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HomeMy WebLinkAbout06-6458. F: \FILES\DATAFILE\General\Current\ l 1936. L complaint Revised: 11/2/06 1 1: 07 AM George B. Faller, Jr., Esquire I.D. Number 49813 Jennifer L. Spears, Esquire I.D. Number 87445 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 717-243-3341 Attorneys for Plaintiff KIM M. SHOWERS and DAVID C. SHOWERS, Plaintiffs V. DONNA K. KNOUSE and TAMMY J. KNOUSE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION ` : JURY TRIAL DEMANDED NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment maybe entered against you by the courtwithout further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiffs. 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 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 REDUCE FEE OR NO FEE: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 KIM M. SHOWERS and IN THE COURT OF COMMON PLEAS OF DAVID C. SHOWERS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs V. NO. OL - L V 9P CIVIL ACTION ` DONNA K. KNOUSE and TAMMY J. KNOUSE, Defendants JURY TRIAL DEMANDED COMPLAINT AND NOW, Plaintiffs, Kim M. and David C. Showers, by and through their attorneys, MARTSON DEARDORFF WILLIAMS & OTTO, file this complaint and aver as follows: 1. Plaintiffs, David C. and Kim M. Showers, husband and wife, are adult individuals residing at 65 Marilyn Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendants, Donna K. Knouse and Tammy J. Knouse, are both adult individuals residing at 66 Bartho Drive, Landisburg, Perry County, Pennsylvania. 3. On or about November 25, 2005, at approximately 1:00 pm, Plaintiff Kim Showers was the owner and operator of a 2002 Pontiac Grand Prix, in which her husband David Showers was a passenger, traveling north on North West Street in Carlisle, Pennsylvania. 4. At that same time, Defendant Tammy J. Knouse was driving a 1996 Mercury, which was owned by Defendant Donna K. Knouse, heading west on "H" Street in Carlisle, Pennsylvania crossing North West Street. 5. Defendant Tammy Knouse was allegedly stopped at the stop sign at the intersection of"H" and North West Streets, then proceeded through the intersection and drove her vehicle into Plaintiffs' vehicle who were rightfully traveling down North West Street. 6. Defendant Tammy Knouse failed to see Plaintiffs' vehicle, which had the right of way, before pulling out into the intersection and hitting Plaintiffs' vehicle. 7. Defendant Tammy Knouse's negligence consists of, among other things, the following acts and/or omissions, which substantially contributed to and were the proximate cause of the injuries suffered by Plaintiffs: a. Failing to abide by speed limits and traveling at an unlawful speed in violation of, among other things, 75 Pa.C.S.A. § 3361; b. Failing to take evasive action to avoid an impact with Plaintiffs; C. Operating her vehicle at an excessive rate of speed under the circumstances; d. Failing to have her vehicle under proper and adequate control; e. Failing to apply the brakes in time to avoid the collision; f. Failing to observe Plaintiffs' vehicle on the highway; g. Failing to operate her vehicle in accordance with existing traffic conditions and traffic controls; h. Failing to exercise the high degree of care required of a motorist entering an intersection; Failing to properly observe traffic signals controlling Defendant's direction oftravel; Failing to keep a reasonable look-out for other vehicles lawfully on the road; k. Attempting to enter an intersection when such movement could not be safely accomplished; Failing to yield the right-of-way to traffic already upon the road; in. Failing to prudently proceed through the intersection so as to avoid creating a dangerous situation for other vehicles on the highway; n. Proceeding through an intersection when such movement could not be made in safety; o. Failing to keep a proper lookout for approaching vehicles; P. Operating the vehicle so as to create a dangerous situation for other vehicles on the roadway; q. Failing to have her vehicle under proper and adequate control; r. Operating her vehicle in a careless disregard for the lives and property of others in violation of 75 Pa.C.S.A. § 3714; S. Permitting or allowing her vehicle to strike and collide with the vehicle operated by the Plaintiffs; and t. Failing to keep a proper lookout and see Plaintiffs' vehicle lawfully traveling on North West Street prior to the collision. 8. Defendant Donna K. Knouse's negligence consists of, among other things, the following acts and/or omissions, which substantially contributed to and were the proximate cause of the injuries suffered by Plaintiffs entrusting: a. A motor vehicle to an individual you knew or should have known was incapable of operating said motor vehicle in a safe and lawful manner; b. A motor vehicle to an individual you knew or should have known was an incompetent and unsafe driver; C. A motor vehicle to an individual you knew or should have known was likely to use a motor vehicle in a manner that would create an unreasonable risk of harm to others; and d. A motor vehicle to an individual without undertaking adequate measures to ensure that the driver was capable of operating said motor vehicle in a safe and lawful manner. COUNTI HIM M. SHOWERS v. DONNA K. KNOUSE 9. The averments ofparagraphs 1 through 8, inclusive, are incorporated herein by reference. 10. As a direct and proximate result of the negligence of Defendant as stated above, Plaintiff suffered numerous serious and permanent physical injuries, including, but not limited to pain in her lumbar and thoracic spine, hips, legs, and knees, and fractured ribs. 11. As a direct and proximate result ofthe negligence ofDefendant, Plaintiffwas forced to incur medical bills and expenses for the injuries she has suffered and she will continue to incur medical expenses in the future. 12. As a direct and proximate result ofthe negligence ofDefendant, Plaintiffhas suffered, or may suffer, a severe loss of her earnings and impairment ofher earning capacity, and the loss of 'income and impairment of earning capacity will, or may, continue in the future. 13. As a direct and proximate result of the negligence of Defendant, Plaintiff has undergone, and may in the future undergo, great mental and physical pain and suffering, mental anguish and humiliation, loss of life's pleasures, and a severe limitation in her pursuit of daily activities, all to her great loss and detriment. 14. Defendant had a duty to Plaintiffto act according to the rules ofthe road and laws ofthe Commonwealth, but breached such duty through her negligence as set forth above. 15. At all times material hereto, Plaintiff acted with due care and was not contributorily negligent. WHEREFORE, Plaintiffs demand judgment against Defendant in excess of $35,000.00, including costs of suit, and any other relief this court deems appropriate. COUNT II DAVID C. SHOWERS v. DONNA K. KNOUSE 16. The averments ofparagraphs 1 through 15, inclusive, are incorporated herein by reference. 17. As a direct and proximate result of the negligence of Defendant as stated above, Plaintiff suffered numerous serious and permanent physical injuries, including, but not limited to pain in his back, right leg and knee, and hips. 18. As a direct and proximate result ofthe negligence ofDefendant, Plaintiffwas forced to incur medical bills and expenses for the injuries he has suffered and he will continue to incur medical expenses in the future. 19. As a direct and proximate result ofthe negligence ofDefendant, Plaintiffhas suffered, or may suffer, a severe loss of his earnings and impairment of his earning capacity, and the loss of income and impairment of earning capacity will, or may, continue in the future. 20. As a direct and proximate result of the negligence of Defendant, Plaintiffhas undergone, and may in the future undergo, great mental and physical pain and suffering, mental anguish and humiliation, loss of life's pleasures, and a severe limitation in his pursuit of daily activities, all to his great loss and detriment. 21. Defendant had a duty to Plaintiff to act according to the rules of the road and laws of the Commonwealth, but breached such duty through her negligence as set forth above. 22. At all times material hereto, Plaintiff acted with due care and was not contributorily negligent. WHEREFORE, Plaintiffs demand judgment against Defendant in excess of $35,000.00, including costs of suit, and any other relief this court deems appropriate. COUNT III KIM M. SHOWERS v. TAMMY I KNOUSE 23. The averments ofparagraphs 1 through 22, inclusive, are incorporated herein by reference. 24. As a direct and proximate result of the negligence of Defendant as stated above, Plaintiff suffered numerous serious and permanent physical injuries, including, but not limited to pain in her lumbar and thoracic spine, hips, legs, and knees, and fractured ribs. 25. As a direct and proximate result of the negligence ofDefendant, Plaintiffwas forced to incur medical bills and expenses for the injuries she has suffered and she will continue to incur medical expenses in the future. 26. As a direct and proximate result of the negligence of Defendant, Plaintiffhas suffered, or may suffer, a severe loss ofher earnings and impairment ofher earning capacity, and the loss ofincome and impairment of earning capacity will, or may, continue in the future. 27. As a direct and proximate result of the negligence of Defendant, Plaintiff has undergone, and may in the future undergo, great mental and physical pain and suffering, mental anguish and humiliation, loss of life's pleasures, and a severe limitation in her pursuit of daily activities, all to her great loss and detriment. 28. Defendant had a duty to Plaintiffto act according to the rules ofthe road and laws ofthe Commonwealth, but breached such duty through her negligence as set forth above. 29. At all times material hereto, Plaintiff acted with due care and was not contributorily negligent. WHEREFORE, Plaintiffs demand judgment against Defendant in excess of $35,000.00, including costs of suit, and any other relief this court deems appropriate. COUNT IV DAVID C. SHOWERS v. TAMMY I KNOUSE 30. The averments of paragraphs 1 through 29, inclusive, are incorporated herein byreference. 31. As a direct and proximate result of the negligence of Defendant as stated above, pain in his back, right leg and knee, and hips. 32. As a direct and proximate result of the negligence of Defendant, Plaintiffwas forced to incur medical bills and expenses for the injuries he has suffered and he will continue to incur medical expenses in the future. 33. As a direct and proximate result of the negligence of Defendant, Plaintiff has suffered, or may suffer, a severe loss ofhis earnings and impairment ofhis earning capacity, and the loss of income and impairment of earning capacity will, or may, continue in the future. 34. As a direct and proximate result ofthe negligence ofDefendant, Plaintiff has undergone, and may in the future undergo, great mental and physical pain and suffering, mental anguish and humiliation, loss of life's pleasures, and a severe limitation in his pursuit of daily activities, all to his great loss and detriment. 35. Defendant had a duty to Plaintiffto act according to the rules ofthe road and laws ofthe Commonwealth, but breached such duty through her negligence as set forth above. 36. At all times material hereto, Plaintiff acted with due care and was not contributorily negligent. WHEREFORE, Plaintiffs demand judgment against Defendant in excess of $35,000.00, including costs of suit, and any other relief this court deems appropriate. COUNT V- LOSS OF CONSORTIUM DAVID C. SHOWERS v. DONNA K. KNOUSE AND TAMMY J. KNOUSE 37. The averments ofparagraphs 1 through 36, inclusive, are incorporated herein by reference. 38. David and Kim Showers are husband and wife and were married at the time of the accident. 39. As a result of the injuries sustained by Kim Showers in the accident, David Showers has suffered from the loss of aid, assistance, comfort, companionship and society of his spouse. 40. As a direct and proximate result of the negligence of Defendants Donna and Tammy Knouse as set forth herein, PlaintiffDavid Showers suffered among other things, emotional trauma and loss of consortium, which is claimed as damages herein, as well as other damages allowed by law. WHEREFORE, Plaintiffs demand judgment against Defendants in excess of $35,000.00, including costs of suit, and any other relief this court deems appropriate. Date: MARTSON DEARDORFF WILLIAMS & OTTO By George B. Fall r h I.D. Number 49813 Jennifer L. Spears, Esquire I.D. Number 87445 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiffs VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of our knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities, which provides that if l make knowingly false averments, I maybe subject to criminal penalties. avid C. owers 7 Kim M. Showers ZVI n h C -T) r-? c-a i C? ?J 77- i t^ c f ?l _-t 4..7 --t P Johnson, Duffie, Stewart & Weidner By: C. Roy Weidner, Jr. I.D. No. 19530 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 crw@jdsw.com KIM M. SHOWERS and DAVID C. SHOWERS, Plaintiffs V. DONNA K. KNOUSE and TAMMY J. KNOUSE, Defendants APPEARANCE NO. 06-6458 CIVIL TERM CIVIL ACTION - LAW JURY TRIAL DEMANDED AND NOW, this day of November, 2006, enter the appearance of C. ROY WEIDNER, JR., I.D. 19530, on behalf of Defendants in the above captioned suit. JOHNSON, DUFFIE, STEWART & WEIDNER C. Roy We ner, Jr. Attorneys for Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :287172 5774-517 16 CERTIFICATE OF SERVICE AND NOW, this a J day of November, 2006, the undersigned does hereby certify that 1 she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: George B. Faller, Jr., Esquire Martson, Deardorff, Williams & Otto 10 East High Street Carlisle, PA 17013 JOHNSON, DUFFIE, STEWART & WEIDNER By: Wchelle H. Spangler fT; "? -.) .. t =? ? -Y.? .. .')"_ ??4r • •? __ ?: . ?. I? Johnson, Duffle, Stewart & Weidner By: C. Roy Weidner, Jr. I.D. No. 19530 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 crw@jdsw.com Attorneys for Defendants KIM M. SHOWERS and IN THE COURT OF COMMON PLEAS OF DAVID C. SHOWERS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs NO. 06-6458 CIVIL TERM V. CIVIL ACTION - LAW DONNA K. KNOUSE and JURY TRIAL DEMANDED TAMMY J. KNOUSE, ; Defendants ANSWER TO PLAINTIFFS' COMPLAINT AND NOW, this day of December, 2006, come Defendants Donna K. Knouse and Tammy J. Knouse through their undersigned attorneys, and answer Plaintiffs' complaint as follows: 1. - 6. Admitted. 7. - 8. Denied. COUNT I KIM M. SHOWERS v. DONNA K. KNOUSE 9. Admitted in Part. Denied in Part. Paragraphs 1 - 8 hereof are incorporated by reference herein. 10.-15. Denied. WHEREFORE, Defendant demands that Plaintiffs complaint against her be dismissed. COUNT 11 DAVID C. SHOWERS v. DONNA K. KNOUSE 16. Admitted in Part Denied in Part. Paragraphs 1 - 15 hereof are incorporated by reference herein. 17.-22. Denied. WHEREFORE, Defendant demands that Plaintiff's complaint against her be dismissed. COUNT M KIM M. SHOWERS v. TAMMY J. KNOUSE 23. Admitted in Part Denied in Part. Paragraphs 1 - 22 hereof are incorporated by reference herein. 24.-29. Denied. WHEREFORE, Defendant demands that Plaintiff's complaint against her be dismissed. COUNT IV DAVID C. SHOWERS v. TAMMY J. KNOUSE 30. Admitted in Part. Denied in Part. Paragraphs 1 - 29 hereof are incorporated by reference herein. 31.-36. Denied. WHEREFORE, Defendant demands that Plaintiff's complaint against her be dismissed. COUNT V- LOSS OF CONSORTIUM DAVID C. SHOWERS v. DONNA K. KNOUSE AND TAMMY J. KNOUSE 37. Admitted in Part. Denied in Part Paragraphs 1 - 36 hereof are incorporated by reference herein. 38.-40. Denied. WHEREFORE, Defendant demands that Plaintiff's complaint against her be dismissed. NEW MATTER - MVFRL 41. Defendants are entitled to the restrictions on Plaintiffs' ability to recover damages provided in the Motor Vehicle Financial Responsibility Law. WHEREFORE, Defendant demands that Plaintiff's complaint against her be dismissed. JOHNSON, DUFFIE, STEWART & WEIDNER r By (!?VRoy Weidner, Jr. :288429 5774-517 VERIFICATION The undersigned says that the facts set forth in the foregoing amended answer to complaint are true and correct. This verification is made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsifications to authorities. YZ?? 2 L.AO-O? , Tam J. house yn Donna K. Knouse Dated: I G.. Irj , 2 OD CERTIFICATE OF SERVICE AND NOW, this gt'f' day of December, 2006, the undersigned does hereby certify that she did this date serve a copy of the foregoing document upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: George B. Faller, Jr., Esquire Martson, Deardorff, Williams & Otto 10 East High Street Carlisle, PA 17013 JOHNSON, DUFFIE, STEWART & WEIDNER By: Christine H. Hakel ? ?? t.. a ?;;,? r=-s ?,a. --+ ??., f 1 f?? ?I rj {?i t.....} +.. .. ?.? _. - .,J ? ? r •'1:: ?"?'?'? SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-06458 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SHOWERS KIM M ET AL VS KNOUSE DONNA K ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: KNOUSE DONNA K but was unable to locate Her deputized the sheriff of PERRY in his bailiwick. He therefore serve the within COMPLAINT & NOTICE County, Pennsylvania, to On November 15th , 2006 , this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Perry County 42.90 Postage 1.74 81.64 f 11/15/2006 MDW&O So answer . R. Thomas Klink, Sheriff of Cumberland County (,-- i,?- IvGlot, Sworn and subscribe to before me this day of P,. D. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2006-06458 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SHOWERS KIM M ET AL VS KNOUSE DONNA K ET AL R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: KNOUSE TAMMY J but was unable to locate Her deputized the sheriff of PERRY serve the within COMPLAINT & NOTICE in his bailiwick. He therefore County, Pennsylvania, to On November 15th , 2006 , this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 16.UU t 11/15/2006 MDW&O So answ- ?-=-- R. Thomas Kline Sheriff of Cumberland County 1/0, /6G Sworn and subscribe to before me this day of A. D. In The Court of Common Pleas of Cumberland County, Pennsylvania Kim M. Showers et al vs. Donna K. Knouse et: al SERVE: Donna K. Knouse No. 06-6458 Civil Now, November 7, 2006 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Perry County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, Nov. 9 , within Noticer & Complaint upon Donna K. Knouse Her at 66 Bartho Dr. Landisburg, PA 17040 ( Tyrone Twp) by handing to Donna K. Knous e , Defendant True & Attested a and made known to 20 0 6,at 12 :10 o' clock P M. served the copy of the original Notice & Complaint the contents thereof. So answers, Derek M. Bates - ; 1-4,164 Deputy -Sheriff-of Perry County, PA Sworn and subscribed before me this 9?A day of N6WAtbq--,206& A AAP . - . ?', 4. - ..A , IVUIRron? v?•- ?IARGARET E FLICKINGEPERRY CONTYUC BLOOMFIELD ., NN COMMISSIO BORO N EXPIRES FEB. 16, _ COSTS SERVICE _ MILEAGE _ AFFIDAVIT • s "In The Court of Common Pleas of Cumberland County, Pennsylvania Kim M. Showers et al VS. Donna K. Knouse et al SERVE: Tammy J. Knouse No. 06-6458 Civil Now, November 7, 2006 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Perry deputation being made at the request and risk of the Plaintiff. County to execute this Writ, this Sheriff of Cumberland County, PA Now, Nov. 9, within Notice & Complaint upon Tammy J. Knouse Affidavit of Service 20 06 at 12:10 o'clock P M. served the at 66 Bartho Dr. Landisburg, PA 17040 ( Tyrone Twp) by handing to Tammy J. Knouse, Defendant a True & Attested and made known to Her the contents thereof. Sworn and subscribed before me this day of , 200(0 In , NOTARIAL SEAL MARGARET E FLICKINGER, NOTARY PUBLIC BLOOMFIELD BORO., PERRY COUNTY MY COMMISSION EXPIRES FEB. 16, 2008 So answers, Derek Bates 4, W D e pu t Sheriff of Perry County, PA copy of the original Notice & Complaint COSTS SERVICE $ MILEAGE AFFIDAVIT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY SHOWERS & SHOWERS Vs. NO. 066458 KNOUSE & KNOUSE CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 C ROY WEIDNER JR, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 03/09/07 File #: M338855 C ROY WEIDNER JR, ESQUIRE 301 MARKET ST PO BOX 109 LEMOYNE, PA 17043 717-761-4540 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) By: Donna Garofolo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY SHOWERS & SHOWERS Vs. KNOUSE & KNOUSE I No. 066458 TO: GEORGE FALLER JR, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 02/16/07 C ROY WEIDNER JR, ESQUIRE 301 MARKET ST PO BOX 109 LEMOYNE, PA 17043 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 By: Donna Garofolo Enc (s) : Copy of subpoena(s) Counsel return card File #: M338855 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBER AND SHOWERS & SHOWERS Vs. KNOUSE & KNOUSE Fi le No. 066458 SUBPOENA TO PRODUCE DOGJM1ENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 PROGRESSIVE GROUP OF INS, 5165 CAMPUS DR, PLYMOUTH MTG PA 19462 TO: ATTN: VICKI REMOLDIE (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 A ADDENDUM -- at MEDICAL LEGAL REPRODUCTIONS(AgNressf940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of compliance, to the party making thi; request at the address listed above. You have the right to seek in advance the rea.onable 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 thi, subpoena may seek a court orde;. compelling you to cci p l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: C ROY WEIDNERJR, ESQ ADDRESS: _ 01 MARKET ST TELEPHONE : LEM 043 SUPREME COURT ID # 215-335-3212 ATTORNEY FOR : 19530 DEFENDANT M338855-01. DATE : 44. 0297 Seal of the Court BY THE OOURT: Prot tary/Cler ivi Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SHOWERS & SHOWERS Vs. No. 066458 KNOUSE & KNOUSE CUSTODIAN OF RECORDS FOR: PROGRESSIVE GROUP OF INS ANY AND ALL RECORDS, MEDICAL AND OR ACCIDENT CORRESPONDENCE, NOTES, RECEIPTS, BILLS, ETC., AND ANY OTHER INFORMATION PERTAINING TO: NAME: KIM M SHOWERS ADDRESS: 65 MARILYN DR CARLISLE PA DATE OF BIRTH: 03/04/65 SSAN: XXXXX4725 ALL POLICY INFORMATION INCLUDING DECLARATION PAGES FOR THE DATE OF LOSS, 11/25/05, AS WELL AS THE FIRST PARTY BENEFIT FILE. CLAIM #057224725; POLICY #52849027-1 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ l RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ l NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorize signature or PROGRESSIVE GROUP OF INS CUMBERLAND M338855-01 * * * SIGN AND RETURN THIS PAGE * * * COMMONWEALTH OF PENNSYLVANIA COON rY OF CL14BERIAN D SHOWERS & SHOWERS Vs. Fi le No. 066458 KNOUSE & KNOUSE , • ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCUIJENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: ORTHO INST OF PENNA, 3399 TRINDLE RD, CAMP HILL PA 17011 (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 things: SEE at MEDICAL LEGAL REPRODUCTIONS(AJdKss?940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of compliance, to the party making thiz- request at the address listed above. You have the right to seek in advance the rea,onable 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 thin subpoena may seek a court orde:- ooape l l i ng you to comm,p l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: C ROY WEIDNER JR, ESQ AC)DRESS: _ 01 MARKET ST r-.rr ? as=?rc TELFPHONE : LEM , --PA--" 04 3 SUPREME COURT ID # 215-335-3212 ATTORNEY FOR : 19530 DEFENDANT M338855-02 DATE : l?/.,P.t'? - a0 _ aco-- Seal of the Court BY THE COURT: Prot tary/Clam Civ 1 Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SHOWERS & SHOWERS Vs. KNOUSE & KNOUSE No. 066458 CUSTODIAN OF RECORDS FOR: ORTHO INST OF PENNA. ANY AND ALL RECORDS INCLUDING FILMS FROM DIAGNOSTIC STUDIES SUCH AS X-RAYS, MRIS, ETC. PERTAINING TO: NAME: KIM M SHOWERS ADDRESS: 65 MARILYN DR CARLISLE PA DATE OF BIRTH: 03/04/65 SSAN: XXXXX4725 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or ORTHO INST OF PENNA. CUMBERLAND M338855-02 * * * SIGN AND RETURN THIS PAGE * * * COVMNWEALTH OF PENNSYLVANIA COUN rY OF CUMBEFI ID SHOWERS & SHOWERS Vs. Fi le No. 066458 KNOUSE & KNOUSE , ORIGINAL X-RAYS REQUESTED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 DR JAMES THOMPSON III, C/O MECHANICSBURG FAM PRACTICE, 122 S FILBERT ST TO: MF.C'HANTOSBURG PA 17055 (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 ADDENDUM MEDICAL LEGAL REPRODUCTIONS(AJG%ssf940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of compliance, to the party making thir- 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 thi subpoena may seek a court orde-• ampel ling you to camply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: C ROY WEIM R JR, ESQ ADDRESS: 301 MARKET ST TELEPHONE : LEMOYNE, PA 1 043 SUPREME COURT ID # 215-335-3212 ATTORNEY FOR : 1 9 5 3 0 DEFENDANT M338855-03 DATE : SYd• -70,--7402 Seal of the Court BY TFIE COURT: Prot tary/cler 1v• Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SHOWERS & SHOWERS Vs. KNOUSE & KNOUSE No. 066458 CUSTODIAN OF RECORDS FOR: DR JAMES THOMPSON III ANY AND ALL RECORDS INCLUDING FILMS FROM DIAGNOSTIC STUDIES SUCH AS X-RAYS, MRIS, ETC. PERTAINING TO: NAME: KIM M SHOWERS ADDRESS: 65 MARILYN DR CARLISLE PA DATE OF BIRTH: 03/04/65 SSAN: XXXXX4725 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or DR JAMES THOMPSON III CUMBERLAND M338855-03 * * * SIGN AND RETURN THIS PAGE * * * SHOWERS & SHOWERS Vs. KNOUSE & KNOUSE File No. 066458 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: COMMONWEALTH OF PPNNSYLVANTA COUNTY OF CUM[BEF IAAND (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 at ALEXANDER SPRING REHAB, 1 TYLER CT, CARLISLE PA 17013 MEDICAL LEGAL REPRODUCTIONS (A sst940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of compliance, to the party making thi= request at the address listed above. You have the right to seek in advance the rea.onable 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 thin, subpoena may seek a court orde;- cxmipe l l i ng you to comp 1 y with it. THIS SUBPOENA WAS ISSUED AT THE RECXJEST OF THE FOLLOWING PERSON: NAME: C ROY WEIDNER JR, ESQ ADDRESS : 361 MARKET- ST LEMO ,- A-1-7043 TELFP}-ZONE SUPREME COURT ID # 215-335-3212 ATTORNEY FOR : 19530 DEFENDANT M338855-04 DATE : ?`..P/J - y74. 07.,2:9 7_ Seal of the Court BY THE OOURT: Prot tars/Clerk, 1 ivision Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SHOWERS & SHOWERS Vs. No. 066458 KNOUSE & KNOUSE CUSTODIAN OF RECORDS FOR : ALEXANDER SPRING REHAB ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: KIM M SHOWERS ADDRESS: 65 MARILYN DR CARLISLE PA DATE OF BIRTH: 03/04/65 SSAN: XXXXX4725 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge,,information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or ALEXANDER SPRING REHAB CUMBERLAND M338855-04 * * * SIGN AND RETURN THIS PAGE * * * COMMDNWFALTH OF PENNSYLVANIA COUNTY OF CL) BERIAM SHOWERS & SHOWERS Vs. Fi le No. 066458 KNOUSE & KNOUSE , SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 AMERIHEALTH MERCY HEALTH, 2404 PARK DR, HARRISBURG PA 17110 TO: ATTN: LEGAL DEPT (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 A at _ MEDICAL LEGAL REPRODUCTIONS(A&%Ssf940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested h? this subpoena, together with the certificate of ccmpliance, to the party making thi_ request at the address listed above. You have the right to seek in advance the rea,onable 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 orde:- oarpe l l i ng you to carp l y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: C ROY WEIDNER JR, ESQ ADDRESS .,, MARKET c+m TELEPHONE : LEM , -PA= 0 4 3 SUPREME COURT ID # 215-335-3212 ATTORNEY FOR : 19530 DEFENDANT M338855-05 DATE : QM' - a©. Seal of the Court BY THE COURT: Prot tary/C erk Ivi Division Deputy (Eff. 1/97) ADDENDUM TO SUBPOENA SHOWERS & SHOWERS Vs. KNOUSE & KNOUSE No. 066458 CUSTODIAN OF RECORDS FOR : AMERI EEALTH MERCY HEALTH ANY AND ALL RECORDS, MEDICAL AND OR ACCIDENT CORRESPONDENCE, NOTES, RECEIPTS, BILLS, ETC., AND ANY OTHER INFORMATION PERTAINING TO: NAME: KIM M SHOWERS ADDRESS: 65 MARILYN DR CARLISLE PA DATE OF BIRTH: 03/04/65 SSAN: XXXXX4725 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or AMERIHEALTH MERCY HEALTH CUMBERLAND M338855-05 * * * SIGN AND RETURN THIS PAGE * * * COK40NWEALTH OF PENNSYLVANIA COLWrY OF C UMBERIAND SHOWERS & SHOWERS Vs. File No. KNOUSE & KNOUSE SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 066458 CLAIMS MANAGEMENT INC, PO BOX 1288, BENTONVILLE AR 72712 TO:- ATTN: MICHELLE KELLOGG (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 -- at _ MEDICAL LEGAL REPRODUCTIONS(A sI940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of ccmpliance, to the party making thi; request at the address listed above. You have the right to seek in advance the rea.onable 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 thin subpoena may seek a court orde;- compeiling you to carply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: C ROY WEIDNER JR, ESQ ADDRESS: - 301 MARKET ST TELEPHONE : LEMOYNE, PA-E7043 SUPREME COURT ID 4 215-335-3212, ATTORNEY FOR: 19530 DEFENDANT M338855-06 DATE : Seal of the Court BY THE COURT: Prot tary/Cler iv Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SHOWERS & SHOWERS Vs. No. 066458 KNOUSE & KNOUSE CUSTODIAN OF RECORDS FOR: CLAIMS MANAGEMENT INC ANY AND ALL WORKERS COMPENSATION RECORDS. CLAIM #C4261784 PERTAINING TO: NAME: KIM M SHOWERS ADDRESS: 65 MARILYN DR CARLISLE PA DATE OF BIRTH: 03/04/65 SSAN: YXXXX4725 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or CLAIMS MANAGEMENT INC CUMBERLAND M338855-06 * * * SIGN AND RETURN THIS PAGE * * * rr*AM'JNWEALTH OF FII?IlQSYLVANIA OOLRM OF CUMBERLAND SHOWERS & SHOWERS Vs. File No. 066458 KNOUSE & KNOUSE SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 WALMART, 702 SW 8TH AVE, BENTONVILLE AR 72716 TO: ATTN: LEGAL DEPT (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 ADDENDUM at MEDICAL LEGAL REPRODUCTIONS{AgNeSsI940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of ccmpliance, to the party making thi_ request at the address listed above. You have the right to seek in advance the rea.onable 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 thi, subpoena may seek a court order oo pelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: C ROY WEIDNER JR, ESQ ADDRESS : _ 301 MARKET ST TELEPHONE: LEM , -FA-37043 SUPREME OOURT ID # 215-335-3212 ATTORNEY FOR : 19530 DEFENDANT M338855-07' DATE: Q?, old, o7ee9? Seal of the Court BY THE OOURT: Prot tary/Cler Civi Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SHOWERS & SHOWERS Vs. No. 066458 KNOUSE & KNOUSE CUSTODIAN OF RECORDS FOR: WALMART ENTIRE PERSONNEL/EMPLOYMENT FILE INCLUDING WORKERS' COMPENSATION FILE. *EMPLOYED AT WALMART STORES INC, 6520 CARLISLE PK, MECHANICSBURG PA 17055. PERTAINING TO: NAME: KIM M SHOWERS ADDRESS: 65 MARILYN DR CARLISLE PA DATE OF BIRTH: 03/04/65 SSAN: XXXXX4725 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or WALMART CUMBERLAND M338855-07 * * * SIGN AND RETURN THIS PAGE * * * r.J i ??J ?? --i1 .?r? rf.,? {?; i ? _F •_ ti. '? =s', L .._ G`„- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY SHOWERS & SHOWERS Vs. NO. 066458 KNOUSE & KNOUSE CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 C ROY WEIDNER JR, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 03/09/07 C ROY WEIDNER JR, ESQUIRE 301 MARKET ST PO BOX 109 LEMOYNE, PA 17043 717-761-4540 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) File #: M338854 By: Donna Garofolo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY SHOWERS & SHOWERS Vs. KNOUSE & KNOUSE I No. 066458 TO: GEORGE FALLER JR, ESQ (PLAINTIFF) NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: 02/16/07 C ROY WEIDNER JR, ESQUIRE 301 MARKET ST PO BOX 109 LEMOYNE, PA 17043 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 By: Donna Garofolo Enc(s): Copy of subpoena(s) Counsel return card File #: M338854 CONMNWFALTH OF PENNSYLVANIA OOUN.rY OF C LZBERLA ND SHOWERS & SHOWERS ' Vs. KNOUSE & KNOUSE File No. 066458 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 PROGRESSIVE GROUP OF INS, 5165 CAMPUS DR, PLYMOUTH MTG PA 19462 TO:- ATTW • VIrKTE REMOLDTE (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 at MEDICAL LEGAL REPRODUCTIONS(AgNssJ940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested b? this subpoena, together with the certificate of ccxnp1iance, to the party making thi request at the address listed above. You have the right to seek in advance the reasonablc- 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 orde;- compe l 1 i ng you to carp 1 y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAIE: r ROY WEIDNER JR, ESQ ADDRESS: _ 3.0 MARKET ST V 1 TELEPHONE: LEMOYNE, PA 17043 SUPREME OOURT I D S 215 - 3 3 5- 3 212 ATTORNEY FOR : 1 9 S1 0 DEFENDANT M338854-01 DATE: Seal of the Court BY THE CXXJRT : ° Prot tary/Cler 1 Division Deputy (Eff. 71/97) ADDENDUM TO SUBPOENA SHOWERS & SHOWERS Vs. KNOUSE & KNOUSE No. 066458 CUSTODIAN OF RECORDS FOR: PROGRESSIVE GROUP OF INS ANY AND ALL RECORDS, MEDICAL AND OR ACCIDENT CORRESPONDENCE, NOTES, RECEIPTS, BILLS, ETC., AND ANY OTHER INFORMATION PERTAINING TO: NAME: DAVID C SHOWERS ADDRESS: 65 MARILYN DR CARLISLE PA DATE OF BIRTH: 02/23/61 SSAN: XXXXX0293 ALL POLICY INFORMATION INCLUDING DECLARATION PAGES FOR THE DATE OF LOSS, 11/25/05, AS WELL AS THE FIRST PARTY BENEFIT FILE. CLAIM #057224725; POLICY #52849027-1 ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED. RECORD CUSTODIAN - COMPLETE AND RETURN [ l RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorized signature or PROGRESSIVE GROUP OF INS CUMBERLAND M338854-01 * * * SIGN AND RETURN THIS PAGE * * * COV1 DNWEALTH OF PENNSYLVANIA COUNPY OF COMBERLAND 4. , SHOWERS & SHOWERS Vs. File No. 066458 KNOUSE & KNOUSE , SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 AMGUARD INS CO, PO BOX 1368, WILKES BARRE PA 18703-1368 TO: ATTN: WC CLAIMS DEPT (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 at _ MEDICAL LEGAL REPRODUCTIONS(AMessf940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of ccmpliance, to the party making thi: 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 •thii subpoena may seek a court orde:- axrpe l l i ng you to comp 1 y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: C ROY WEIDNER JR, ESQ ADDRESS: _ 0 MARKET TELEPHONE : LEMO 7 04 3 SUPREME COURT I D# 215-335-3212 ATTORNEY FOR : .19530 DEFENDANT M338854-02 DATE : C1GCt oZ4 o74C? 7 Seal of the Court BY THE COURT: Prot y/Cler Wii Division Deputy (Eff. 7/97) ADDENDUM TO SUBPOENA SHOWERS & SHOWERS Vs. KNOUSE & KNOUSE No. 066458 CUSTODIAN OF RECORDS FOR : AMGUARD INS CO ANY AND ALL WORKERS COMPENSATION RECORDS. CLAIM ##BWWC346132018; INSURED: BWI OF PA INC. PERTAINING TO: NAME: DAVID C SHOWERS ADDRESS: 65 MARILYN DR CARLISLE PA DATE OF BIRTH: 02/23/61 SSAN: XXXXX0293 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO. I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE. I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX): ( ) RECORDS ( ) PATIENT BILLING ( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed Date Authorize signature or AMGUARD INS CO CUMBERLAND M338854-02 * * * SIGN AND RETURN THIS PAGE * * * ??' _? ,? :n, -n - t??? 1. Y: ? `;' `?? .?^' + ?" l N .; ?.. ; i" ?;? i '?\ ?-. rte' _ :?Y ?7 '; Johnson, Duffie, Stewart & Weidner By: C. Roy Weidner, Jr. I.D. No. 19530 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 crw@jdsw.com Attorneys for Defendants KIM M. SHOWERS and DAVID C. SHOWERS, Plaintiffs V. NO. 06-6458 CIVIL TERM CIVIL ACTION - LAW DONNA K. KNOUSE and JURY TRIAL DEMANDED TAMMY J. KNOUSE, Defendants PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY: Please mark the above captioned action settled and discontinued, including all counterclaims, crossclaims and joinders of additional parties. MARTSON, DEARDORFF, WILLIAMS & OTTO 11 12 11, 1 - &-n I By: &eg . F er, Jr. JOHNSON, DUFFIE, STEWART & WEIDNER By oy Weidner, Jr. DISCONTINUANCE CERTIFICATE AND NOW,?? a_(S_ suit has been marked as abo a directed. PROTHONOTARY :305175 5774517 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 6' CERTIFICATE OF SERVICE AND NOW, this fhday of ?l/U?°mCr 2007, the undersigned does hereby certify that she did this date serve a copy of the foregoing praecipe upon the other parties of record by causing same to be deposited in the United States Mail, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: George B. Faller, Jr., Esquire Martson, Deardorff, Williams & Otto 10 East High Street Carlisle, PA 17013 JOHNSON, DUFFIE, STEWART & WEIDNER By: 'chelle H. Spangler :305175 5774-517 Q ? i rn 0 -0 j 74, . rn N