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HomeMy WebLinkAbout06-1758VALERIE D. CHANDLER, Plaintiff V. TAISEAN A. HARRIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006- ( 7 56 CIVIL TERM CIVIL ACTION-LAW PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue a Writ of Summons in the above-referenced case on behalf of the Plaintiff, Valerie D. Chandler, to the Defendant, Taisean A. Harris. ?30? z+e(?1 kow( C__&r h5L1__ P4 1700 O'BRIEN, BARIC & SCHERER Date: J-23-O& Please serve the Defendant as follows: Taisean A. Harris 3308 Enola Road Carlisle, Pennsylvania 17013 ;GAS(/ Michael A. Scherer, Esquire I.D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 5 1 c ? a r`l _Z -.. r.r; Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS VALERIE D. CHANDLER Plaintiff Vs. TAISEAN A. HARRIS 3308 ENOLA ROAD CARLISLE PA 17013 Defendant Court of Common Pleas No 06-1758 In CivilAction-Law To TAISEAN A. HARRIS, You are hereby notified that VALERIE D. CHANDLER the Plaintiff(s) has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date MARCH 24, 2006 Attorney: Name: MICHAEL A SCHERER ESQ Address: 19 W SOUTH ST CARLISLE PA 17013 Attorney for: Plaintiff Telephone: (717) 249-6873 Supreme Court ID No. 61974 Curtis R. Long Prothonotary By Al- eputy r VALERIE D. CHANDLER, Plaintiff vs. TAISEAN A. HARRIS, Defendant PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, TAISEAN A. HARRIS, with regard to the above-captioned matter. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 1758 Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED Respectfully submitted, NEALON GOVER & PERRY By. Date: 6((dCG Michael S. Ferguson, Esquire I.D. No. 83882 2411 North Front Street Harrisburg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE AND NOW, this day of June, 2006, 1 hereby certify that I have served the foregoing PRAECIPE FOR ENTRY OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael A. Scherer, Esquire 19 West South Street Carlisle, PA 17013 IV400-el- MMichaell S. Fer uson, Esquire ?. - _-, _ C -T-i i F .? --, , f-?, ? _- ??__ a , ??-?- ?.? ,, `; --1 ...,..? .. r VALERIE D. CHANDLER, Plaintiff vs. TAISEAN A. HARRIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 1758 Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, Date: ((? Lc? NEALON GOVER & PERRY By:tQ?_ Michael S. Ferguson, Esquire I.D. No. 83882 2411 North Front Street Harrisburg, PA 17110 7171232-9900 RULE TO THE PLAINTIFF: A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. DATED:JL,c3E 66& 2"twu.e-l ?' Pr honotary r CERTIFICATE OF SERVICE AND NOW, this ` (° day of June, 2006, 1 hereby certify that I have served the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael A. Scherer, Esquire 19 West South Street Carlisle, PA 17013 '?)Q4 ?- Michael S. Ferguson, Esquire r. {y ?r, r? ?? 45 .-{ - "! I `j}?; l.? i l -_, : 1`Ci 1 C1 -? ?? z; _;; ?I ?f SHERIFF'S RETURN - REGULAR CASE NO: 2006-01758 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHANDLER VALERIE D VS HARRIS TAISEAN A KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon HARRIS TAISEAN A the DEFENDANT , at 1446:00 HOURS, on the 3rd day of April 2006 at 3 CORAL DRIVE CARLISLE, PA 17013 by handing to MEGAN OLIPHANT, ADULT IN CHARGE 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 Service Postage Surcharge So Answers: 18.04 .40 .39 10.00 R. Thomas Kline 00 32.79 04/04/2006 OBRIEN BARIC SCHERER Sworn and Subscribed to before By. me this /9 day of ^1ut74 A. D. Prothonotary VALERIE D. CHANDLER IN THE COURT OF COMMON PLEAS and DAVID CHANDLER, OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 2006-1758 CIVIL TERM V. TAISEAN A. HARRIS, CIVIL ACTION-LAW Defendant 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 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 VALERIE D. CHANDLER and DAVID CHANDLER, Plaintiffs V. TAISEAN A. HARRIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-1758 CIVIL TERM CIVIL ACTION-LAW COMPLAINT AND NOW, comes the Plaintiff, Valerie D. Chandler, by and through her attorney, Michael A. Scherer, Esquire, and respectfully represent as follows: 1. The Plaintiffs, Valerie D. Chandler and David Chandler, are adult individuals, husband and wife, who reside at 4 South Acorn Drive, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The Defendant, Taisean R. Harris, is an adult individual who resides at 3 Coral Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. The facts and occurrences hereinafter set forth occurred on or about Friday, May 7, 2004 at 4:30 p.m. on Trindle Road also known as State Route 641, Carlisle, North Middleton Township, Cumberland County, Pennsylvania. 4. At the aforesaid time and place, the Plaintiff, Valerie D. Chandler was stationary behind a vehicle turning left onto Valley Street in the 1700 block of Trindle Road, State Route 641, Carlisle, Cumberland County. Pennsylvania. 5. Defendant's vehicle struck Plaintiff from behind and caused the Plaintiffs automobile to be pushed into the rear of the automobile directly in front of her. 6. The accident was caused as a result of the negligence of the Defendant in that he: a. caused his vehicle to strike the rear of Plaintiff's vehicle; b. drove his vehicle at a speed greater than was reasonable and prudent under the conditions then existing; C. operated his vehicle at a speed in excess of that which would have allowed him to stop his vehicle within the assured clear distance ahead; and, COUNTI Valerie D. Chandler V. Taisean A. Harris 7. Plaintiff sustained painful and severe injuries which include, but are not limited to, headaches, a lumbar sprain and cervical sprain/strain that has resulted in continuing pain and discomfort in her neck and back. 8. By reason of the aforesaid injuries, Plaintiff was forced to incur liability for medical treatment, medications, physical therapy and similar miscellaneous expenses in an effort to restore herself to health, and claim is made therefore. 9. Plaintiff continues to be plagued with occassional pain and limitations which have prevented her from doing her normal and usual household, recreational and work activities and, therefore, avers that she has suffered a serious and permanent impairment of her bodily function and claim is made therefore. 10. Because of the nature of her injuries, Plaintiff has been advised and, therefore, avers that she may be forced to incur similar expenses in the future, and claim is made therefore. 11. As a result of the aforesaid injuries, Plaintiff has undergone and in the future may undergo great physical and mental suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefore. 12. As a result of the aforesaid accident and injuries, Plaintiff has sustained work loss of 200 hours, loss of opportunity, and a diminution of her earning power and capacity, and claim is made therefore. WHEREFORE, Plaintiff Valerie D. Chandler demands judgment against Taisean R. Harris for damages and costs in an amount in excess of the limits requiring compulsory arbitration. COUNT II David Chandler v. Taisean A. Harris 13. Paragraphs one through twelve are incorporated herein. 14. As a direct and proximate result of the collision and negligence of the Defendant, David Chandler has been deprived of the society, companionship, contributions and consortium of his wife, Valerie Chandler, and has suffered a disruption in his daily habits, lifestyle and pursuits, as well as loss of enjoyment of life and life's pleasures, to his detriment and loss. WHEREFORE, Plaintiff David Chandler demands judgment against Taisean R.' Harris for damages and costs in an amount in excess of the limits requiring compulsory arbitration. Respectfully submitted, O'BRIEN, BARIC & SCHERER P"61j ichael A. Scherer, Esquire I. D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiffs mas.d it/ge n i itlchand le r/com plai nt. pld VALERIE D. CHANDLER and IN THE COURT OF COMMON PLEAS DAVID CHANDLER, OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. 2006-1758 CIVIL TERM TAISEAN A. HARRIS, CIVIL ACTION-LAW Defendant VERIFICATION The statements in the foregoing Complaint are based upon information which has been assembled by my attorney in this litigation. The language of the statements is not my own. I have read the statements; and to the extent that they are based upon information which I have given to my counsel, they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties ofl 18 Pa.C.S.A. § 4904 relating to unsworn falsifications to authorities. DATE: July RZ , 2006 DATE: July 2-6 , 2006 CERTIFICATE OF SERVICE I hereby certify that on August \? , 2006, I, Jennifer S. Lindsay, secretary to Michael A. Scherer, Esquire, did serve a copy of the Complaint, by first class U.S. postage prepaid, to the party listed below, as follows: Michael S. Ferguson, Esquire Nealon, Glover & Perry 2411 North Front Street Harrisburg, Pennsylvania 17110 10: 15 7172495755 VAL(-.RiF D. CHANDLER, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2046-1758 CIVIL TERM I AISLAN A. HARRIS, CIVIL ACTION-LAW Defendant STIPULATION Michael A. Scherer, Esquire, counsel for the plaintiff, and MichaO 1-erguson. LS quire, counsel for the defendant, hereby agree to add David Chandler to this action as a plaintiff and the caption shall be arnended accordingly. -14 --- 2006 ?rvgoSf ( 2006 Michael A. Scherer, Esquire "-?c - Mich ael f ergusr n, 1=:squire t ?' -. . CERTIFICATE ISITE TO SERVICE OF A SUBPOENA 0 PURSUANT TO RULE 4009.22 4, V**4 IN THE MATTER OF: VALERIE D. CHANDLER COURT OF COMMON PLEAS TERM, CUMBERLAND -VS- TAISEAN A. HARRIS CASE NO: 2006-1758 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/03/2006 on behalf of ? & ga0 Attorney for DEFENDANT R1.13 133-H DE11-0639360 26672-LO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: VALERIE D. CHANDLER -VS- TAISEAN A. HARRIS COURT OF COMMON PLEAS TERM, CASE NO: 2006-1758 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY WALNUT BOTTOM RADIOLOGY MEDICAL RECORDS & XRAYS ALEXANDER SPRING REHAB MEDICAL RECORDS & XRAYS BELVEDERE MEDICAL CENTER MEDICAL RECORDS & XRAYS TO: MICHAEL SCHERER, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/14/2006 CC: MICHAEL FERGUSON, ESQ. - 06-481 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.11S 133-H DE02-0337017 26672-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VALERIE D. CHANDLER vs. TAISEAN A. HARRIS File No. 2006-1758 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE REGIONAL MEDICAL CNTR (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: **** SEE. ATTACHED RIDER **** at The MCS GEM- In 1601 Mark .t Stre.t. Suite 800. Philadelphia- PA 19103 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: MICHAEL FERGUSON. ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (21$) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: JV ?? 1???; Seal of the Court 26672-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS 246 PARKET STREET CARLISLE. PA 17013 RE: 26672 VALERIE D. CHANDLER Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject VALERIE D. CHANDLER 4 S. ACORN DRIVE, BOILDING SPRING, PA 17007 Social Security #: XXX-XX-8778 Date of Birth: 06-25-1970 R1.11S 133-H SU10-0632230 26672-LO1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA R10441 PURSUANT TO RULE 4009.22 kVIN THE MATTER OF: VALERIE D. CHANDLER -Vs- TAISEAN A. HARRIS COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 2006-1758 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/03/2006 S on behalf of Attorney for DEFENDANT R1.13 133-H DE11-0639361 26672-L02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: VALERIE D. CHANDLER -VS- TAISEAN A. HARRIS COURT OF COMMON PLEAS TERM, CASE NO: 2006-1758 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY WALNUT BOTTOM RADIOLOGY MEDICAL RECORDS & XRAYS ALEXANDER SPRING REHAB MEDICAL RECORDS & XRAYS BELVEDERE MEDICAL CENTER MEDICAL RECORDS & XRAYS TO: MICHAEL SCHERER, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/14/2006 CC: MICHAEL FERGUSON, ESQ. - 06-481 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.11S 133-H DE02-0337017 26672-CDI COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VALERIE D. CHANDLER V5. TAISEAN A. HARRIS File No. 2006-1758 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for RT.I .. REGIONAL MEDICAL CTR. (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: **** SEE ATTAC ED RIDER **** at The M CS rrrnlp, Ine._ 1601 Market Street Suite 800_ Philadeln ia. PA 19103 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: MICHAEL FERGUSON. ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ,J(jr? _ // _p !0]t Seal of the Court BY THE COURT: Prothonotary/Clerk, 26672-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR CARLISLE REGIONAL MEDICAL CTR. RADIOLOGY DEPARTMENT 246 PARKER ST. CARLISLE, PA 17013 RE: 26672 VALERIE D. CHANDLER Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : VALERIE D. CHANDLER 4 S. ACORN DRIVE, WILDING SPRING, PA 17007 Social Security #: XXX-XX-8778 Date of Birth: 06-25-1970 R1.11S 133-H SU10-0632232 26672-LO2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: VALERIE D. CHANDLER -VS- TAISEAN A. HARRIS COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 2006-1758 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/03/2006 ytI on behalf of Attorney rney for DEFENDANT R1.13 133-H DE11-0639362 26672-L03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: VALERIE D. CHANDLER -VS- TAISEAN A. HARRIS COURT OF COMMON PLEAS TERM, CASE NO: 2006-1758 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY WALNUT BOTTOM RADIOLOGY MEDICAL RECORDS & XRAYS ALEXANDER SPRING REHAB MEDICAL RECORDS & XRAYS BELVEDERE MEDICAL CENTER MEDICAL RECORDS & XRAYS TO: MICHAEL SCHERER, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE.: 07/14/2006 CC: MICHAEL FERGUSON, ESQ. - 06-481 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.11S 133-H DE02-0337017 26672-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VALERIE D. CHANDLER vs. TAISEAN A. HARRIS File No. 2006-1758 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for WALNUT BOTTOM A IO O rY (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: **** SEE ATTACHED RIDER **** at The MCC Gwo- Inc 1601 Market Street Suite 800 Philadelphia PA 19103 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: MICHAEL FERGUSON. ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG-PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: S i r /"04!, Seal of the Court 26672-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WALNUT BOTTOM RADIOLOGY 850 WALNUT BOTTOM ROAD CARLISLE, PA 17013 RE: 26672 VALERIE D. CHANDLER Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : VALERIE D. CHANDLER 4 S. ACORN DRIVE, BOILDING SPRING, PA 17007 Social Security #: XXX-XX-8778 Date of Birth: 06-25-1970 R1.11S 133-H SU10-0632234 26672-L03 CERTIFICATE IN THE MATTER OF: VALERIE D. CHANDLER TAISEAN A. HARRIS PREREQUISITE TO SERVICE OF A SUBPOENA O PURSUANT TO RULE 4009.22/y/ / COURT OF COMMON PLEAS -VS- TERM, CUMBERLAND CASE NO: 2006-1758 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/03/2006 $ on behalf of ear) L GUS N, SQ. - Attorney for DEFENDANT R1.13 133-H DE11-0639363 26672-LO4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: VALERIE D. CHANDLER -VS- TAISEAN A. HARRIS COURT OF COMMON PLEAS TERM, CASE NO: 2006-1758 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY WALNUT BOTTOM RADIOLOGY MEDICAL RECORDS & XRAYS ALEXANDER SPRING REHAB MEDICAL RECORDS & XRAYS BELVEDERE MEDICAL CENTER MEDICAL RECORDS & XRAYS TO: MICHAEL SCHERER, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/14/2006 CC: MICHAEL FERGUSON, ESQ. - 06-481 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 4800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.11S 133-H - DE02-0337017 26672-COI COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VALERIE D. CHANDLER VS. TAISEAN A. HARRIS File No. 2006-1758 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ALEXANDER PRIN r REHAB (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: **** SE A ACHED RTDFR **** at The MCS CaM Inc 1601 Market Street Suite 800. Philadelphia. PA 19103 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: MICHAEL FERGUSON. ESO. ADDRESS: 2411 N. FRONT ST. ARRTSB 1R PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: . ?. r rt L'i ?Y? Seal of the Court BY THE COURT: Prothonotary/Clerk, 26672-04 EXPLANATION OF REQUIRED RECORDS T0: CUSTODIAN OF RECORDS FOR ALEXANDER SPRING REHAB 1 TYLER COURT SUITE-200 CARLISLE. PA 17013 RE: 26672 VALERIE D. CHANDLER Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : VALERIE D. CHANDLER 4 S. ACORN DRIVE, WILDING SPRING, PA 17007 Social Security #: XXX-XX-8778 Date of Birth: 06-25-1970 R1.11S 133-H SU10-0632236 26672-L04 PREREQUISITE TO SERVICE OF A SUBPOENA IN THE MATTER OF: PURSUANT TO RULE 4009.22 VALERIE D. CHANDLER -VS- TAISEAN A. HARRIS 01'104441 COURT OF COMMON PLEAS TERM, CUMBERLAND CASE NO: 2006-1758 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 08/03/2006 1JqS on behalf of aawou Attorney for DEFENDANT R1.13 133-H DE11-0639364 26672-L05 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: VALERIE D. CHANDLER -VS- TAISEAN A. HARRIS COURT OF COMMON PLEAS TERM, CASE NO: 2006-1758 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE REGIONAL MEDICAL CNTR MEDICAL RECORDS CARLISLE REGIONAL MEDICAL CTR. X-RAY ONLY WALNUT BOTTOM RADIOLOGY MEDICAL RECORDS & XRAYS ALEXANDER SPRING REHAB MEDICAL RECORDS & XRAYS BELVEDERE MEDICAL CENTER MEDICAL RECORDS & XRAYS TO: MICHAEL SCHERER, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 07/14/2006 CC: MICHAEL FERGUSON, ESQ. - 06-481 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 R1.11S 133-H DE02-0337017 26672-CO1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VALERIE D. CHANDLER VS. TAISEAN A. HARRIS File No. 2006-1758 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for B V D E MEDICAL CENTER (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: **** SEE ATTACHED RIDER **** at The MCS Ca=- Inr 1601 Market Street. Suite 800 Philadelphia- PA 19103 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: MICHAEL FERGUSON ADDRESS: 2411_N. FRONT ST. TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ij ?LCY)L Seal of the Court 26672-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BELVEDERE MEDICAL CENTER 850 WALNUT BOTTOM ROAD CARLISLE, PA 17013 RE: 26672 VALERIE D. CHANDLER Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films. and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : VALERIE D. CHANDLER 4 S. ACORN DRIVE, WILDING SPRING, PA 17007 Social Security #: XXX-XX-8778 Date of Birth: 06-25-1970 R1.11S 133-H SU10-0632236 26672-LOS C? r-A p 'ft C n rn Gn -Y VALERIE D. CHANDLER, Plaintiff vs. TAISEAN A. HARRIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 1758 Civil Term CIVIL ACTION - LAW JURY TRIAL DEMANDED ORIGINAL PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendant, TAISEAN A. HARRIS, with regard to the above-captioned matter. Respectfully submitted, Date: -jo.L.&P NEALON GOVER & PERRY _1q U C By: u DD4:?9= Michael S. Ferguson, Esquire I.D. No. 83882 2411 North Front Street Harrisburg, PA 17110 717/232-9900 4 CERTIFICATE OF SERVICE AND NOW, this day of , 2006, 1 hereby certify that I have served the foregoing PRAECIPE TO WITHDRAW APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Michael A. Scherer, Esquire 19 West South Street Carlisle, PA 17013 Michael S. Ferguson, Esquire P Z G:3-+ 7- i rA-?? \ ? I"7 ? r i i ? CZ) j _ Jeffrey T. McGuire, Esquire Attorney I. D. # 73617 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Attorney for Defendant, Taisean A. Harris VALERIE D. CHANDLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2006-CV-1758-CV TAISEAN A. HARRIS CIVIL ACTION - LAW Defendants. : JURY TRIAL DEMANDED ORIGINAL PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, Taisean A. Harris, with regard to the above-captioned matter. Ily submitted, Date: October 6, 2006 By: J . McGuire, Esquire ey I. D. # 73617 dwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Attorney for Defendant, Taisean A. Harris CERTIFICATE OF SERVICE AND NOW, this 6th day of October 2006, 1 hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mail at Harrisburg, Pennsylvania, postage prepaid, addressed to: Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013-3445 CALDWELL & KEARNS ?--- By: ,ilo Shirl . Erb, Secretary 107556 -?, ?"? '-_? 1 I, ?? 4..? ? _ _.? ,. r' _.?_ ?? r ``; ?,:. ?i' -` tom.) .. ?` ` ?; :; Jeffrey T. McGuire, Esquire Attorney I.D. No. 73617 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) Attorneys for Taisean A. Harris VALERIE D. CHANDLER, and DAVID CHANDLER Plaintiffs vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 1758 Civil Term TAISEAN A. HARRIS Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Valerie D. Chandler David Chandler c/o Michael A. Scherer, Esquire 19 West South Street Carlisle, PA 17013 YOU ARE HEREBY NOTIFIED that the New Matter set forth herein contain averments against you to which you are required to respond within twenty (20) days after service thereof. Failure by you to do so may constitute an admission. bmitted, Date: May 96, 2007 By: MclGuire, Esquire I.D.#73617 Jeffrey T. McGuire, Esquire Attorney I.D. No. 73617 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 (717) 232-2766 (fax) Attorneys for Taisean A. Harris VALERIE D. CHANDLER, and DAVID CHANDLER Plaintiffs vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006 1758 Civil Term TAISEAN A. HARRIS Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED DEFENDANT, TAISEAN A. HARRIS' ANSWER TO COMPLAINT WITH NEW MATTER AND NOW, comes Defendant, Taisean A. Harris, by and through his attorney, Jeffrey T. McGuire, Esquire, of Caldwell & Kearns, PC, and files the within Answer to Plaintiff's Complaint and avers in support thereof as follows: 1. Admitted on information and belief. 2. Admitted. 3. Admitted. 4. Admitted. 5. - 6. It is admitted that the Defendant's vehicle came into contact with the rear of th Plaintiff's vehicle at that location. COUNTI Valerie D. Chandler v. Taisean A. Harris 7. - 12. Denied. After reasonable investigation, the Defendant is without sufficient knowledge or information to form a belief as to the truth of the matter asserted. Therefore, it is denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, Defendant requests judgment in his favor and against the Plaintiff together with any costs associated therewith. COUNT II David Chandler v. Taisean A. Harris 13. Paragraphs 1 through 12 are incorporated herein by reference thereto. 14. Denied pursuant to Pa. R.C.P. 1029(e). WHEREFORE, Defendant requests judgment in his favor and against the Plaintiff together with any costs associated therewith. NEW MATTER 15. Plaintiffs' claim is barred in whole or in part by provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 16. Plaintiffs' injuries pre-existed the motor vehicle accident which is the subject of Plaintiffs' complaint. 17. In accordance with §1722 of the Pennsylvania Motor Vehicle Financial Responsibility law, Plaintiff is not entitled to recover any sums paid or payable from any group plan or other arrangement from this Defendant. 18. Plaintiff fails to plead whether she was bound by the limited tort or full tort option on the date of the accident, and if limited tort applies, Plaintiff failed to plead an exception to the rule prohibiting recovery of non-economic damages in accordance with 75 Pa. C.S.A. § 1705. 19. Defendant specifically preserves those defenses of contributory/comparative negligence and assumption of risk under Pa. R.C.P. 1030. 2 WHEREFORE, Defendant demands that the complaint be dismissed and judgment entered in his favor and against the Plaintiff without cost to him but together with such costs, expenses and attorneys fees as authorized by law and which the Court deems necessary, just and appropriate under the circumstances. submitted, Date: May 3a , 2007 By: XcGuire, Esquire I. D. # 73617 Q'aldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Attorney for Defendant, Taisean A. Harris 06621-011/108381 3 VERIFICATION I, Jeffrey T. McGuire, Esquire, Attorney for Defendant, Taisean A. Harris, who is authorized to make this Verification on Defendant's behalf, verify that the information contained in the foregoing document is true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: 3d 7 CERTIFICATE OF SERVICE AND NOW, thisday of May 2007 I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mail at Harrisburg, Pennsylvania, postage prepaid, addressed to: Michael A. Scherer, Esquire 19 West South Street Carlisle, PA 17013 CALDWELL & KEARNS By= i . e r .. R7 Fz:z _r7 ? N ? rrt ' 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-1758 CIVIL TERM CIVIL ACTION-LAW REPLY TO NEW MATTER 15. The allegations in Paragraph 15 are a conclusion of law and no response VALERIE D. CHANDLER and DAVID CHANDLER, Plaintiffs V. : TAISEAN A. HARRIS, Defendant is required. 16. Denied. The injuries of Valerie Chandler as described in the Complaint were as a result of the motor vehicle accident caused by the negligence of the defendant. 17. The allegations in Paragraph 17 are a conclusion of law and no response is required. 18. Denied. Plaintiffs are not required to plead their tort option. 19. The allegations in Paragraph 19 are a conclusion of law and no response is required. Respectfully submitted, O'BRIEN, BA IC & SCHERER A11/ .. , / M(fchabl A.' S6herer, Esquire I.D. No. 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiffs mas.dir/genlit/chandler/newmatter.rep J VALERIE D. CHANDLER and DAVID CHANDLER, Plaintiffs V. TAISEAN A. HARRIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-1758 CIVIL TERM CIVIL ACTION-LAW VERIFICATION I verify that the statements made in the foregoing Reply To New Matter are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: June A( 2007 Date: June ?_, 2007 /UO- "__ 'Et)VO-141111 Valerie D. Chandler avid Chandler L/ CERTIFICATE OF SERVICE I hereby certify that on July 6, 2007, I, Amanda L. Fisher, secretary at O'Brien, Baric & Scherer, did serve a copy of the Reply To New Matter, by U.S. First Class mail, postage prepaid, to the party listed below, as follows: Jeffrey T. McGuire, Esquire Caldwell and Kearns 3631 North Front Street Harrisburg, Pennsylvania 17110 Amanda L. Fisher `?? ?-- ? _ ?rc ,1 ?? c- --, ys. :? ? _ ~ =;' - ;.,?; -;? a s ? ;? ? ;;? •' =r? -; ? :C W-" -., VALERIE D. CHANDLER and DAVID CHANDLER, Plaintiffs V. TAISEAN A. HARRIS, Defendant TO THE PROTHONOTARY: IN THE COURT OF 130MMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-175 CIVIL TERM CIVIL ACTION-LA U Kindly mark the above-captioned action as h Respectfully O'BRIEN, Bj Date: r t. q. 0 -7 been settled and discontinued. mitted, & SCHERER r Micha I A. ScRerer, Esquire I.D. # 1974 19 West South Street Carlisle, PA 17013 (717) 49-6873 for Plaintiffs qGR& I hereby certify that on November _L , 2007, I; Jennifer S. Lindsay, secretary at O'Brien, Baric & Scherer, did serve a copy of the Pra cipe To Discontinue, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Jeffrey T. McGui e, Es uire Caldwell and earn 3631 North Fro6t Street Harrisburg, Pennsylvania 17110 say h - ?+o p ZDI M,