburn, Esquire
Freeburn Hamilton
4415 North Front Street
Harrisburg, PA 17110
PLEASE TAKE NOTICE that Defendants intend to serve four (4) subpoenas
identical to the ones that are attached to this notice. You have twenty (20) days from the date
listed below in which to file of records and serve upon the undersigned objections to the
subpoenas. If no objection is made, the subpoenas may be served.
JOHNSON, DUFFIE, STEWART & WEIDNER
By
Jeffers n J. Shipman, Esquire
Attorn s I.D. #: 51785,
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
Attorneys for Defendant
DATE:
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing has been duly served upon the
following, by depositing the same in the United States Mail, certified mail, postage
prepaid, in Lemoyne, Pennsylvania, on (e?
Richard E. Freeburn, Esquire
Freeburn Hamilton
4415 North Front Street
Harrisburg, PA 17110
Attorneys for Plaintiff
JOHNSON, DUFFIE, STEWART & WEIDNER
By
Jeffer on J. Shipman, Esquire
I.D. #: 51785
P.O. Box 109
Lemoyne, PA 17043
717-761-4540
Attorneys for Defendant
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Denise Beary,
Plaintiff
vs. File No. 06-1156
Amanda Yeager,
Defendant
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO. Devonshire Family Practice
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce
the foiiowing documents or things: any and all medical records, reports, correspondence, diagnostic test
results regarding Denise Beary DOB: 12/1/71 SSN: 176-48-5350
at Johnson Duffie Stewart & Weidner, 301 Market Street, P.O. Box 109, Lemoyne, PA 17043.
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: - Jefferson J. Shipman, Esquire
ADDRESS: 301 Market Street
Lemoyne, PA 17043
TELEPHONE: 717-761-4540
SUPREME COURT ID #: 51785
ATTORNEY FOR: Defendant
BY THE COURT:
P oth notary/Clerk, Civil Divisio
eputy
2UU7
DATE:- Lmp.
Seal of the Court
(Eff. 7/97)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Denise Beary,
Plaintiff
vs. File No. 06-1156
Amanda Yeager,
Defendant
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Broad Street Familv Practice
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce
the following documents or things: any and all medical records, reports, correspondence, diagnostic test
results regarding Denise Beary DOB: 12/1/71 SSN: 176-48-5350
at Johnson. Duffie, Stewart & Weidner, 301 Market Street. P.O. Box 109, Lemoyne, PA 17043.
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: Jefferson J. Shipman. Esquire
ADDRESS: 301 Market Street
Lemoyne, PA 17043
TELEPHONE: 717-761-4540
SUPREME COURT ID #: 51785
ATTORNEY FOR: Defendant
BY THE COURT:
P of notary/Clerk, Civil Division
eputy
DATE: 2aD7
Seal of the Court
(Eff. 7/97)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Denise Beary,
Plaintiff
vs. File No. 06-1156
Amanda Yeager,
Defendant
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Pennsylvania Neurological Associates
(Name of Person or Entity)
Within twenty (20) clays after service of this subpoena, you are ordered by the court to produce
the following documents or things: any and all medical records, reports, correspondence, diagnostic test
results regarding Denise Beary DOB: 12/1/71 SSN: 176-48-5350
at Johnson. Duffie, Stewart & Weidner, 301 Market Street, P.O. Box 109, Lemoyne PA 17043.
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: Jefferson J. Shipman, Esquire
ADDRESS: 301 Market Street
Lemoyne, PA 17043
TELEPHONE: 717-761-4540
SUPREME COURT ID #: 51785
ATTORNEY FOR: Defendant
BY THE COURT:
rot onotary/Clerk, Civil Division
Deputy
DATE: 02667
Seal of the Court
(Eff. 7/97)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Denise Beary,
Plaintiff
vs.
Amanda Yeager,
Defendant
File No. 06-1156
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Appalachian Orthopedic Center LTD
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce
the following docUments or things: any and all. medical records, reports, correspondence, diagnostic test
results regarding Denise Beary DOB: 12/1/71 SSN: 176-48-5350
at Johnson, Duffie, Stewart & Weidner, 301 Market Street, P.O. Box 109, Lemoyne, PA 17043.
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: Jefferson J. Shipman, Esquire
ADDRESS: 301 Market Street
Lemoyne, PA 17043
TELEPHONE: 717-761-4540
SUPREME COURT ID #: 51785
ATTORNEY FOR: Defendant
DATE: r o-007
Seal of the Court
BY THE COURT:
0 onotary/Clerk, Civil Division
Deputy
(Eff. 7/97)
C> ?' -art
G-?
"?
_f
i
'P. ??
F,,? ,
,i
_
y.. ;
??
- ,
.,.
Johnson, Duffie, Stewart & Weidner
By: Jefferson J. Shipman, Esquire
I.D. No. 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
e-mail: jjs@jdsw.com
(717) 761-4540
DENISE BEARY,
V.
Attorneys for
Defendant
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
AMANDA YEAGER,
Defendant
CIVIL ACTION -LAW
NO. 06-1156 CIVIL TERM
JURY TRIAL DEMANDED
CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
TO: Richard E. Freeburn, Esquire
Freeburn Hamilton
4415 North Front Street
Harrisburg, PA 17110
As a prerequisite to service of a subpoena for documents and things
pursuant to Rule 4009.22, Defendant hereby certifies that:
(1) A Notice Of Intent To Serve A Subpoena, with copies of the subpoenas
attached thereto, was mailed, via Certified Mail, or delivered to each party at least
twenty days prior to the date on which the subpoenas were sought to be served;
(2) A copy of the Notice of Intent including the proposed subpoenas, is
attached to this Certificate;
(3) No objection to the subpoenas has been received, the twenty day waiting
period was waived; and
(4) The subpoenas to be served are identical to the subpoenas attached to
the Notice Of Intent.
JOHN N, DUFFIE, STEWART & WEIDNER
By
Je rson J. Shipman, Esquire
Attorneys I.D. #: 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
e-mail: jjs@jdsw.com
DATE : Attorneys for Defendant
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing has been duly served upon the
following, by depositing the same in the United States Mail, first class, postage prepaid,
in Lemoyne, Pennsylvania, on 161.a?
Richard E. Freeburn, Esquire
Freeburn Hamilton
4415 North Front Street
Harrisburg, PA 17110
Attorneys for Plaintiff
JOHNSON, DUFFIE, STEWART & WEIDNER
By
Jeffers n J. Shipman, Esquire
I.D. #: 51785
P.O. Box 109
Lemoyne, PA 17043
717-761-4540
Attorneys for Defendant
Johnson, Duffie, Stewart & Weidner
By: Jefferson J. Shipman, Esquire
I.D. No. 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
e-mail: jjs@jdsw.com
(717) 761-4540
Attorneys for
Defendant
DENISE BEARY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
AMANDA YEAGER,
Defendant
CIVIL ACTION -LAW
NO. 06-1156 CIVIL TERM
: JURY TRIAL DEMANDED
NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
TO: Richard E. Freeburn, Esquire
Freeburn Hamilton
4415 North Front Street
Harrisburg, PA 17110
PLEASE TAKE NOTICE that Defendants intend to serve two (2) subpoenas
identical to the ones that are attached to this notice. You have twenty (20) days from the date
listed below in which to file of records and serve upon the undersigned objections to the
subpoenas. If no objection is made, the subpoenas may be served.
JOHNSON, DU_9FIE, STEWART & WEIDNER
Jeffeyson J. Shipman, Esquire
Attorneys I.D. #: 51785
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
Attorneys for Defendant
DATE: t6lgld-?
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing has been duly served upon the
following, by depositing the same in the United States Mail, certified mail, postage
prepaid, in Lemoyne, Pennsylvania, on 16
Richard E. Freeburn, Esquire
Freeburn Hamilton
4415 North Front Street
Harrisburg, PA 17110
Attorneys for Plaintiff
JOHNSON, DUFFIE, STEWART & WEIDNER
By _
Je rson J. Shipman, Esquire
I.D. #: 51785
P.O. Box 109
Lemoyne, PA 17043
717-761-4540
Attorneys for Defendant
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Denise Beary,
Plaintiff
vs. File No. 06-1156
Amanda Yeager,
Defendant
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO: Community General Osteopathic Hospital
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce
the following documents or things: MRI (ACTUAL FILMS) of Cervical Spine dated 8/30/07 regarding
Denise Beary DOB: 12/1/71 SSN: 176-48-5350
at Johnson. Du_ffte, Stewart & Weidner, 301 Market Street. P.O. Box 109, Lemoyne PA 17043.
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: Jefferson J. Shipman. Esquire
ADDRESS: 301 Market Street
Lemoyne. PA 17043
TELEPHONE: 717-761-4540
SUPREME COURT ID #: 51785
ATTORNEY FOR: Defendant
BY THE COURT:
/51 llati je. 671"
P othonotary/Clerk, Civil ision
L6&
Deput
DATE: lob a
Seal of he Court
(Eff.. 7/97)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Denise Beary,
Plaintiff
vs.
Amanda Yeager,
Defendant
File No. 06-1156
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO. Tristan Associates
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce-
the following documents or things: MRI (ACTUAL FILMS) of Cervical Spine dated 1/8/05 regarding
Denise Beare DOB: 12/1/71 SSN: 176-48-5350
at Johnson, Duffle, Stewart & Weidner. 301 Market Street P.O. Box 109, Lemoyne PA 17043.
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:
ADDRESS:
TELEPHONE:
SUPREME COURT ID #:
ATTORNEY FOR:
Jefferson J. Shipman. Esquire
301 Market Street
Lemovne. PA 17043
717-761-4540
51785
Defendant
BY THE COURT:
K.
Ppbthonotary/Clerk, Civil Divis' n
Depu
DATE: l9 17 D
Seal of he Court
(Eff. 7/97)
CZ3
T't
'
--.? )?Y
r
PSI) -D rTT
c) _4a CJ
e.,
^".r r.?
? 4 S r r I
J
t
.per ?
W ?
DENISE BERRY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2006-01156
AMANDA YEAGER, CIVIL ACTION - LAW
Defendant
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONTARY OF SAID COURT:
Kindly enter the appearance olf the undersigned on behalf of Plaintiff in the
above-captioned action.
FREEBURN & HAMILTON
-DIA
Christina L. Bradley, Esq ire
I.D. No. 89107
4415 North Front Street
Harrisburg PA 17110
(717) 671-1955
Date: 11/15/07
I '
CERTIFICATE OF SERVICE
I hereby certify that a true and d correct copy of the foregoing document
has been duly served on the following this 15th day of November, 2007, by
placing the same in the U.S. First Class Mail, postage prepaid, at Harrisburg,
Pennsylvania, addressed as follows:
Jefferson J. Shipman, Esquire
JOHNSON DUFFIE STEWART & WEIDNER, PC
PO Box 109
Lemoyne PA 17043
BY: ??6G!/ol?
J e A. es, Assistant to
C a L. Bradley, Esquire
I.D. No. 89107
4415 North Front Street
Harrisburg PA 17110
(717) 671-1955
Date: 11/15/07 Counsel for Plaintiffs
N
f
f? l I-T 7-M
er, ,a - --- z7
3
(D 2
--i
cn
FREEBURN & HAMILTON
By: Christina L. Bradley, Esquire
I. D. No. 89107
4415 North Front Street
Harrisburg, PA 17110
(717) 671-1955
(717) 671-1960
DENISE BERRY,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
AMANDA YEAGER,
Defendant
NO. 06-1156 CIVIL TERM
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRAECIPE TO DISCONTINUE
TO THE PROTHONOTARY:
PLEASE mark the above-captioned matter satisfied, settled and discontinued with
prejudice.
Date: PM'_C L-k-A i2I zoos
FREEBURN & HAMILTON
By: I '&C?' /
Christina L. Bradley, Esqu' e
Attorney I.D. #: 89107
4415 North Front Street
Harrisburg, PA 17110
(717) 671-1955
Attorneys for Plaintiff
FILE1r- Y::i"E
2009 NOV 24 AM 9: 17