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Home My WebLink About02-3672 CHRISTOPHER GOINS, Plaintiff, IN THE COURT OF COMMON FLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION LAW NO. ~ -.?L7 ~ Qic..J~l~~ FLYING J. INC. and FL YING J. TRAVEL PLAZA, Defendants. JURY TRIAL DEMANDED. NOTICE TO: Flying 1. Inc. 2704 Commerce Drive Harrisburg, P A TO: Flying J. Travel Plaza 150 I Harrisburg Pike Carlisle, P A YOU HA VB 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 attomey 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 ajudgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELF. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 249-3166 1-800-990-9108 Document ##191586 CHRISTOPHER GOINS, Plaintiff, IN THE COURT OF COMMON FLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION LAW NO. FL YING J. INe. and FLYING J. TRAVEL PLAZA, Defendants. JURY TRIAL DEMANDED. NOTICIA TO: Flying J. Inc. 2704 Commerce Drive Harrisburg, FA TO: Flying 1. Travel Plaza 1501 Harrisburg Pike Carlisle, P A US TED HA SInO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siquientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y A viso radicando personalrnente 0 por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se Ie advierte de que si usted falla de tomar accion como se describe anteriorrnente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda 0 cualquier otra reclamacion or remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero 0 propiedad u otros derechos importantes para usted. USTED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO FUEDE FAGARLE A UNO, LLAME 0 VA Y A A LA SIGUIENTE OFICINA PARA A VERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 249-3166 1-800-990-9108 Document #: 230063. J CHRISTOPHER GOINS, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. CIVIL ACTION LAWNO.40;Z -..1"7.2.- Civil .- leI-"^- FLYING J. INC. and FLYING J. TRAVEL PLAZA, JURY TRIAL DEMANDED. Defendants. CIVIL COMPLAINT I. Plaintiff Christopher Goins is an adult individual residing at 5316 Dogwood Road, Baltimore, Maryland. 2. Defendant Flying 1. Travel Plaza is a branch of a Utah corporation, Flying J. Inc., with a principal place of business at 1501 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania. 3. Defendant Flying J. Inc. is a Utah corporation with a duly registered agent in Pennsylvania located at 2704 Commerce Drive, Harrisburg, Dauphin County, Pennsylvania. 4. At all times relevant hereto, Defendant Flying J. Inc. owned, occupied, possessed, maintained, controlled and operated Flying J. Travel Plaza, a truck stop, restaurant and business establishment located at 1501 Harrisburg Pike, Carlisle, Cumberland County, Pennsylvania. 5. On August I, 2000, at approximately 2:00 a.m., Plaintiff Christopher Goins was proceeding to the restroom of the restaurant at Flying J. Travel Plaza, when his foot slipped on a recently mopped area causing him to fall to the concrete surface with resulting injury. 6. At the time of the fall, Plaintiff Christopher Goins was eating at the restaurant and was a business invitee. Document #: 230063. } 7. Plaintiff Christopher Goins was caused to fall by the negligent acts of an employee in mopping the floor and failing to warn customers of the condition. COUNT I Plaintiff Christopher Goins v. Defendant Flyine J. Travel Plaza 8. Paragraphs 1 through 7 hereof are incorporated herein by reference as if fully set forth. 9. Defendant Flying J. Travel Plaza knew or should have known of the dangerous condition on their premises and knew or should have expected that its customers would not discover the hazard and protect its customers against the hazard. 10. Defendant Flying J. Travel Plaza individually and/or by its agents, servants, workmen and/or employees, acting within the scope of their authority, breached its legal duty to the public and to the Plaintiff and was negligent in the falling particulars: a. failing to take the necessary protective and precautionary measures to insure that its customers, including Plaintiff, had a safe walkway surface and were not subject to the slipping hazard; b. failing to have an alternate walkway surface available to avoid the hazardous condition; c. failing to barricade, rope off, or otherwise bar access to the hazardous condition; d. failing to inspect the walkway surface to insure that no hazardous condition exists for its customers, including Plaintiff; Document #: 230063./ e. failing to place signs around the wet floor or otherwise failing to warn its customers, including Plaintiff, of the hazardous condition; f. failing to mark or otherwise identify the hazardous condition; g. failing to supervise its employees, servants, workmen, agents and/or independent contractors in their maintenance of the walkway surface; h. hiring and/or maintaining an employee, servant, workman, agent and/or independent contractor who is unfit or incompetent to maintain the walkway surface; 1. failing to properly supervise its employees, servants, workmen, agents, and/or independent contractors to insure that there is not a hazardous condition existing on the walkway surface and in the restaurant; J. failing to properly and adequate train its employees, servants, workmen, agents, and/or independent contractors to insure that there on the walkway surface in the restaurant did not pose a hazardous condition to its customers, including Plaintiff; and k. failing to exercise reasonable care to protect its customers, including Plaintiff, against the hazardous condition. 11. As a direct and proximate result of the negligence of Defendant Flying J. Travel Plaza, Plaintiff Christopher Goins sustained, and in the future may sustain, serious and debilitating injuries, some of which are or may be permanent and which may be an aggravation and/or exacerbation of preexisting injuries, which include, but are not limited to, the following: a. trauma and injury to his head, including a large scalp laceration; b. trauma and injury to his chest, including a chest wall contusion; c. trauma and injury to his back, including a cervical strain; Document #: 230063. J d. trauma and injury to his head, including a closed head injury; and e. trauma and injury to his eyes. 12. As a direct and proximate result of the aforesaid negligence, carelessness and recklessness of Defendant Flying 1. Travel Plaza, Plaintiff Christopher Goins was forced to incur medical bills and expenses for the injuries he has suffered and will continue to incur medical expenses in the future. 13. As a direct and proximate result of the aforesaid negligence, carelessness and recklessness of Defendant Flying 1. Travel Plaza, Plaintiff Christopher Goins has suffered and may suffer a loss of earnings, permanent disability, and impairment and or loss of earning capacity. 14. As a direct and proximate result of the aforesaid negligence, carelessness and recklessness of Defendant Flying J. Travel Plaza, Plaintiff Christopher Goins has undergone and in the future will undergo great physical pain, mental pain, discomfort, inconvenience, distress, embarrassment and humiliation, past and future loss of his ability to enjoy the pleasures oflife, and limitations in pursuit of daily activities, all to his great loss and detriment. 15. As a direct and proximate result of the aforesaid negligence, carelessness and recklessness of Defendant Flying J. Travel Plaza, Plaintiff Christopher Goins has sustained incidental costs and losses to include, but not be limited to, past and future medication costs and medical appliances. WHEREFORE, Plaintiff Christopher Goins demands judgment in his favor and against Defendant Flying J. Travel Plaza, for the aforesaid damages in an amount which exceeds the Document #: 230063.1 limits of compulsory arbitration in Cumberland County, Pennsylvania, plus interest and/or damages for delay and costs of prosecution. COUNT II Plaintiff Christopher Goins v. Flyin2 J. Inc. 16. Paragraphs 1 through 15 hereof are incorporated herein by reference as if fully set forth. 17. At all times relevant hereto, Defendant Flying J. Inc. and their employees, servants, workmen and/or agents were acting within the scope of their employment with Flying J. Inc., and said Defendant is vicariously liable for their acts, commissions or omissions as though it performed the acts, commissions or omissions itself and is subject to the doctrine of respondeat superior. 18. Defendant Flying J. Inc. knew or should have known of the dangerous condition at the restaurant and knew or should have expected that its customers would not discover the hazard and protected its customers against the hazard. 19. Defendant Flying 1. Inc. individually and/or by its agents, servants, workmen and/or employees, acting within the scope of their authority, breached its legal duty to the public and to the Plaintiff and was negligent in the following particulars: a. failing to take the necessary protective and precautionary measures to insure that its customers, including Plaintiff, had a safe walkway surface and were not subject to the slipping hazard; b. failing to have an alternate walkway surface available to avoid the hazardous condition; Document #: 230063.1 c. failing to barricade, rope off, or otherwise bar access to the hazardous condition; d. failing to inspect the walkway surface to insure that no hazardous condition exists for its customers, including Plaintiff; e. failing to place signs around the wet floor or otherwise failing to warn its customers, including Plaintiff, of the hazardous condition; f. failing to mark or otherwise identify the hazardous condition; g. failing to supervise its employees, servants, workmen, agents and/or independent contractors in their maintenance of the walkway surface; h. hiring and/or maintaining an employee, servant, workman, agent and/or independent contractor who is unfit or incompetent to maintain the walkway surface; i. failing to properly supervise its employees, servants, workmen, agents, and/or independent contractors to insure that there is not a hazardous condition existing on the walkway surface and in the restaurant; j. failing to properly and adequate train its employees, servants, workmen, agents, and/or independent contractors to insure that there on the walkway surface in the restaurant did not pose a hazardous condition to its customers, including Plaintiff; and k. failing to exercise reasonable care to protect its customers, including Plaintiff, against the hazardous condition. 20. As a direct and proximate result of the negligence, carelessness and recklessness of Defendant Flying J. Inc., Plaintiff Christopher Goins sustained and in the future may sustain, Document #: 230063.1 serious and debilitating injuries, some of which are and may be permanent, an aggravation of a preexisting condition which include, but are not limited to, the following: a. trauma and injury to his head, including a large scalp laceration; b. trauma and injury to his chest, including a chest wall contusion; c. trauma and injury to his back, including a cervical strain; d. trauma and injury to his head, including a closed head injury; and e. trauma and injury to his eyes. 21. As a direct and proximate result of the aforesaid negligence, carelessness and recklessness of Defendant Flying 1. Inc., Plaintiff Christopher Goins was forced to incur medical bills and expenses for the injuries he has suffered and will continue to incur medical expenses in the future. 22. As a direct and proximate result of the aforesaid negligence, carelessness and recklessness of Defendant Flying J. Inc., Plaintiff Christopher Goins has suffered and may suffer a loss of earnings, permanent disability, and impairment and or loss of earning capacity. 23. As a direct and proximate result of the aforesaid negligence, carelessness and recklessness of Defendant Flying J. Inc., Plaintiff Christopher Goins has undergone and in the future will undergo great physical pain, mental pain, discomfort, inconvenience, distress, embarrassment and humiliation, past and future loss of his ability to enjoy the pleasures oflife, and limitations in pursuit of daily activities, all to his great loss and detriment. 24. As a direct and proximate result of the aforesaid negligence, carelessness and recklessness of Defendant Flying J. Inc., Plaintiff Christopher Goins has sustained incidental Document #: 230063./ costs and losses to include, but not be limited to, past and future medication costs and medical appliances. WHEREFORE, Plaintiff Christopher Goins demands judgment in his favor and against Defendant Flying 1. Inc., for the aforesaid damages in an amount which exceeds the limits of compulsory arbitration in Cumberland County, Pennsylvania, plus interest and/or damages for delay and costs of prosecution. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By %~~ Attorney LD. No. 83894 3211 North Front Street P.O. Box 5300 Harrisburg, P A 17110-0300 (717) 238-8187 Dated: ~!2fIz,. Attorneys for Plaintiff Document #: 230063. J VERIFICATION I, Chistopher Goins, do hereby verify that the facts set forth in the foregoing Civil Complaint are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. CI..~~ ~'~.(I Christ her Goins Date: ~alo~ Document #: 230063.1 CHRISTOPHER GOINS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INe. and FLYING J TRAVEL PLAZA, Defendants : CIVIL ACTION - LAW : JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned as counsel on behalf ofthe Defendant, Flying J Inc., in the above-referenced matter. DATE: /tUG. 14. 2012-- BY: Respectfully submitted, MARSHALL, DENNEHEY, WARNER, COLE~ & GO GIN TIMOT J. I.D. No. 52918 4200 Crurns Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3505 Attorney for Defendant, Flying J Inc. CHRISTOPHER GOINS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants : CIVIL ACTION - LAW : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Joanne M. Parr, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby ~ certify that on this \'0 day of August, 2002, served a copy of the foregoing document via First Class United States mail, postage prepaid as follows: Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street PO Box 5300 Harrisburg, P A 17110-0300 ~. I&,~ Jo e . Parr o ~ -U(T n1r~ ~fE~ ciS >.: E~ (~, ~f5=':' J> ~;; :::1 -<. o f~.) -:0- c:: (.-") r) ~1-1 -n r= "n CI () --I', -,:D "j:C) :< rn , ) -:,,\ }J -< ,:;:. ;:':Jl- :1,: :..r'l <? SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-03672 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GOINS CHRISTOPHER VS FLYING J INC 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: FLYING J INC but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT & NOTICE On August 29th , 2002 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 29.25 .00 66.25 08/29/2002 METZGER WICKERSHAM ~o answe s: ~ _.----- ~> ::::: - R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this flU]; day of J~~ :2IJ1:iL A.D. ~. Q, 'fu./P,-"Jj.Z;' Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 2002-03672 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GOINS CHRISTOPHER VS FLYING J INC ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FLYING J TRAVEL PLAZA the DEFENDANT , at 1650:00 HOURS, on the 7th day of August 2002 at 1501 HARRISBURG PIKE CARLISLE, PA 17013 by handing to ROGER LOCKBAUM, ASST D MAN a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 3.45 .00 10.00 .00 19.45 .~~e<./~ R. Thomas Kline 08/29/2002 METZGER WICKERSHAM Sworn and Subscribed to before h' u.. d f me t lS II - ay 0 ~~ 2uo.z, A.D. Q~M/l.- C: ~ J;rii othonotary . B~ I-;::< 62 v/ f-t. /:1: Deputy Sheriff @ffitt of t4~ ~4~riff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (7l7) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania GOINS CHRISTOPHER vs County of Dauphin FLYING J INC Sheriff's Return No. 1916-T - -2002 OTHER COUNTY NO. 02-3672 AND NOW:August 12, 2002 at 8: OOAM served the within NOTICE & COMPLAINT upon FLYING J INC by personally handing to MONIQUE WEAVER, CSA 1 true attested copy (ies) of the original NOTICE & COMPLAINT and making known to him/her the contents thereof at C/O PRENTICE HALL 2704 COMMERCE DR., SUITE B HBG, PA 17110-0000 ,,)frduvn) (~-. of AUGUST, 2002 n. r f }(7i~'''1~) So Answers, JK~ Sworn and subscribed to before me this 15TH day PROTHONOTARY of Dauphin County, Pa. (;:~ By Deputy Sheriff Sheriff's Costs: $29.25 PO 08/07/2002 RCPT NO 167695 FRITZ hi The Court of Common Pleas of Cumberland County, Pennsylvania Christopher Goins VS. Flying J Inc. et al SERVE: Flying J Inc. No. 02 3672 civil Now, AUgust 6, 2002 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk ofthe Plaintiff. ../7...#, ~. ~~J<:/~ Sheriff of Cumberland County, PA Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to copy of the original a and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ \05 _A \LIAB\TJM\LLPG\1139181JMF\20614\OOI46 CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LA W JURY TFUAL DEMANDED DEFENDANT'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS FROM PLAINTIFF 1. Plaintiff instituted this action by filing a Complaint on July 31,2002 alleging therein that Plaintiff sustained certain damages as a result of a slip and fall incident at Defendant's place of business on August 1,2000. 2. Defendant filed its Answer in this action 011 August 13,2002 denying liability for Plaintiffs alleged accident. 3. Thereafter, Plaintiff was served Interrogatories and a Request for Production of Documents on August 14,2002. 4. Plaintiffs deposition had been noticed to take place in this action on November 19, 2002, but was postponed because Plaintiff has not answered Defendant's Interrogatories or Request for Production of Documents. 5. To date Defendant has not received Plaintiffs Answers to Interrogatories nor Responses to Defendant's Request for Production of Documents nor is there any agreement of counsel concerning any further enlargement of time for Plaintiff to answer this outstanding written discovery. 6. Accordingly, Defendant Flying J Inc. respectfully requests that this Honorable Court enter a Rule to Show Cause directing that Plaintiff show cause why Defendant's Motion to Compel Discovery should not be granted. DATE: rJAN \ J ~I 1fJJ?; Respectfully submitted, MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN ~t~ BY: TIM HY. LD. No. 52 8 4200 Cmms Mill Road, Suite B Harrisburg, P A 17112 (717) 651-3505 Attorney for Defendants o ~; ~n 2::1_, ?"r.- (/') ./' F5 11; (-:: ~,.~., ~;.~~ =-] -... c;, W r\.) ~: :'.J (~ ~) -< \05 J \LIAB\TJM\LLPG\113921 \JMF\20614\00146 CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INe. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED RULE TO SHOW CAUSE ".I AND NOW, this L::J, day of January, 2003, Plaintiff is directed to show cause within twenty (20) days why the Motion of Defendant to Compel Answers to Defendant's Interrogatories and Request for Production of Documents should not be granted. BY THE COURT: .Ad J. Jrr ..,clE- I ';1 ~ f. -~ ~, ViNVAt\St~N3d JJNno:) rl~ ;/"'l!38'NnJ I 8' ", . Z "',-, ,',^ 11' . ','t P, -., :'1' .11 . ;"", to , 11 ~ 1...; '..} AU"..' o'hUe CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : No.: 02-3672 FLYING J INe. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION -- LA W JURY TRIAL DEMANDED DEFENDANTS'. FLYING J INC. AND FLYING.J TRAVEL PLAZA. MOTION FOR SANCTIONS Defendants', Flying J, Inc. and Flying J. Travel Plaza, by and through their counsel, Marshall, Dennehey, Warner, Coleman & Goggin, hereby move this Honorable Court to enter an Order precluding Plaintiff from introducing any evidence against Defendants at the trial of this matter, and in support thereof states the following: 1. Plaintiff was served with Interrogatories and a Request for Production of Documents on August 14,2002. 2. Plaintiffs deposition had been noticed to take place on this action on November 19,2002, but was postponed because Plaintiff has not answered Defendants' Interrogatories or Request for Production of Documents. 3. Defendants filed a Motion to Compel Answers to Interrogatories and Responses to Request for Production of Documents on January 16, 2003. (A true and correct copy of Defendants' Motion to Compel Answers to Defendants' Interrogatories and Request for Production of Documents is attached hereto and marked as Exhibit "A"). 4. Attached to the Motion was a Rule to Show Causl;: why Defendants' Motion to Compel should not be granted. 5. On January 23,2003, after due consideration of Defendants' Motion to Compel, this Honorable Court entered an Order directing Plaintiff to show cause within twenty (20) days why the Motion of Defendants to Compel Answers to Defendants' Interrogatories and Request for Production of Documents should not be granted. (A true and correct copy of this Court's Order is attached hereto and marked as Exhibit "B"). 6. The twenty (20) day deadline within which Plaintiff was to show cause why Defendants' Motion to Compel should not be granted expired on February 11, 2003. 7. On or about January 27,2003, counsel for Defendants served upon Plaintiffs counsel, via certified mail, a copy of this Court's Order. The return receipt was returned and signed by "B. Moyer" on January 28,2003. (A true and correct copy of that correspondence is attached hereto and marked as Exhibit "C"). 8. The twenty (20) day deadline following receipt ofthis Court's Order expired on February 16, 2003. 9. Plaintiff did not provide a response or show cause why Defendants' Motion to Compel should not be granted. 10. As of the filing of this Motion, neither Plaintiff nor Plaintiffs counsel has produced the requested documents or responses. 11. Based upon the foregoing, Moving Defendants request this Court enter an Order precluding Plaintiff from introducing into evidence at a trial, any evidence whatsoever based upon the subject Interrogatories and Request for Production of Documents, pursuant to Pa. R.e.p. 4019 (c)(2). 2 WHEREFORE, Moving Defendants, Flying J, Inc. and Flying J. Travel Plaza, move this Court to enter an Order granting sanctions as requested above. Respectfully Submitted, MARSHAIJL, DENNEHEY, WARNER, COLEMAN & GOGGIN DATE: BY: ~~ TIN MURPHY, ESQUIRE I.D. N .81085 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3504 Attorneys for Defendants, Flying J, Inc. and Flying J. Travel Plaza \05 _A\LIAB'JRM\LLPG\ll8432\CYW\20614\OOI46 3 CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICI~ I, Cherri M. Whitson, an employee of Marshall, Dennehe:y, Warner, Coleman & Goggin, do hereby certify that on this 5R day of March, 2003, served a copy ofthe foregoing document via Certified Mail as follows: Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.e. 3211 North Front Street PO Box 5300 Harrisburg, P A 17110-0300 /i;L7n. Lo~ ~ Chern M. Whitson . . \05 _A \LIAB\TJM\LLPG\113918'JMF\20614\00146 CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INe. and FLYING J TRA VEL PLAZA, Defendants CIVIL ACnON - LAW c ,--- <..~.. JURY TRIAL DEMANDED S',::. ~'.) ! - ',~ ...:... ," DEFENDANT'S MOTION TO COMPEL ANSWERS TO INTERROGATniuES;; AND RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMEN.tS (oJ FROM PLAINTIFF 1. Plaintiff instituted this action by filing a Complaint on July 31, 2002 alleging therein that Plaintiff sustained certain damages as a result of a slip and fall incident at Defendant's place of business on August 1, 2000. 2. Defendant filed its Answer in this action on August 13,2002 denying liability for Plaintiffs alleged accident. 3. Thereafter, Plaintiff was served Interrogatorit::s and a Request for Production of Documents on August 14,2002. 4, Plaintiffs deposition had been noticed to take place in this action on November 19, 2002, but was postponed because Plaintiff has not answered Defendant's Interrogatories or Request for Production of Documents. 5. To date Defendant has not received Plaintiffs Answers to Interrogatories nor Responses to Defendant's Request for Production of Documents nor is there any agreement of counsel concerning any further enlargement of time for Plaintiff to answer this outstanding written discovery. 6. Accordingly, Defendant Flying J Inc. respectfully requests that this Honorable Court enter a Rule to Show Cause directing that Plaintiff show cause why Defendant's Motion to Compel Discovery should not be granted. DATE: tj)\JJ' 1 ~/ 1fJJ'5 BY: Respectfully submitted, MARSHAl,L, DENNEHEY, WARNER, COLEMAN & GOGGIN ~.. I.D. No. 52... 8 4200 Crums Mill Road, Suite B Harrisburg, P A 17112 (717) 651-3505 Attorney for Defendants CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INe. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LA W JURY TRIAL DEMANDED CERTIFICATE OF SERVICI~ I, Joanne M. Parr, an employee of Marshall, Dennehey, 'Varner, Coleman & Goggin, do hereby certify that on this \ ~ day of January, 2003, served a copy of the foregoing document via First Class United States mail, postage prepaid as follows: Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street PO Box 5300 Harrisburg, P A 17110-0300 ~~\\\.~ ~OaDneM. Parr JA\11 At 3 ~0n" ~ IV Luj \} \05 _A \LlAB\TJM\LLPG\113921IJMF\20614\00146 CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INe. and FLYING J TRA VEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED RULE TO SHOW CAUSE AND NOW, this .l'1.:A.. day of January, 2003, Plaintiff is directed to show cause within twenty (20) days why the Motion of Defendant to Compel Answers to Defendant's Interrogatories and Request for Production of Documents should not be granted. BY THE COURT: J5)1f.~ (2 .~ I / J. rnUE C<)&'~'l i;'nCH",:7 '''';'''~n'''' v:~,~;'1"r.t!" ,~,,1 '~;^~f~~'::'!:}:":::f ...... ... .: ...', .""","", h2'nd ~~"L~V,i::;~'~;;~ Prothonr.uri CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INe. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRV\L DEMANDED CERTIFICATE OF SERVICE I, Joanne M. Parr, an employee of Marshall, Dennehey,Wamer, Coleman & Goggin, do hereby certify that on this~ day of January, 2003, served a copy ofthe foregoing document via Certified Mail as follows: Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street PO Box 5300 Harrisburg, PA 17110-0300 l \~~ t\\ ,~~ ~anne M. Parr A I MARsHAll., DENNEHEY, WARNER, CoLEMAN &Go<~~') A P. 0 f E S S ION ALe 0 . P 0 RAT ION www.marshalldennehCl .s. Postal Service Eil{lFJED MAIL RECEIPT o!!le?ftc /lJ1laif Ohly: No Insurance Coverage ProvIded) Direct Dial: 717-651-3505 Email: tmcmahon@mdwcg.com IT' 17112 /TI ru J:[J Cl 0 Cl Cl Cl ~ IT' .-=I .-=I Cl 0 I"- Certified Fee 4200 Crums Mill Road, Suite B. Harrisburg, PA (717) 651-3500 . Fax (717) 651-9630 Return Receipt Fee (Er1 dorsement Required) RElSlricted Delivery Fee (&dommant Required) 1bfal Postage " Fees Here $ \\~'\ \tJ~ SlmtTo ~_~ :\ ~, s;,;;er.iPt~o~~- - -~~. . ~----------_..._. 01 j'O Box No_ ciij;;iiiSii,;Zii.;:;,------------..---.---------.--------. ;.1 .. .. .f January 27, 2003 Via Certified Mail Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street PO Box 5300 Harrisburg, P A 17110-0300 RE: Christopher Goins v, Flying J Inc. and Flying J Travel Plaza! CCP (Cumberland County) No.: 02-3672 Our File # 20614-00146.061 Dear Mr. Norfleet: Enclosed please find a Rule directed to Plaintiff to show cause within twenty (20) days as to why Defendant's Motion to Compel Answers to Defendant's Interrogatories and Request for Production of Documents should not be granted. Veryt~:' TIMO H J. - TJM/jrnp Enclosure \05 _A \L1AB\T1M\CORR\114882\JMru0614\OO 146 . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: SENDER: COMPLETE THIS SECTION ~~~ ~~\ C5t \\\~~ \~~~\\t\m ~~\\ ~ .~~~~. \>.~.~5~\::) \'\\\~-~ 7001 1940 0000 8239 x D. Is delivery add different from item 1? If YES, enter delivmy address below: ~t o Addressee DYes o No 3. Service Type R[ Certified Mail 0 E)<press Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) []581 DYes PS Form 3811 , March 2001 Domestic Return Receipt ~\~,-~\.~ 102595-0t -M- t 424 (') r; 'J'~'~ ~f;:: -~. c:: ):': ;;;--: >: :=1 -< ;"'--r ;:; o .-{"1 ..-. '-, :--.;] "" .:-3 - , ,I (~~~ '"-!"j ':-? .) ) '-11 ~~~...~ J~ -<.. i'v CHRISTOPHER GOINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. CIVIL ACTION - LAW FLYING J. INC. and FL YING J. TRAVEL PLAZA, NO. 02-3672 Defendants. JURY TRIAL DEMANDED PETITION OF PLAINTIFF'S COUNSEL FOR LEAVE TO WITHDRAW TO THE HONORABLE JUDGE OF SAID COURT: Plaintiff's counsel, Andrew W. Norfleet, Esquire and the Law Firm of Metzger, Wickersham Knauss & Erb, P.C., petition this Court for leave to withdraw as counsel for Plaintiff and in support thereof represents as follows: 1. On July 31, 2002, undersigned counsel filed a Complaint on behalf of Plaintiff, Christopher Goins. 2. At said time, Plaintiff was residing at 5316 Dogwood Road, Baltimore, Maryland. 3. At a later date and unknown to undersigned cOlillsel, Plaintiff moved from the Baltimore address. 4. Undersigned counsel has received mail returned from Mr. Goins previous address and no forwarding address has been provided. Mr. Goins did not file a forwarding address with the United States Postal Service. Document #; 260840.1 5. The telephone number assigned to Mr. Goins has been disconnected and undersigned counsel is unable to reach Mr. Goins and cannot provide Answers to Discovery requested by defense counsel and cannot produce Mr. Goins for deposition. 6. Mr. Goins has not made any attempt to contact undersigned counsel for more than three months. WHEREFORE, Andrew W. Norfleet and METZGER, WICKERSHAM, KNAUSS & ERB, P.C., request this Honorable Court dismiss them as counsel of record in this matter Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. -. )- '/ Date: 3/12/03 -t.__~~ . /~, Andr w W. Nor et Supreme Court .D. No. 83894 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 (717)238-8187 Attorneys for Defendant Document #: 260840.1 VERIFICATION I, Andrew W. Norfleet, Esquire, do hereby verify that the facts set forth in the foregoing Petition of Plaintiff s Counsel for Leave to Withdraw are true and correct to the best of my personal knowledge or 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: March 12,2003 Andrew Document#:26084~1 CERTIFICATE OF SERVICE I, Andrew W. Norfleet, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I have this 12th day of March 2003, served a true and exact copy of the herein Petition of Plaintiffs Counsel for Leave to Withdraw with reference to the foregoing action by first-class postage prepaid, on the following: Justin E. Murphy, Esquire Marshall, Dennehey, Warner, Colleman & Goggin 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 Mr. Christopher Goins 5316 Dogwood Road Baltimore, MD 21207 ~.'~~ Andre W. Norfleet" . . Document #: 260840.1 -rr t', [~:; ~~- .) "r,'..., _" ;'~2~ 1__ r_,r~ . , ~. c:; :i~ ( ~.~ ""- --/ -< C) ~.~ j..,) 'J} (..0 '.._,J ., ?E -< CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. . 02-3672 CIVIL FL YING J INC. and FL YlNG J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED IN RE: DEFENDANTS' MOTION TO MAKE RULE ABSOLUTE ORDER IcJ# AND NOW, this 7 day of March, 2003, the motion of the defendants to make rule absolute is granted and the plaintiff is directed to respond to all outstanding discovery in this case within thirty (30) days of service hereof. BY THE COURT, Andrew W. Norfleet, Esquire 5 For the Plaintiff ,4-- Justin E. Murphy, Esquire F or the Defendants C.Or' '"-r mat '&.L ~ ..1/11/03 :r1m ViNVA'l)Si\!I'f3d 'L'I(','~'''' .,," ,", "'r~:'f!"iO J\ i\j jI,.).,_ J i: L.'~.' \1 I 8 I :t~ J :.;:' 3 CHRISTOPHER GOINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. CIVIL ACTION - LA W FLYING J. INC. and FL YING J. TRAVEL PLAZA, NO. 02-3672 Defendants. JURY TRIAL DEMANDED RULE TO SHOW CAUSE NOW, this /1" day of March, 2003, upon consideration of the within Petition of Plaintiffs Counsel for Leave to Withdraw, a Rule is entered upon Christopher Goins to show cause, if any he has, why the relief requested ~md said Motion should not be granted. Rule returnable Z 0 days after service. BY THE COURT: cc: Andrew W. Norfleet, Esquire - Counse for Defendant Justin E. Murphy, Esquire Prothonotary //4 J. ~ ~ 3, /9,0.3 ~. Document #: 260840.1 V\t\I\fl\lASi\lN3cl I I ~'l.n.. r-.',r'\ rl. ,,".r,.r::;r,c.:!^Jn'" /\..1...1' t ..,' ,,' , ':~; 'ill V 81 :Uj ~, I '.~ / i CHRISTOPHER GOINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL ACTION - LAW v. FLYING J. INC. and FLYING J. TRAVEL PLAZA, NO. 02-3672 Defendants. JURY TRIAL DEMANDED PETITION OF PLAINTIFF'S COUNSEL FOR LEAVE TO WITHDRAW TO THE HONORABLE JUDGE OF SAID COURT: Plaintiffs counsel, Andrew W. Norfleet, Esquire and the Law Firm of Metzger, Wickersham Knauss & Erb, P.C., petition this Court for leave to withdraw as counsel for Plaintiff and in support thereof represents as follows: 1. On July 31, 2002, undersigned counsel filed a Complaint on behalf of Plaintiff, Christopher Goins. 2. At said time, Plaintiff was residing at 5316 Dogwood Road, Baltimore, Maryland. 3. At a later date and unknown to undersigned cOlIDsel, Plaintiff moved from the Baltimore address. 4. Undersigned counsel has received mail returned from Mr. Goins previous address and no forwarding address has been provided. Mr. Goins did not file a forwarding address with the United States Postal Service. Document #: 260840.1 \05_ A \LIAB\TJM\LLPG\1 02259\JMF\15000\50000 CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LA W : JURY TRIAL DEMANDED PLAINTIFF'S RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS ADDRESSED TO PLAINTIFF PLEASE TAKE NOTICE that you are hereby requested to produce for inspection and other purposes, including copying, pursuant to the Pennsylvania Rules of Civil Procedure, at the office of the counsel for the requesting party, or at such other location as may be mutually agreeable between counsel for you and counsel for the requesting party, not less than thirty (30) days after service of these requests, documents herein cited. The word "document" or "documents" as herein used includes but is not limited to photographs, video tapes, drawings, reports, statements and memoranda, as well as all other documents as defined in the Rules. 1. All documents in your possession, control or custody constituting, relating to, or pertaining to the documents identified in response to Defendant's Interrogatories. 2. All medical bills, reports, records, and x-rays, relating to the injury allegedly sustained in the occurrence described in the Complaint, as well as all medical bills, records, and reports relating to prior or subsequent injuries to the same parts of the body claimed by PlaintifIto have been injured in the occurrence described in the Complaint. 3. All employee reports, records, tax. returns from 1996 to the present, attendance records, and wage statements relating to the claim of loss of income as a result of the occurrence described in Plaintiffs Complaint. 4. Copies of all statements, memoranda, summaries of other writings, documents, diagrams and pictures obtained from your investigation, your insurance company's investigation, or your attorney's investigation into the incident involved. (You need not supply any attorney's "work product" or other material which is specifically accepted as privileged by the above Rules). 5. All documents in your possession, custody or control prepared in anticipation of litigation or trial of this case, except those documents which disclose the mental impressions of your attorney or your attorney's conclusions, opinions, memoranda, notes or summaries, legal research or legal theories, and except those documents prepared in anticipation of litigation by your representatives to the extent that they would disclose the representatives' mental impression, conclusions or opinions respecting the value or merit of the claim or defense. 6. To the extent that you have not already provided the same in response to previous requests herein, all statements obtained from any witnesses or memoranda of conversations with witnesses or recordings of witnesses' statements memoranda, or recordings made by parties to this lawsuit or their representative. 7. To the extent not already provided in response to previous requests herein, all statements made by any party to this action, including written statements signed or otherwise adopted or approved by the person making it or stenographic, mechanical, electrical, or other recording or transcription thereof, which is a substantially verbatim recital of an oral statement and contemporaneously recorded, as allowed by Pennsylvania Rules of Civil Procedure No. 4003.4. 8. To the extent that you have not already provided the same, copies of all records, documents and memoranda, which have any bearing upon the matters alleged against the requesting party or upon the responsibility of the requesting party for the matters alleged against the requesting party. 9. To the extent not already provided, all reports ofthose experts who are to be called by you as witnesses at trial, which reports made or secured by you in connection with your investigation of the matters relating to this lawsuit. 10. To the extent not already provided, copies of all expert.s' reports made or secured by you in connection with your investigation of the matters relating to this lawsuit. 11. To the extent not already provided, all photographs, diagrams, maps, surveys, plans and models of the site of the incident in question that are in your possession. 12. To the extent not already provided, all documents containing the names and addresses of witnesses or potential witnesses with the exception of material described above, specifically correspondence privileged by the above rules. 13. To the extent not already provided, copies of all exhibits which you intend to offer into evidence at the trial of this matter. 14. The shoes or other footwear, as applicable, which you were wearing on August 1,2000 at approximately 2:00 am. DATE: AuCs. Ii, 200 'L Respectfully submitted, MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: &k .~ TIM?~~ON. ESQUIRE J.D. No. 52918 4200 Crums Mill Road, Suite B Harrisburg, P A 17112 (717) 651-3505 Attorney for Defendant. Flying J Inc. 1. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 2. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 3. Requested documents not available at this time. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 4. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 5. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 6. None available. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 7. None available. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 8. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 9. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 10. None available at this time. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 11. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 12. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Ru1es of Civil Procedure. 13. None available at this time. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 14. Unknown at this time. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 280095-1 Carlisle Hcspltal -- Emergency Department 24~ Parker St. Carlisle, PA 17013 -- (717) 245-5500 ... goins. christopher 8/1/00 2:46am 843798 DISPOSITION SUMMARY Patient: qoins. christopher SS#: CURRENT Address: City: Current Ph: Age/DOB: _ Medical Record: 843798 Zip: Arrival: 8/1/00 2:46am Disch: 8/1/00 6:47am Disposition: MD ED: A.J. Guarracino. DO PMD: Res/PAlNP: PMD Ph: Dx #1: Laceration (Unspecified Site) ICD-9 #1: 870-897? #1 Dx Engl: LACERATS.ESW Dx #2: Closed Iniurv Head. Unspecified Consciousness State ICD-9 #2: 854.00 #2 Dx Engl: HEADINJ.ESW Dx #3: Cervical Strain ICD-9 #3: 847.0 #3 Dx Engl: SPNECK.ESW Med Inst: Ibuprofen . Med #1 Engl: IBUPROFE.EDP Rx #1: Ibuprofen 400 mq 1 tablet by mouth everv 4 to 6 hours as needed.with food #30 tablets #1 Dx Span: LACERATS.SSW #2 Dx Span: HEADINJ.SSW #3 Dx Span: SPNECK.SSW mmmmm Follow-up: YOUR FAMILY DOCTOR FlU MD Ph: FlU DfT: 4 Days Other Instr: seek medical attention immediatelY if sians of wound infection or concussion as described in printed instructions. keep wound clean and apply bacitracin ointment daily for 5 days. staples out in 7-10 days. May return to work/school: 8/3/00 MY SIGNATURE BELOW INDICATES: > I have received and understood the oral instructions regarding my current medical problem. > I will arrange follow-up care as instructed above. J > I acknowledge receipt of the written instructions as outlined on this and \.. t A ~\. ~'C any previous page(s). I will read and review these instructio~s~ uJ.- -\-t.. -y,;::> I.Y"" ~ J X X~ ~~ Patient (or Legal Guardian) Signature Staff (Witness) Signature ~ Carlisle Hospital and ~, Health Services,. CONSENT Tp HOSPITAL ADMISSION AND ~E~TREATMENT Time: (AM) (PM) ame of Pent care, ,which may include routine diagnostic procedures and such medical treatment as the named attending physician (s) or other of the hospital's medical staff consider to be necessary. 2. I understand that the practice of medicine and surgery is not an exact science and that diagnosis and treatment may involve risks of injury, or even death. I acknowledge that no guarantees have been made to me as to the result of examination or treatment during this hospitalization. 3. I understand that: (A) It is customary, absent emergency or extraordinary circumstances, that no substantial procedures are perfonned upon a patient unless and until he or she has had an opportunity to discuss them with the physician or other health professional to the patient's satisfaction; (B) Each patient has the right to consent, or to refuse consent, to any proposed procedure or therapeutic course; and (C) No patient will be involved in any research or experimental procedure without his or her full knOwledge and consent. 4. I understand that many of the physicians on the staff of this hospttal, including the attending physician(s) named al-ove, are not employees or agents of the hospital but, rather, are independent contractors who have been granted the privilege of using its facilities for the care and treatment of their patients. Further, I realize that among those who attend patients at this hospital are medical, nursing, and other health care personnel in training who, unless requested otherwise, may be present during patient care as a part of their education. Still or motion pictures and closed circuit television monitoring of patient care also may be used for educational purposes or for documentation of the clinical course unless a patient expressly requests otherwise. 5. I release CARLISLE HOSPITAL from all responsibility for all arti^!es which I am retaining or will have with me during my stay at the hospital. I understand this includes clothing, bridgework. ~alse teeth, eyeglasses, jewelry, money, radio, razor or any other item kept in my possession. I understand I may deposit valuables in a safe provided by the hospital; only if this is done will the hospital assume any responsibility for the safekeeping, 6. I hereby acknowledge that I have received written information on the topics of Patient Rights and Advance Directives. J5 ~ J <Stl Date of Signature: V II < I acting on behalf o~ ~~eof Authorized Representative , ~9'~ from a condition requiring hospital care, hereby consent to rendering of such (SIGNATURE OF PATIENT) (SIGNATURE OF WITTNESS) (If patient is unable to consent or is a minor, compete the following): Patient (i years of age) (is unable to consent because): ~~~'~SifZOFwrrN~ ' AD 0315 (10/91) PATIENT IDENTIFICATION NAME: (~hr;.sh)0her bOil1..5 I IvIEDICALRECORD#: gQ379y ? // / ()O I I DATE: %/00 DATE OF SERVICE: 1. FOLLOW UP ISSUE: ;;. X'r~_ h'/106~-J 2. ACITON: ! t -!Is \, i -C f--!-cr ~t ~ f It ; IU. b.et.u. . L~ r kL 6')..{ Li.l'/tp-!7;r..bCJa.fnf I J '-\:'~-~ 3. PATIENT NOTIFICATION: 1. Time/Date: 2. Time/Date: 3. Time/Date: 4. PRIMARY CARE PHYSICIAN NOTllflliD: 0 Yes 0 No Time/Date: 5. SIGNATURES: Physician :John Coy Ie Time/Date: Nurse: Time/Date: ~ Carlisle Hospital EMERGENCY DEPARTMENT FOLLOW-UP FORM PATIENT IDENTIFICATION ER 0630 (9/98) C!trl!;-bpAtr. Go. M;: /fl-/;20!70 }y. ~Ie... 8Lf37f8 ~tJ , ? -'~ PATIENT IDENTIFICATION NAlvfE: t.+-I,-:J,:;~-ro {'I-€.~ 6~-:::-N~ DATE: ~I,~ I MEDICAL RECORD #: ~4 3 -=r Cj 3" DATE OF SERVICE: '?J I 1. FOLLOW UP ISSUE: ~p~ #rL ~,.~ ~~ .b ~-e=----cJ_..~ ;P~ ~.~ ....6 /1~~-,-6 ~-'9- ~ - ./,~ -"..,~. ~ ~.....- - o. ~ pi' ~ d-4:(:?' 2. ACTION: ~ L-~ /' 3. PATIENT NOTIFICATION: 1. TimeIDate: J-/ / S tP ~rr7 2. TimeIDate: 3. Time/Date: 4. PRIMARY CARE PHYSICIAN NOTIFIED: DYes ~No Time/Date: 5.srGNAT~ Physic' e~ Nurse: Time/Date: o/t 5~ Time/Date: ~ Carlisle Hospital EMERGENCY DEPARTMENT FOLLOW-UP FORM PATIENT IDENTIFICATION ER 0630 (9/98) ~ Carlisle Hospital DEPARTMENT OF RADIOLOGY and Health Services 246 Parker Street. P.O. Box 310. Carlisle, Pennsylvania 17013..0310. (717) 249-1212 CARLISLE IMAGING ASSOCIATES, P.C. GOINS, CHRISTOPHER 5316 DOGWOOD ROAD BALTIMORE, MD 21207 29Y 08/01/2000 X-HAY #150959 MED. REC. #843798 DR, GUARRACINO, ANTHONY CERVICAL SPINE This study is slightly limited by the patient's condition. No subluxation or fracture seen, Soft tlssue prominence in the nasal pharynx is probably due to adenoid tlssue. IMPRESSION: Negative cervical splne. The study is mildly limited. CHEST There is prominence of the pulmonary arterial segment of the mediastinal silhouette. This is more prominent than is usually seen. It raises the possibility of enlargement of the main pulmonary artery, as could occur with valvular disease. This does not have the configuration of an enlarged aorta and there is no upper mediastinal widening to suggest hemorrhage. The lungs and costophrenic angles are clear with acute disease. There is a small nodule projecting in the left mid lung field with the diameter of approximately 6 mm in a young patient. This would presumably represent a scar. The visualized bones are grossly intact. IMPRESSIONS: Abnormally prominent pulmonary arterial segment of the cardiac silhouette to suggest further evaluation. tv' DAVID R. kOYAL. M.D. I DRB/bks D: 08/01 2000 - 10:17 am T: 08/02 2000 - 03:34 pm RADIOLOGY FILE Carlisle Hospital -- Emergency Department 246 Parker St. Carlisle, PA 17013 -- (717) 245-5500 c Patient: Qoins, christopher MD ED: A.J. Guarracino, DO Res/PAlNP: AFTERCARE INSTRUCTIONS We are pleased to have been able to provide you with emergency care. Please review these instructions when you return home in order to better understand your diagnosis and the necessary further treatment and precautions related to your condition. Your diagnoses/prescriptions today are: Disch: 8/1/00 6:47am Medical Record: 843798 Dx #1: Laceration (Unspecified Site) Dx #2: Closed Iniury Head. Unspecified Consciousness State Dx #3: Cervical Strain Med Instr #1: Ibuprofen Rx #1: Ibuprofen 1 tablet bv mouth every 4 to 6 hours as needed,with food Disp: #30 tablets 400 mQ e Refill: ~ General Information on LACERATIONS (CUTS) The word "laceration" is the medical term for an accidental cut in the skin. Lacerations often result from auto accidents, falls or contact with broken glass or other sharp objects. Although some lacerations are very large, most are only one to two inches long and can be easily repaired in the emergency department. Treatment usually consists of: 1. a shot of numbing medication to deaden the area around the wound, 2. opening up the wound and cleaning it with lots of water and 3. stitching the wound back together with special thread. Stitching the wound usually results in less scarring and quicker healing. What are the risks? Most lacerations heal in about two weeks and do not produce any serious medical problems. There are, however, some risks: 1. When the skin is disrupted by a laceration, germs sometimes get into the wound and start to grow and multiply, producing an infection. These wound infections occur in roughly 1 % to 3% of all lacerations and can result in serious problems. 2. Most lacerations do leave some form of a permanent scar, although it may not be very noticeable. Many scars gradually improve for the first 6 to 12 months after the initial injury. 3. Deep lacerations sometimes go into the blood vessels, tendons, nerves or bone. This can be serious. INSTRUCTIONS 1) Keep the wound CLEAN and dry. Cover it with a plastic bag when bathing. 2) If the bandage gets dirty or wet, change it right away. Otherwise, you should change the bandage once a day, starting the second day after the injury. To change the bandage you should: A) remove the old bandage, B) gently wash the area with soap and water, C) if you are not allergic to it, using a Q-tip, gently apply a thin layer of antibiotic ointment and D) put on a fresh bandage. 3) Most lacerations are not painful once they have been cleaned, stitched and bandaged. Pain medications are not usually necessary. 4) Tetanus shots are good for 5 to 10 years, provided you have had all your childhood immunizations ("baby shots"). 5) SEEK IMMEDIATE MEDICAL ATTENTION if: A) you develop a fever, persistent bleeding, vomiting or B) the wound gets warm, red, swollen or tender or C) you develop red streaks on the skin near the wound or D) you notice a creamy liquid (pus) draining from the wound. 6) Be extra careful if you have a very large laceration, an animal bite, a small puncture wound or a human bite wound. These types of injuries tend to get infected more often. 7) Have the stitches removed in days by a nurse or doctor. c Pg2 General Information on HEAD INJURIES The term "head injury" refers to any injury that results from being hit on the head. Typically, there are cuts, scrapes or bruises on the face or scalp and often there is a mild headache that gets better over one to two days. More serious head injuries can also shake the brain, resulting in a momentary loss of consciousness, confusion or amnesia. This is called a concussion. Often head injuries result from motor vehicle accidents, falls or fights. What are the risks? Most minor head injuries (including mild concussions) get better over several days and do not produce any serious medical problems. There are, however, some risks: 1. If there are any cuts or scrapes, they may become infected. 2. Sometimes there is serious damage to the face, eyes, ears, jaw or teeth. 3. A serious head injury can injure the brain, resulting in permanent brain damage or even death. A serious head injury usually produces warning signs right away. On rare occasions, however, the WARNING SIGNS MAY NOT APPEAR FOR SEVERAL HOURS OR EVEN DAYS. For this reason it is important to seek immediate medical attention if any of these warning signs appear: 1. UNCONSCIOUSNESS (passing out, blacking out). 2. Unusual drowsiness. 3. Confusion. 4. A severe headache. 5. Vomiting. 6. Blurred vision. 7. Convulsions (seizures, fits). 8. A stiff neck. 9. Areas of numbness, tingling or weakness. 10. Stumbling or loss of balance. 11. Unequal size of the left and right pupils. 12. In children ALSO look for a decreased activity, trouble walking, poor feeding or fussiness. INSTRUCTIONS 1) If you are not allergic to them, you may take acetaminophen (Tylenol) or ibuprofen (Advil) to help ease the pain. Stronger medicines are not usually required. 2) SEEK IMMEDIATE MEDICAL ATTENTION if you develop any of the warning signs listed above. 3) Unless instructed otherwise, FOR THE NEXT 24 HOURS, you should: A) stay with a friend or family member who has read this sheet and B) have someone check you every 3 to 4 hours to make sure you have not developed any of the warning signs listed above. At night they should wake you up about every 4 hours. 9 General Information on a SPRAINED NECK (Mild) The neck is formed by seven bones that are stacked on top of each other and held together by strong bands called ligaments. Any forceful bending or twisting of the neck may damage these ligaments, resulting in a "sprained neck". This is the most common cause of everyday neck pain. Neck sprains often result from auto accidents, sleeping in the wrong position, a poor posture, constant sneezing or a blow to the head or neck. Sometimes the exact cause of the neck sprain can not be determined. What are the symptoms? A sprained neck usually produces an aching or cramping pain in the back of the neck. Movement of the head usually makes this pain worse. What are the risks? Most people with a sprained neck gradually get better over several days and do not develop any serious medical problems. There are, however, some risks: 1. Some people get episodes of neck pain over and over again. This is less likely to occur if proper care is taken. 2. Exams, tests and X-rays are not 100% reliable. Although unlikely, it is always possible that the neck pain may actually be the result of another more serious medical problem such as a broken bone or an infection. This is very uncommon, but it does occur. Pg 3 INSTRUCTIONS 1) The best thing to help reduce the pain is to avoid any activity that puts stress on your neck. Avoid leaning over, lifting, coughing or any rapid movements of the head. Laying in bed will relax the neck even more. 2) Ice packs are sometimes helpful during the first two days. Put the ice in a plastic bag. Roll up the bag in a towel and put it on your neck for 5 to 15 minutes at a time. 3) After the first two days, warm packs may help ease the pain and speed healing. Roll up a small towel. Soak it in warm water and put it on your neck for 5 to 15 minutes at a time. 4) Maintain a good posture; this puts less stress on your neck. 5) No medicine will relieve the pain completely, but aspirin, ibuprofen (Advil) or acetaminophen (Tylenol) may help. WARNING: Do not take these drugs if you are allergic to them. Do not take these drugs if you are already taking a prescription pain medication. DON'T GIVE ASPIRIN TO ANYONE LESS THAN 18 YEARS OLD. 6) Call your doctor if the pain does not get better within a week. 7) SEEK IMMEDIATE MEDICAL ATTENTION if you develop severe neck pain, numbness, tingling or pass out. D Drug Information on IBUPROFEN BRAND AND GENERIC NAMES - Advil, Medipren, Mido1200, Motrin, Nuprin, Pamprin IB, Rufen, Trendar. DOSAGE & USAGE INFORMATION Habit forming? No Prescription needed? Yes, for some brands at higher strength Available as generic? Yes Drug class: Anti-inflammatory (non-steroid) * Treatment for joint pain, stiffness, inflammation and swelling of arthritis and gout. * Pain reliever. * Treatment for dysmenorrhea (painful or difficult menstruation). * Treats juvenile rheumatoid arthritis. How to take: Tablet or capsule - Swallow with liquid or food to lessen stomach irritation. If you can't swallow whole, crumble tablet and take with liquid or food. When to take: At the same times each day. If you forget a dose: Take as soon as you remember up to 2 hours late. If more than 2 hours, wait for next scheduled dose (don't double this dose). What drug does: Reduces tissue concentration of prostaglandins (hormones which produce inflammation and pain). Time lapse before drug works: Begins in 4 to 24 hours. May require 3 weeks regular use for maximum benefit. Don't take with: See Interaction column and consult doctor. WARNINGS & PRECAUTIONS Don't take if: * You are allergic to aspirin or any non-steroid, anti-inflammatory drug. * You have gastritis, peptic ulcer, enteritis, ileitis, ulcerative colitis, asthma, heart failure, high blood pressure or bleeding problems. * Patient is younger than 15. Before you start, consult your doctor: * If you are taking aspirin, beta-blockers (high blood pressure/other), blood thinner, carteolol, cortisone drugs (steroid drugs), lithium, methotrexate, minoxidil, oxyphenbutazone, phenylbutazone, probenecid, sotalol, terazosin, thyroid hormones, water pills or any drug used to treat high blood pressure. * If you have epilepsy. * If you have Parkinson's disease. * If you have been mentally ill. * If you have had kidney disease or impaired kidney function. Over age 60: Adverse reactions and side effects may be more frequent and severe than in younger persons. Pregnancy: Studies inconclusive on harm to unborn child. Decide with your doctor whether drug benefits justify risk to unborn child. Breast-feeding: May harm child. Avoid. Infants & children: Not recommended for anyone younger than 15. Use only under medical supervision. Prolonged use: * Eye damage. * Reduced hearing. * Sore throat, fever. * Weight gain. Skin & sunlight: Possible increased sensitivity to sunlight. Driving, piloting or hazardous work: Don't drive or pilot aircraft until you learn how medicine affects you. Don't work around dangerous machinery. Don't climb ladders or work in high places. Danger increases if you drink alcohol or take medicine affecting alertness and reflexes, such as antihistamines, tranquilizers, sedatives, pain medicine, narcotics and mind altering drugs. Discontinuing: Don't discontinue without consulting doctor. Dose may require gradual reduction if you have taken drug for a long time. Doses of other drugs may also require adjustment. POSSIBLE INTERACTION WITH OTHER SUBSTANCES (Combined Effect) * Alcohol: Possible stomach ulcer or bleeding. Pg4 B Follow-up: YOUR FAMILY DOCTOR F/U MD Ph: F/U OfT: 4 Davs Other Instr: seek medical attention immediatelv if sians of wound infection or concussion as described in printed instructions. keep wound clean and applv bacitracin ointment dailv for 5 days. staples out in 7-10 days. May return to work/school: 8/3/00 EKGs and X-Rays: If you had an EKG or X-Ray today, it will be formally reviewed by a specialist tomorrow. If there is any change from today's Emergency Department reading, you will be notified. IMPORTANT NOTICE TO ALL PATIENTS: The examination and treatment you have received in our Emergency Department have been rendered on an emergency basis only and will not substitute for definitive and ongoing evaluation and medical care. A follow-up physician has been designated for you. It is essential that you make arrangements for follow-up care with that physician as instructed. Report any new or remaining problems at that time, because it is impossible to recognize and treat all elements of injury or disease in a single Emergency Department visit. Significant changes or worsening in your condition may require more immediate attention. The Emergency Department is always open and available if this becomes necessary. (C) 1996 Wellsoft Corp, Price/Stern/Sloan THIS IS THE LAST PAGE . ~) Carlisle Hospital 246 Parker Street. Carlisle. PA 17013-0310 . 717-245-5500 REG. DATElTIME Of' LOCATION OF PATIENT MED. REC. NO, 843798 08/01/00 03:29 PREVIOUS NAME NONE NAME I ADDRESS / PHONE I AGE / SEX / RACE I M.S. GOINS, CHRISTOPHER 5316 DOGWOOD RD INSURANCE COMMENT REASON FOR VISIT D t \ MD (410)944-7247 S. 29V M W S 12/20/70 000-00-0000 (410)944-7247 / PATIENT I OTHER EMPLOYER GUARANTOR'S EMPLOYER 000-00-0000 21207 EMERGENCY NOTIFY REEN, NANCV (410)944-7247 9 FELL ON SLIPPERY FLOOR HIT BACK OF HEAD COMMENT PT TRAVELING THRU AREA BRIEF VISIT 26700 CLASS I VISIT 26710 CLASS II VISIT 26720 CLASS III VISIT 26730 CLASS IV VISIT 26740 CLASS V VISIT 26750 MINOR SUTURE EDS 01 MEDIUM SUTURE EDS 02 MAJOR SUTURE EDS 03 INTUBATION EDS 04 IV SET UP EDS 06 PELVIC EXAM EDS14 NITRO SET-UP EDS16 I ! CAST, SCOTCH SHORT ARM 26031 ! CAST, SCOTCH LONG ARM 26032 ! CAST, SCOTCH SHORT LEG 26033 CAST, SCOTCH LONG LEG 26034 CAST ROLL, PLASTER 26075 BIP MONITOR 26037 PACER PADS 79064 GASTROIHEMO SLIDE 26060 KIDDE TOURNIQUET 26048 OCL PER FOOT 79670 F.S.B.S. 80081 TUBE GAUZE PER FOOT 26074 ED STAT ESTAT PULSE OX POXED EXTENDED CHARGE I 26760 EXTENDED CHARGE /I 26770 ,'--- -- ------ --- ----------', I I I I I I I I I I I I I I \ I '------------------------------, ,- --------- ----...., I I I I I I I I I I I I I I \ I '------------------------------, ."..---- ------- - I I I I I I I I \ .....- -- ----- -- --------------....., I I I I I I I I ---------------, ~ 1974005 PRE. CERT. NO UARRACINO, ANTHONV J -----, , I I I I I I I --" ISOLATION ALERT N ADDITIONAL CHARGES I I I I I I I I \ ,-------- ------ A <1'13.<i ,-- -- --- -----, : 1'1.3. () : I I : 't~., : l 'l4'J.D ; .....------- -~ (-----'f~~l),-- \ ! ~<115 ! : ECZ",q. (. : I I \ I ,-------------------~ ,'-------- --- ------, I \ I I I I I I I I I I I I \ I ,-------------------~ , ---------, I \ I I I I I I I I I I I I \ I ,-------------------~ .,..-.------- , , I I I I I I \ '-.--- - -------, \ I I I I I I ./ ,""--- ---------, I \ I I I I I I I : I I' I j \ , ,-------------------- ,""- --- I I I I I I I \ ,---------------- ,~{){)tl (j{".SCf ------, \ I I I I I I j --_/ ~.,..--- I I I I I I I \ '-- ~---- I I I I I I I \ ,------------- -- -- --- -- -, \ I I I I I I j -------------, -----, \ I I I I I I I ------, ,---------- - ---, I \ I I I I I I I I I : I I \,-------------------_/ ,---- I I I I I I I \ ,------- ---, \ I I I I I I , ---_/ ER-0508 (REV. 6/99) ~ Carlisle Hospital A Service of Carlisle Hospital and Health Services August 8, 2000 fl./37;12 Christopher Goins 5316 Dogwood Road Baltimore, MD 21207 Dear Mr. Goins, Please have your primary care physician contact us regarding your xray results from August 1,2000. The number he or she should call is 717-245-5500. Johnson Coyle, M.D. Emergency Department Physician Carlisle Hospital JGClkmd 246 Parker Street. P.O. Box 310. Carlisle, PA 17013-0310. 717.249.1212 CARLISLE GOODWILL FIRE PO BOX 207 ALLENTOWN, PA 18105 IF PAYING BY MASTERCARD, DISCOVER OR VISA, FILL OUT BELOW. CHECK CARD USING FOR PA YMENT . !~STERCARD _0 CIC ~A DISCOVER CARD NUMBER I'~~ SIGNATURE EXP. DATE Account Number Inv.Date Balance Due Amt Remitted 0002927 08/14/00 $290.00 Pt. Name: GOINS, CHRISTOPHER ADDRESS SERVICE REQUESTED PAGE NO. 1 1..1.1...11..1.111...1...1.1.1.1.1..11.....11....11.11...1..11 GOINS, CHRISTOPHER 5316 DOGWOOD RD BALTIMORE, MD 21207 1...111..1....1111....1.1.11.....1.111...1...111...1...11.1..1 CARLISLE GOODWILL FIRE PO BOX 207 ALLENTOWN, PA 18105 02478862 B616 Please detach and return the top portion of this STATEMENT with your payment in the enclosed enveloped. Retain the bottom portion for your records. 203-Aur Origin: FLYING JAYS Destination: Carlisle Hospital Subtotal Amount Paid 290.00 0.00 IMPORTANT MESSAGE II Balance Due $290.00 I Please complete the reverse side by providing us with your insurance information and signature. Return this information using the enclosed envelope. Make Checks Payable To: CARLISLE GOODWILL FIRE PLEASE SEE REVERSE SIDE FOR IMPORTANT INSTRUCTIONS. IMPORTANT MESSAGE FROM YOUR PHYSICIAN This bill covers only the professional fee; you may also receive a separate hospital bill Questions? 800-666-2455 Call Monday-Friday between the hours of 9:30 AM - NOON AND 1:00 - 5:00 PM EST If insurance information or other information on this form is incorrect, please correct on back of return stub. DR. GUARRAC / ER EXAM-4 DR. GUARRAC / WOUND REPAIR SERVICE AT CARLISLE HaSP-HEALTH SVC . . . . . CAR00001974005 ** PAY THIS AMOUNT ** 481 IMPORTANT: TO ASSURE PROPER CREDIT. DETACH AND RETURN THE STATEMENT BELOW WITH YOUR CHECK OR MONEY ORDER PAYABLE IN US CUR Chal~tONE, Inc. P.O. Box 1438 San Jose CA 95109-1438 (800) 299-8694 INVOICE Invoice No. 101928195210 Dear Valued Requester: MR :It 21-74-'67 Date: 01/22/2001 Per your request, enclosed are the medical records forwarded from st Agnes. Hospital, Baltimore, MD. PAYMENT IS DUE UPON RECEIPT OF THIS INVOICE. A service charge of 1.5% per month (annual rate 18%), except Michigan state, will be charged if not pa within 30 days from the date of this invoice. Please detach the bottom portion of this invoice and return with your remittance to ChartONE, Inc. to ensure proper credit. Please note we accept VISA and MASTERCARD paymer If paying by credit card, please complete the necessary information below Please make check payable to: ChartONE, I nc. P.O. Box 1438 San Jose, CA 95109-1438 ( 800) 299-8694 (Federal Tax ID:It: 94-3360691) REGiUESTED BY: MICHAEL KORANDA TOMASKO & KORANDA 219 STATE STREET HARRISBURG, PA 17101 (717)238-1100- Patient /~TOPHR GO~ categor~ SSN: 212-02-9910 DOB: / / DOA : / / Req'r ID: Other ID: Paper Pages: 32 Micro Pages: 0 Comp Pages: 0 Clerical Fee: Basic Fee: Page Fee: Shipping: Handling: Itemized: Tax: Adjustment: Pre-Payment: Total Due: $ Ship to: 17.08 0.00 18.24 1.60 0.00 0.00 0.00 0.00 ~ \ T: k-- r J - '/30101 Please return this portion with your payment payable to: P.O. Box 1438 ChartONE, Inc. San Jose CA 95109-1438 (800) 299-8694 INVOICE Invoice No. 106124103102 Dear Valued Requester: MR # 84-37-98 Date: 12/06/2000 Per your request, enclosed are the medical records forwarded from CARLISLE HOSPITAL, CARLISLE, PA. PAYMENT IS DUE UPON RECEIPT OF THIS INVOISEi.Aservice charge of 1.5% per month (annual rate 18%), except Michig,3.nstp.te, will be charged if not paid within 30 days from the date oft:.his invoicei/Please detach the bottom portion of this invoice and return with your remittance to ChartONE, Inc. to ensure proper credit. Please note we accept VISA and MASTERCARD payments. If paying by credit card, please complete the necessary information below. REQUESTED BY: MICHAEL KORANDA TOMASKO & KORANDA Please make check payable to: 218 STATE ST ChartONE,lnc. P.Ori Box 1438 Sa1;J,Jose, CA 95109-1438 (80<;)) 299-8694 (FeoeralTax ID#: 94-3360691) HARRISBURG, PA 17101 (717 )238-1100- FILE Total Due: $ 15.39 0.00 12.36 0.77 O~..OO 0.00 .71 0.00 0.00 ,//...--..----... e~ 'I ~'I k- P J. I LJ I L/OO Patient: '. Category: ,SSN: DOB: i OA: eq'r 10: ther 10: 3 aper Pages: .cro Pages: mp Pages: CHRISTOPHE GOINS A 212-02-9910 / / / / Clerical Fee: Basic Fee: Page Fee: Shipping: Handling: i d 12 o o Pre-Payment: to: ~DD~92DDDDD~DhE{hEDDDL6h696h2~DD{6 lI::IffilO A.llNOW 1I0 :lIO'ilHO 'lID0A. NO lffiawnN .LNflOOOV 'lID0A. !llIlL'il. aSV::I'Id ::IAoav SS!flIoav OL 'IIVW ONV OL ::Iiav A. Vd }I;)'ilHO!DlVW ::ISV::Iid ONITllH ::IONVllflSNI 1I0.il ::IOIS ::ISlI::IA!flI mlS SS!flIoav A\llN .ill !flI'iIH :lIO'ilHO 0 09ZEt HO snawn~o~ SZ06-~ .:LdSa I SS~IARSS A~HSORSHS 3ROHI.:L~a 11111111111111111111111I1111111111111111111111111111 LOZIZ aM 3ROHI.:L~a <Ill aOOMOOa 91E S; SHIOO RSHdO.:LSIRHa OSOtEUE 1'010['"::1 .anowy OO"S9Z 011([ ,_oury 6S9L-LtZZE ~~ ~~IAHOSX~Y~ 6S9Lt xoa "O"d SS~IARSS A~HSORSHS 3ROHI.:L~a 06t9-S9Z-00S :01. SNOI1.S:mb 9NI'I'II8 .LJ"ICI OSOt E I t E lI::1awnN .LNflOOOV SHIOO RSHdO.:LSIRH~ !lWYNLN::IUVd OO/tl/Zl IO/tO/IO !llVO LNlD'i!llVLS 'll1.va'll!la .-..-.-................-..-..................--..-........--....---................----...........--------------------.........--.-----... .........-...---.............-...---...-....-...--....................................--- AONlllnJt) sn HI lI'1llV A V d 'IlI<IlIO AlNOPIIllO )I::>iIH::> lIIlOA H.LIJt.IA01111l.LNlIPlllI.LVJ.S 1IH.L Nl IWIlI aNY H::>V.LlIa 'lIan::> 1I11dOlld lllIOSSV OJ. :J.NVlllOdPIII OO"S9Z . .:LNnOHY SIH.:L AYd .. OSOtEUE . . "AY SSY~d I SSIMRSII.:LO "SdO~SJ BS asso .:LHSHS.:LY.:LS SIH.:L 40 SaIS ~:SlI:iIA:iIlI SSY~d ISS~IARSS ~~]aSH SS HYlIOORd ANY HI S.:LYdI~IJ,Wd RO AYd Rn HI .:LI aNY Yd ~~I I :ilAYH A aHSS nn.:L3R ~dHO~ H~IHM nOA ~I ...... .LS3: w OO:~ 00:8JO smoq :nll u:l~Mlaq V!'!-Id- UPUOW Ifll3 l.SUO!JS:l mq (l!l!dsoq :llarnd:lS 1! M!:Y.l:lJ osfll AIlW nOA ~:l:lJ (1!ue '!ss:lJo.Id Qtp A(UO SJ:)^O:) mq S!'lL NVI:>(SAHcl81l0A WOO ~3YS~iU\I .LNY.IlIOcIWI ~atlent ACCOUnting ::;ervlceS PO Box 100 101 Noble Blvd Ste 104 Carlisle PA 170130100 onS37-00 I 01 I 11/09/00 SORRY, WE DO PlOT ACCEPT CREDIT CARDS FOR PAYMENT ADDRESS SERVICE REQUESTED ~ . ~STERCARD ~-~ 8A D OTHER PAY THIS AMOUNT $ 91.00 $ MAIL PAYMENT TO: CARLISLE IMAGING ASSO PO Box 100 101 Noble Blvd Ste 104 Carlisle PA 17013 0100 I.. .111...111......11..11..1..1...1111...1.1..11......11..11.1 ADDRESSEE: Christopher S Goins 5316 Dogwood Rd BALTIMORE MD 21207-5903 1..1.1...11..1.111...1...1.1.1.1.1..11.....11... .11.11...1..11 o Please check box if above addressee is incorrect or insurance information has changed, and indicate change(s) on reverse side. 1- - I. . STATEMENT OF ACCOUNT PLEASE DETACH AND RETURN TOP PORTION WITH YOUR PAYMEN . - -. . - . OS/01/00drr Christoph OS/01/00drr Christoph OS/01/00drr Christoph 71020 72050 72020 Chest, 2 View Front & L 959.1 Spine, Cerv, Minimum Of 953.9 Radiologic Exam Spine 1 953.9 24.00 43.00 24.00 24.00 43.00 24.00 MAKE CHECKS PAYABLE TO: CARLISLE IMAGING ASSO PROVIDER!. '. PRACTICE NAME Pat1ent Account1ng Serv1ces 071837-00 FOR BILLING INQUIRIES, CALL 717-249-24S2 DATE OF LAST 30E/30E/30E INSUIIANCE PAYMENT PBlDlNO PAYMENT DUE DATE 11/09/00 STATEMENT DATE 0.00 0.00 0.00 CURRENT OVER 3D Dl\YS OVER liD Dl\YS OVER ID Dl\YS OVER 120 Dl\YS TRANSACTIONS AFTER THE CLOSING DATE WILL APPEAR ON YOUR NEXT STATEMENT 91. 00 PLEASE PAY THIS AMOUNT CARLISLE HOSPITAL 246 PARKER STREET CARLISLE PA 17013 PAllENT NAME Return Service Requested (EB rVlU j (II N !!! CHRISTOPHER S GOINS PATIENT NUMBER 1974005 CURRENT BALANCE 750.00 AGREEMENT AMOUNT .00 DISCHARGE I SERVICE DATE 08/01100 BILLING DATE 09/07/00 PAYMENT DUE DATE 09/28/00 CREDIT CARD PAYMENT INFORMATION CARD TYPE I EXP.DATE ACCOUNT NUMBER CARD HOLDER SIGNA11JRE PLEASE PAY THIS ArU~ CARLISLE HOSPITAL 246 PARKER STREET CARLISLE, PA 170130310 CHRISTOPHER S GOINS 5316 DOGWOOD RD BALTIMORE MD 21207 1",111",111"""11"11",11,,11,,,,,111..1.,1. .1,11. .11..,1 1974005 3 60 o 1,.1,1."11"1,111,.,1,,.1,1,1,1,1,,11,..,,11.,,,11.11",1,,11 o o o CK ~ c w o :; ffi Ii) a: o ~ c Cl z ti ~ ~ It a: ~ ::; ~ <( ( c 08/01/00 08/01/00 08/01100 08/01/00 08/01/00 08/01/00 08/01/00 08/01/00 SPINE CERVICAL ROUTINE MIN 4 VIEWS CHEST ROUTINE 2V LIDOCAINE lY. /EPI INJECT. 20ML IBUPROFEN TABLET 400M6 BACITRACIN TOPICAL OINT. 146M SPINE ONE VIEW SPECIFY AREA OXIMETRY MEASUREMENT CLASS IV VISIT EMERGENCY DEPT. 1 1 1 2 1 1 1 1 229.00 127.00 8.00 4.00 4.00 101.00 71. 00 206.00 GOINS ;:~ ~RGES PAYMENTSI OTtER ADJUSTMENTS .00 750.00 .00 You may reach Patient Financial Services ~~~~ 08/01/00 CURRENT ACCOUNT BALANCE 750.00 09/28/00 750.00 RETAIN THIS PORTION at 717=218-8820 8:00 AM unitl 4:00 PM Monda thru Friday .00 AGREEMENT AMOUNT PAYMENTS RECEIVED AFTER BILLING DATE WILL APPEAR ON NEXT STATEMENT IMPORTANT MESSAGE FROM YOUR PHYSICIAN This bill covers only the professional fee; you may also receive a separate hospital bill Questions1 800-666-2455 Call Monday-Friday between the hours of 9:30 AM - NOON AND 1:00 - 5:00 PM EST If insurance information or other information on this form is incorrect, please correct on back of return stub. DR. GUARRAC / ER EXAM-4 DR. GUARRAC / WOUND REPAIR SERVICE AT CARLISLE HOSP-HEALTH SVC . . . . . CAR00001974005 "* PAY THIS AMOUNT "* 481 .' -lMPORTANT: TO ASSURE PROPEReREOlT. DETACH AND RETURN THE STATEMENT BELOW WITH YOUR CHECK OR MONEY ORDER PAYABLE IN us CURAi DIRECT BILLING QUESTIONS TO: 800-666-2455 RWC CORPORATION PO BOX 828340 PHILADELPHIA, PA 19182-8340 DUE DATE 11/02/00 PATIE}ITNAME CHRISTOPHER GOINS ACCOUNTNUMBER CAROOOO 1974005 Amouiit Due $481 . 00 Amount Enclosed STATEMENT DATE 10/12/00 . 'I...II~I.....! 11..1...1.11..1.. .11..1..111....1..111...11...1 CHRISTOPHER GOINS 5316 DOGWOOD RD BALTIMORE, MD 21207 RWC CORPORATION PO BOX 828340 PHILADELPHIA,'PA 19182-8340 o CHECK HERE IF NEW ADDRESS SEE REVERSE SIDE FOR INSURANCE BIlliNG PLEASE MAKE CHECK PAYABLE TO AND MAIL TO ADDRESS ABOVE PLEASE WRITE YOUR ACCOUNT NUMBER ON YOUR CHe:PK OR MONEY ORDER 91919 ~10 3*9.,~.tJOO 19! 4 00 5 O_OpO 4 81 00 i -. ... '.".'." . I ~~,~:2;~':~~';c~~i.~~!$~'x"J ...... - -. .~~;.:::~~~~V_~,~..~lo~."""'"...,;';rt...~~.A._~~ '- .~ '___"~-,- ....~.-:-_. '_":"_'~~. ",c'-_ . ":--....- -~...-f: '_~"~'-".~-:- ~~-~.~~;:<_~~_., ,:,' . -:'..~...; , ". '... '~.<". -'''~~ --,-' --. -, - '. .. - - ",... . . . . '.J ~- -<~. . c. ..-~,__~. _..;",.' ~-~'_-,',<~::".~,,::~-: .,'. " ..- .'-_.'"",'-.~---...'>.._-" . ..., :'~-- .s~~~=-.,:.,~~~~~~~11iff.~:?m~#1 ,; >, 1 EYE EXAM REPORT A. EXAM SUMMARY 1. VISUAL ACUITY AIDED R. 20 / -z,.,o L. 20 / --z..-J 2. GLAUCOMA CHECK NORMAL 3. MUSCLE BALANCE 4. RETINAL HEALTH 5. CORNEAL HEALTH 6. PUPILLARY REFlEXES 7. OTHER OTHER NO~ W w ty- B. DIAC}N6SIS Et'MYOPIA (NEARSIGHTEDNESS) o Ij)'.f't:ROPIA (FARSIGHTEDNESS) G-"ASTIGMA TISM (CORNEAL IRREGULARITY) C. PATIENT EYE HEALTH PLAN: - "~~"'''.'''.'''''<-''''''.,' DATE: -1J / 7-0/ (J 0 PATIENT: C-~ g C V !.1:!f" UNAIDED R. 20 / (tJ 0 L. 20/1?rv B;ONO PROBLEM o o o o o o o PRESBYOPIA (R~~E~~CnoN) o OTHER o OTHER D. DOCTOR'S RECOMMENDATIONS: Spectagll!S:/ ~Iycarbonate _ Progressives ~alf eye / near only _ S Ity lens _ mt Coating _ Ultraviolet _ Anti-Reflective _ Warranty _ Emergency Pair _ Safety Contacts: _ Daily Wear __ Flexible Wear __ Torics __ Colors __ Disposables _ Gas penneable _ Sight Plus __ Emergency Pair __ Care Kit Sunglasses: _ Prescription _ Piano (non-prescription) _ Occupational Other: E. FOLLOW-UP RECOMMENDATIONS:u ______ NEXT ExAM: 06 MOS. 01 YEAR 018 MOS. ~RS ~ REASON FOR NEXT EXAM: OP. 88 COOE.82085 1095 PATIENT COpy 1t~ =oR OP< ~~,~_~: "-~;~.~~~~~~~ ::~-:~":c " ,,-; ~,-..,~~ -;p ..~,'~_.. ~~W;ii:~~~i,::;j~~~~.~~~~~::::~:: ';.':~~~~1;:;:;~~~:~~';-~~:(~~:~ ~l~~~~:"'>".>~::~>-~~~n-~--'_' - . ..- ._'_:'_ ___~-. ~~~~~~~~~c~,:;rt~~~,~i:i~~~$~:-~~:t:-~~ or-~c.'.-=~::'-:-.o:.:~"";:__:_,,_-,,,'-".."~ -. . . ,.,~~,~-~~~:-"",:,~- .. ---'-, - '~..", iilmi~[~~~;;~~~iiar"'~''e.;&....~~'''<~7<iv"''xC.. _"'.".__.....-_._.,., -..._:._-~~. ..-'~.-'- \..._.-,-"..,r'.(."':><>o:..,-<........ .... /, ~ _~;~~ic:Oi,-zi;zf?~~~~J"-:Y'~. . . . VF.RTFTCA TTON The undersigned hereby certifies that he is the attorney for Christopher Goins and that the facts in the foregoing Plaintiff s Response to Request for Production of Documents Addressed to Plaintiff are true and correct to the best of his knowledge, information and belief, and that said matters relating to Plaintiff s Response to Request for Production of Documents Addressed to Plaintiff are as known to the undersigned as to the client, Brian W. Shields, said knowledge being based upon information contained in the file in this matter, and further states that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. ~ vJ.11iA~ Andrew W. Norfleet, Esquire Date: May 9, 2003 280781-1 (") c '..' r,- " r ( 5:~ r' --) -'...., (.. ; ,~_., r) 1 , I \05 _A \LIAB\TJM\LLPG\ 1 02257\JMF\15000\50000 CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INe. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW : JURY TRIAL DEMANDED PLAINTIFF~S ANSWERS TO INTERROGATORIES OF DEFENDANT. FLYING J INC.. ADDRESSED TO PLAINTIFF Definitions. -- The following definitions are applicable to these standard interrogatories: "Document" means any written, printed, typed, or other graphic matter of any kind or nature, however produced or reproduced, including photographs, microfilms, phonographs, video and audio tapes, punch cards, magnetic tapes, discs, data cells, drums, and other data compilations from which information can be obtained. "Identify" or "Identity" means when used in reference to -- (1) A natural person, his or her: (a) Full name; and (b) Present or last known residence and employment address (including street name and number, city or town, and state or county); (2) A document: (a) Its description (e.g., letter, memorandum, report, etc.), title, and date; (b) Its subject matter; (c) Its author's identity; (d) Its addressee's identity; , , (e) Its present location; and (f) Its custodian's identity; (3) An oral communication: (a) Its date; (b) The place where it occurred; (c) Its substance; (d) The identity of the person who made the communication; (e) The identity of each person to whom such communication was made; and (f) The identity of each person who was present when such communication was made; (4) A corporate entity: ( a) Its full corporate name; (b) Its date and place of incorporation, ifknown; and ( c) Its present address and telephone number; (5) Any other context: A description with sufficient particularity that the thing may thereafter be specified and recognized, including relevant dates and places, and the identification of relevant people. entities, and documents. "Incident" means the occurrence that forms the basis of a cause of action or claim for relief set forth in the complaint or similar pleading. "Person" means a natural person, partnership, association, corporation, or governmental agency. Standard Instructions. -- The following instructions are applicable to these standard interrogatories: (1) Duty to answer. -- The interrogatories are to be answered in writing, verified, and served upon the undersigned within 30 days of their service on you. Objections must be signed by the attorney making them. In your answers, you must furnish such information as is available to you, your employees, representatives, agents, and attorney. Your answers must be supplemented and amended as required by the Pennsylvania Rules of Civil Procedure. (2) Claim of privilege. -- With respect to any claim of privilege or immunity from discovery, you must identify the privilege or immunity asserted and provide sufficient information to substantiate the claim. (3) Option to produce documents. -- In lieu of identifying documents in response to these interrogatories, you may provide copies of such documents with appropriate references to the corresponding interrogatories. 1. General. 101. Personal information. -- State: (a) Your full name; (b) Each other name, if any, which you have used or by which you have been known; (c) The name of your spouse at the time of the accident and the date and place of your marriage to such spouse; (d) The address of your present residence and the address of each other residence which you have had during the past five years; ( e) Your present occupation and the name and address of your employer; (f) Date of your birth; (g) Your Social Security number; (h) Your military service and positions held, if any; and (i) The schools you have attended and the degrees or certificates awarded, if any. 102. Insurance. -- If you are covered by any type of insurance, including any excess or umbrella insurance, that might be applicable to the incident in this matter, state the following with respect to each such policy: (a) The name of the insurance carrier which issued the policy; (b) The named insured under each policy and the policy number of each policy; (c) The type(s) and effective date(s) of each policy; (d) The amount of coverage provided for injury to each person, for each occurrence, and in the aggregate for each policy; and (e) Each exclusion, if any, in the policy which is applicable to any claim thereunder and any reasons, if any, why you or the carrier claim the exclusion is applicable. 103. Expenses. -- List and describe all expenses and losses that you have incurred because of the incident. 104. Factual basis for claims and defenses. -- State with particularity the factual basis for each claim or defense you are asserting in this case. 105. Witnesses. -- (a) Identify each person who (1) Was a witness to the incident through sight or hearing and/or (2) Has knowledge of facts concerning the happening of the incident or conditions or circumstances at the scene ofthe incident prior to, at the time of, or after the incident. (b) With respect to each person so identified, state that person's exact location and activity at the time of the incident. 106. Statements. -- If you know of anyone that has given any statement (as defined by the Rules of Civil Procedure) concerning this action or its subject matter, state: (a) The identity of such person; (b) When, where, by whom, and to whom each statement was made, and whether it was reduced to writing or otherwise recorded; and (c) The identity of any person who has custody of any such statement that was reduced to writing or otherwise recorded. 107. Reports of incident. -- Identify the documents (except reports of experts subject to Pa.R.C.P. No. 4003.5) which describe the incident or the cause thereof. 108. Demonstrative evidence. -- If you know of the existence of any photographs, motion pictures, video recordings, maps, diagrams, or models relevant to the incident, state: (a) The nature or type of such item; (b) The date when such item was made; (c) The identity ofthe person that prepared or made each item; and (d) The subject that each item represents or portrays. 109. Trial preparation material. -- If you, or someone not an expert subject to Pa.R.C.P. No. 4003.5, conducted any investigations of the incident, identify: (a) Each person, and the employer of each person, who conducted any investigation(s); and (b) All notes, reports or other documents prepared during or as a result of the investigation(s) and the persons who have custody thereof. 110. Trial witnesses. -- Identify each person you intend to call as a non-expert witness at the trial of this case, and for each person identified state your relationship with the witness and the substance of the facts to which the witness is expected to testify. 111. Expert witnesses. -- Identify each expert you intend to call as a witness at the trial of this matter, and for each expert state: (a) The subject matter about which the expert is expected to testify; and (b) The substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion. (You may file as your answer to this interrogatory the report of the expert or have the interrogatory answered by our expert.) 112. Trial exhibits. -- Identify all exhibits that you intend to use at the trial of this matter and state whether they will be used during the liability or damages portions of the trial. 113. Books, magazines, etc. -- If you intend to use any book, magazine, or other such writing at trial state: (a) The name of the writing; (b) The author of the writing; (c) The publisher ofthe writing; (d) The date of publication of the writing; and (e) The identity of the custodian of the writing. 114. Admissions. -- If you intend to use any admission( s) of a party at trial, identify such admission(s). 2. Personal injury. 201. Injuries and diseases alleged. -- Identify all injuries or diseases that you allege you suffered as a result of the incident. 202. Prior or subsequent injuries or diseases. -- If, either prior to or subsequent to the incident, you suffered any injury or disease in those portions of the body claimed by you to have been affected by the incident, state: (a) The injury or disease you suffered; (b) The date and place of any accident, if such injury or disease was caused by an accident; (c) The identity of hospitals, doctors, or practitioners who rendered treatment or examination because of such injury or disease; and (d) The identity of anyone against whom a claim was made, and the tribunal and docket number of any claim or lawsuit that was filed in connection with such injury or disease. 203. Medical treatment. -- If you received medical treatment or examination (including x-rays) because of injury or disease you suffered as a result of the incident, state: (a) The identity of each hospital at which you were treated or examined; (b) The date on which each such treatment or examination at a hospital was rendered, and the charge by the hospital for each; (c) The identity of each doctor or practitioner by whom you were treated or examined; (d) The date on which each such treatment or examination by a doctor or practitioner was rendered, and the charge for each; and (e) The identity of any document(s) (except reports of experts subject to Pa.R.C.P. 4003.5) regarding any medical treatment or examination, setting forth the author and date of such document(s). 204. Earnings before the incident. -- For the period of three years immediately preceding the date of the incident, state: (a) The name and address of each of your employers or, if you were self- employed during any portion of that period, each of your business addresses and the name of the business while self-employed; (b) The dates of commencement and termination of each of your periods of employment or self-employment; (c) The nature of your occupation in each employment or self-employment; and (d) The wage, salary, or rate of earnings received by your in each employment or self-employment, and the amount of income from employment and self- employment for each year. 205. Earnings after the incident. -- If you have engaged in one or more gainful occupations subsequent to the date of the incident, state: (a) The name and address of each of your employers or, if you were self- employed at anytime subsequent to the incident, each of your business addresses and the name of the business while self-employed; (b) The dates of commencement and termination of each of your periods of employment or self-employment; (c) The nature of your occupation in each employment or self-employment; (d) The wage, salary, or rate of earnings received by you in each employment or self-employment, and the amount of income from employment and self- employment for each year; and (e) The date(s) of any absence(s) from your occupation resulting from any injury or disease suffered in this incident and the amount of any earnings or other benefits lost by you because of such absence(s). 206. Limitation of duties and activities after the incident. -- If, as a result of this incident, you have been unable to perform any of your customary occupational duties or social or other activities in the same manner as prior to the incident, state with particularity: (a) The duties and/or activities you have been unable to perform; (b) The periods of time you have been unable to perform; and (c) The identity of all persons having knowledge thereof. 207. Substance impairment. -- If you consumed any alcoholic beverage, sedative, tranquilizer, marijuana, cocaine, hashish, or other drug, medicine or pill during the eight hours immediately preceding the incident, state: (a) The nature, amount, and type of item consumed; (b) The amount of time over which consumed; (c) The identity of any and all persons who have any knowledge as to the consumption of those items; and (d) The identity of the physician or medical practitioner or other person who gave, purchased or prescribed any of said items, if any. 208. With respect to the allegations set forth in Plaintiffs Complaint at Paragraph 5, to wit that on August 1,2000 at approximately 2:00 a.m. Plaintiff was proceeding to the restroom of the restaurant at Flying J Travel Plaza, state when Plaintiff first arrived on August 1, 2000 at the Flying J Restaurant, by whom Plaintiff was accompanied, if anyone at that time, and the route of travel and/or path of travel from the point that Plaintiff began to proceed to the restroom up until the point where Plaintiff fell as alleged. 209. State whether Plaintiff was carrying anything in either or both of his hands at the time of the slip and fall incident alleged in his Complaint at Paragraph 5. 210. State whether Plaintiff observed one or more "wet floor" warning signs or any other warning signs in the vicinity of the area where Plaintiff alleges at Paragraph 5 in his Complaint that he had fallen on August 1,2000 at approximately 2:00 a.m. 211. State whether Plaintiff had ever before August 1,2000 patronized the Flying J Restaurant located at 1501 Harrisburg Pike, Carlisle, Pennsylvania and ifso identify all dates on which Plaintiff had previously patronized this restaurant facility. Respectfully submitted, MARSHALL, DENNEHEY, WARNER, COL & OG DATE: AtJ~. '+, Z(JJ?.. BY: T 1.0. No. 5291 4200 Crums Mill Road, Suite B Harrisburg, P A 17112 (717) 651-3505 Attorney for Defendant, Flying J Inc. 101. (a) Christopher S. Goins (b) None that counsel is aware of. (c) Unknown at this time. (d) 5316 Dogwood Road Baltimore, Maryland 21207 (e) unknown at this time (t) unknown at this time (g) 212-02-9910 (h) none. (i) No degrees awarded. l02. Undersigned counsel is not aware of any available insurance coverage. 103. Medical expenses of$I,870.15 104. Plaintiff fell on a wet floor that was not properly identified so as to avoid said danger. 105. (a) Christopher Goins (I) Vicitm; witnesses by experience (2) Has knowledge of the facts (b) Robin Smith (I) Eyewitness to accident (2) Has knowledge of facts of the accident ( c) Rhonda Scott (1) Witness to the accident (2) Has knowledge of the facts of the accident 105 (b). (I) Robin Smith: was sitting at Plaintiff's table and witnessed the fall. (2) Rhonda Scott: was sitting at Plaintiffs table and witnessed the fall. 106. Undersigned believes that Plaintiff gave a recorded statement to Defendant's insurance carner. 107. Undersigned is not in possession of any such reports. 108. Undersigned believes that photos were provided by previous counsel to Defendant's . . Insurance carner. 109. No investigation conducted at this time. 110. Witnesses identified in response to answer to #105. 280094-1 111. None at this time. Plaintiff shall supplement these answers pursuant to the Rules of Civil Procedure should they become available. 112. None at this time. Plaintiff shall supplement these answers pursuant to the Rules of Civil Procedure should they become available. 113. None at this time. Plaintiff shall supplement these answers pursuant to the Rules of Civil Procedure should they become available. 114. None at this time. Plaintiff shall supplement these answers pursuant to the Rules of Civil Procedure should they become available. 201. Plaintiff suffered open head injuries that required staples to close. Plaintiff also experienced headaches and blurred vision. To the best of counsel's knowledge, Plaintiff continues to receive medical care. 202. No prior injuries. 203. (a) Carlisle Hospital (b) 8/1/00 (c) Dr. Guarrac (d) 8/1/00 (e) Provided (a) Dr. Blumsom (b) 11/20/00 (c) Dr. Blumson, OD (d) 11/20/00 (e) Provided (a) Carlisle Imaging Assoc. (b) 8/1/00 (c) Unknowm (d) 8/1/00 (e) Provided 204. Undersigned will supply this information to counsel when available. 205. See response to request #204. 206. See response to request #204. 207. Unknown. It is the belief of undersigned counsel that Plaintiff had not consumed alcohol or other substances. 280094-1 208. Plaintiff was accompanied by the witnesses identified in response to request #105. Undersigned will supplement this answer pursuant to the Pennsylvania Rules of Civil Procedure when additional information is available. 209. Plaintiff was not carrying any objects. 210. Plaintiff did not observed any "wet floor" signs. 211. Plaintiff had not been patron of the Flying J prior to the night in question. 280094-1 VF,RIFICATION The undersigned hereby certifies that he is the attorney for Christopher Goins and that the facts in the foregoing Plaintiff's Answers to Interrogatories of Defendant Flying J, Inc. are true and correct to the best of his knowledge, information and belief, and that said matters relating to Plaintiff's Answers to Interrogatories of Defendant Flying J, Inc. are as known to the undersigned as to the client, Christopher Goins, said knowledge being based upon information contained in the file in this matter, and further states that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. ~w<~. Andrew W. Norfleet, Esquire Date: May 9, 2003 280781-1 ,.' ~- l ~'l ~. -::- ~~: / :r::-,:- ~;" ( .<C. <.) C -::~ ,..-...." I -n c.', .~ -1 ;'J ~ ::j (.-) r-n '.Jl UJ -=! , CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. : No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION- LAW JURY TRIAL DEMANDED DEFENDANTS', FLYINGJ INC. AND FLYING J TRAVEL PLAZA, MOTION FOR SANCTIONS Defendants', Flying J, Inc. and Flying J. Travel Plaza, by and through their counsel, Marshall, Dennehey, Warner, Coleman & Goggin, hereby move this Honorable Court to enter an Order precluding Plaintiff from introducing any evidence against Defendants at the trial of this matter, and in support thereof states the following: 1. Plaintiff was served with Interrogatories and a Request for Production of Documents on August 14,2002. 2. Plaintiff's deposition had been noticed to take place on this action on November 19,2002, but was postponed because Plaintiff has not answered Defendants' Interrogatories or Request for Production of Documents. 3. Defendants filed a Motion to Compel Answers to Interrogatories and Responses to Request for Production of Documents on January 16, 2003. (A true and correct copy of Defendants' Motion to Compel Answers to Defendants' Interrogatories and Request for Production of Documents is attached hereto and marked as Exhibit "A"). 4. Attached to the Motion was a Rule to Show Cause why Defendants' Motion to Compel should not be granted. 5. On January 23,2003, after due consideration of Defendants' Motion to Compel, this Honorable Court entered an Order directing Plaintiff to show cause within twenty (20) days why the Motion of Defend ants to Compel Answers to Defendants' Interrogatories and Request for Production of Documents should not be granted. (A true and correct copy of this Court's Order is attached hereto and marked as Exhibit "B"). 6. The twenty (20) day deadline within which Plaintiff was to show cause why Defendants' Motion to Compel should not be granted expired on February 11, 2003. 7. On or about January 27,2003, counsel for Defendants served upon Plaintiffs counsel, via certified mail, a copy ofthis Court's Order. The return receipt was returned and signed by "B. Moyer" on January 28,2003. (A true and correct copy of that correspondence is attached hereto and marked as Exhibit "C"). 8. The twenty (20) day deadline following receipt ofthis Court's Order expired on February 16, 2003. 9. Plaintiff did not provide a response or show cause why Defendants' Motion to Compel should not be granted. 10. On March 19, 2003, the Honorable Kevin A. Hess issued a Rule to Show Cause within twenty (20) days why Plaintiffs counsel's Petition for Leave to Withdrawal should not be granted. (A true and correct copy of the Rule to Show Cause and the Petition for Leave to Withdrawal are attached as Exhibit "D"). 2 11. Plaintiffs counsel's petition was predicated upon the fact that Plaintiff moved, changed his telephone number, and made no attempts to contact his attorney for more than three months. 12. As ofthe filing ofthe present Motion, there has been no response of Plaintiff to the Rule to Show Cause why the Petition of Plaintiffs counsel for Leave to Withdrawal should not be granted. 13. By Order dated March 14,2003, the Honorable Kevin A. Hess granted Defendants' Motion to Make Rule Absolute and directed Plaintiff to respond to all outstanding discovery within thirty (30) days of service of the Order. (A true and correct copy ofthe Order granting Defendants' Motion to Make Rule Absolute is attached hereto as Exhibit "E"). 14. Just prior to the expiration of the time limit to respond to Judge Hess' Order of 3/4/03, Plaintiff's counsel provided unverified responses to Defendant's discovery requests. Defendant has requested Plaintiff's counsel to provide verifications for the discovery responses. (See, Exhibit "F"). 15. As of the date of the filing ofthe present Motion, Defendants have not received proper, verified discovery from the Plaintiff in response to the M.arch 14,2003 Order of the Honorable Kevin A. Hess. 16. Based upon the foregoing Moving Defendants request this Court enter an Order precluding Plaintiff from introducing into evidence at trial, any evidence whatsoever based upon the subject Interrogatories and Request for Production of Docum(mts, pursuant to Pa. R.C.P. 4019 (c)(2). 3 17. Moving Defendants have served a copy of the pff:sent Motion to Plaintiff at his last known address of5316 Dogwood Road, Baltimore, Maryland 21207 by first class, postage pre-paid mail, in addition to serving Andrew W. Norfleet, Esquire. WHEREFORE, Moving Defendants, Flying J, Inc. and Flying J. Travel Plaza, move this Court to enter an Order granting sanctions as requested above. Respectfully Submitted, MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN JUSTIN M LD.NO.8 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3504 DATE: l,.~~ BY: Attorneys for Defendants, Flying J, Inc. and Flying J. Travel Plaza \05 _A \LIABIJRMILLPG\118432\CYW\20614\OO 146 4 VERIFICATION I, Justin E. Murphy, Esquire, Attorney for Defendants, Flying J, Inc. and Flying J Travel Plaza, verifies that the facts set forth in the Motion for Sanctions are true to the best of his knowledge, information and belief. If the above statements are not true, the deponent is subject to the penalties of 18 Pa.C.S. g4904 relating to unsworn falsification to authorities. JUSTINE~ DATE: 105_ A ILIAB\JRMILLPGl1232891CYWI20614100146 I05_A ILIABITJMILLPGII13918\JMFI20614100146 CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW n '.' C_-:. ~..~. _c~ - -. ....,." L." :'>-._) U: __c.__ r'':'; ',_ .- ~.''''' (', -"- DEFENDANT'S MOTION TO COMPEL ANSWERS TO INTERROGATOluES;. AND RESPONSES TO REOUEST FOR PRODUCTION OF DOCUMENTs (D FROM PLAINTIFF 1. Plaintiff instituted this action by filing a Complaint on July 31, 2002 alleging therein that Plaintiff sustained certain damages as a result of a slip and fall incident at Defendant's place of business on August 1,2000. 2. Defendant filed its Answer in this action on August 13, 2002 denying liability for Plaintiffs alleged accident. 3. Thereafter, Plaintiff was served Interrogatories ;md a Request for Production of Documents on August 14,2002. 4. Plaintiffs deposition had been noticed to take place in this action on November 19, 2002, but was postponed because Plaintiff has not answered Defendant's Interrogatories or Request for Production of Documents. 5. To date Defendant has not received Plaintiffs Answers to Interrogatories nor Responses to Defendant's Request for Production of Documents nor is there any agreement of counsel concerning any further enlargement of time for Plaintiff to answer this outstanding written discovery. 6. According]y, Defendant F]ying J Inc. respectfully requests that this Honorab]e Court enter a Ru]e to Show Cause directing that Plaintiff show cause why Defendant's Motion to Compel Discovery should not be granted. DATE: tjAIJ' I ~I 'lJ.1J3 Respectfully submitted, MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN ~.~ BY: TIM HY. J.D. No. 52 8 4200 Crums Mill Road, Suite B Hamsburg, PA 17112 (717) 65]-3505 Attorney for Defendants CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Joanne M. Parr, an employee of Marshall, DeIlllehey, Warner, Coleman & Goggin, do hereby certify that on this \~ day of January, 2003, served a copy of the foregoing document via First Class United States mail, postage prepaid as follows: Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.c. 3211 North Front Street PO Box 5300 Harrisburg, PA 17110-0300 ~ \\\,~\. L.~oaIllle M. Parr CHRISTOPHER GOINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff, v. CIVIL ACTION - LAW FLYING J. INC. and FLYING J. TRAVEL PLAZA, NO. 02-3672 Defendants. JURY TRIAL DEMANDED RULE TO SHOW CAUSE NOW, this jq l2 day of March, 2003, upon consideration of the within Petition of Plaintiff's Counsel for Leave to Withdraw, a Rule is t~ntered upon Christopher Goins to show cause, if any he has, why the relief requested and said Motion should not be granted. Rule returnable dO days after service. BY THE COURT: /5/ ~,~ CI J.t"A I I 1. cc: Andrew W. Norfleet, Esquire - Counsel for Defendant Justin E. Murphy, Esquire Prothonotary rFfU~;<~ 'tc .~ r i' ,-; In T~~dtnony . i I}N(. 1;nto ;'jd{ m't ~~j)(j ~:;~ itill ~ ;:,f "",id C~li:t ,,( Wi H~. POl. '~'i /(~ J~~~ Prot!tllootlti Document #: 260840.1 MARsIIALL, DENNEHEY, W AHNER, A PROFESSIONAL COIlPQRATION A COLEMAN & Goc::ci I i"\ U"J ">.4 www.marsba1ldennehc::::J 0- 17112 m ru co D D D D D ::r 0- M M D D l'- 4200 Crums Mill Road, Suite B . Harrisburg, P A (717) 651-3500' Fax (717) 651-9630 Direct Dial: 717-651-3505 Email: tmcmahon@mdwcg.com Via Certified Mail Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street PO Box 5300 Harrisburg, PA 17110-0300 January 27,2003 I Postal Service ~U=.IED MAil RECEIPT If'ie~-JL,1t:Iif O!rly: No Insurance Coverage PrOVided) r~ , Pc.;:lagti L!...____m ,,_______ ~~J O:lrtifiedf~ R,rtum Receipt Fee {Endo'Sement Requif9dJ Rsstrlcted 0ef1V8l'y Fee (Endorsement Required) "Rrtal Po$tage a Fee$. Hem $ \\;;;)'\\~~ ~~~~.~:._~~~.~~~,~._---_..._._. S1Tee(,Apt.No.; or PO lkn No. cii;Si8i;;.ijp+ 4-"-.~~._-~~~O~--"~--_.-------~._. . i....(t:lIlf..t;1I uary 2001 ... RE: Christopher Goins v. Flying J Inc. and Flying J Travel Plaza, CCP (Cumberland County) No.: 02-3672 Our File # 20614-00146.061 Dear Mr. Norfleet: Enclosed please find a Rule directed to Plaintiff to show cause within twenty (20) days as to why Defendant's Motion to Compel Answers to Defendant's Interrogato:ries and Request for Production of Documents should not be granted. TJM/jmp Enclosure \05_A ILIABlTJM\CORR\114882\JMffi0614\OO146 Very t~urs, TIMO J. - SENDER: COMPLETE THIS SECTION . Complete items 1, 2. and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you_ . Attach this card to the back of the mail piece. or on the front if space permits. 1. Article Addressed to: ~~~~~\~. \\\~~,~~~\\(illI ~~\\ B.~~~'\~-\. \?,I."::\.~5~D \ '\ \ \ ~-~ 4. Restricted Delive'Y? (EXtea Fee) 7001 1940 0000 8239 0581 2. Article Number C (Transfer from service label) c. Signature f) X i3> f'f) -' ~t o Addressee Dyes DNo D. Is delivery add diff'3rent from item 1? If YES, enter delivery ;iddress below: 3. SelViee Type ~ Certified Mail o Registered o Insured Mail o E!<.press Mail o A'eturn Receipt for Merchandise D C.O.D. DYes 102595-01-M-1424 PS Form 3811, March 2001 Domestic Return Receipt ~\~-~\'-\\c, CHRISTOPHER GOINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. CIVIL ACTION - LAW FLYING J. INC. and FLYING J. TRAVEL PLAZA, NO. 02-3672 Defendants. JURY TRIAL DEMANDED ORDER AND NOW, this day of March, 2003, upon consideration of the verified Petition of Defendant's Counsel for Leave to Withdraw, IT IS HEREBY ORDERED that said Petition is granted and that Petitioner Metzger, Wickersham, Knauss & Erb, P .C. and Andrew W. Norfleet, Esquire, are permitted to withdraw their appearance of record for the Defendant in the above matter. BY THE COURT J. cc: Andrew W. Norfleet, Esquire - Counsel for Defendant Justin Murphy, Esquire Prothonotary Document #: 260840./ CHRISTOPHER GOINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff, v. CIVIL ACTION - LAW FLYING J. INC. and FLYINGJ. TRAVEL PLAZA, NO. 02-3672 Defendants. JURY TRIAL DEMANDED o r"'""' c;"~ '.' 4".: :~ ~2,~..--r', >, ::':J z-:. -n (I:) .=-, ;../ -'. ~c. -..,.-, tf~ 0J ./.:'" :J1 -~ Co.) Plaintiff's counsel, Andrew W. Norfleet, Esquire and the Law Firm of Metzger, PETITION OF PLAINTIFF'S COUNSEL FOR LEAVE TO WITHDRAW TO THE HONORABLE JUDGE OF SAID COURT: Wickersham Knauss & Erb, P.C., petition this Court for leave to withdraw as counsel for Plaintiff and in support thereof represents as follows: 1. On July 31, 2002, undersigned counsel filed a Complaint on behalf of Plaintiff, Christopher Goins. 2. At said time, Plaintiff was residing at 5316 Dogwood Road, Baltimore, Maryland. 3. At a later date and unknown to undersigned counsel, Plaintiffrnoved from the Baltimore address. 4. Undersigned counsel has received mail returned from Mr. Goins previous address and no forwarding address has been provided. Mr. Goins did not file a forwarding address with the United States Postal Service. Document #: 260840.1 C) "Tl ~l , ) ---;..; d,; i::::") ;'-:nl <.-1 ., ~ _. 5. The telephone number assigned to Mr. Goins has been disconnected and undersigned counsel is unable to reach Mr. Goins and cannot provide Answers to Discovery requested by defense counsel and cannot produce Mr. Goins for deposition. 6. Mr. Goins has not made any attempt to contact undersigned counsel for more than three months. WHEREFORE, Andrew W. Norfleet and METZGER, WICKERSHAM, KNAUSS & ERB, P.C., request this Honorable Court dismiss them as counsel of record in this matter Respectfully submitted, , METZGER, WICKERSHAM, KNAUSS & ERB, P.C. ~# Andn!wW.No et . Supreme Court J.D. No. 83894 321 I North Front Street P. O. Box 5300 Harrisburg, PA 17110.0300 (717)238-8187 Attorneys for Defendant Date: 3/12/03 Document #: 260840.1 VERIFICATION I, Andrew W. Norfleet, Esquire, do hereby verify that the facts set forth in the foregoing Petition of Plaintiff's Counsel for Leave to Withdraw are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date: March 12,2003 Andrew Document #: 260840.1 CERTIFICATE OF SERVICE I, Andrew W. Norfleet, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I have this 12th day of March 2003, served a true and exact copy of the herein Petition of Plaintiff's Counsel for Leave to Withdraw with reference to the foregoing action by first-class postage prepaid, on the following: Justin E. Murphy, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crums Mill Road, Suite B Harrisburg, P A 17112 Mr. Christopher Goins 5316 Dogwood Road Baltimore, MD 21207 ~~~ Andre W. Norflee Document #; 260840_1 C'V W1\"I'u:.; \ 'I\.f' CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. 02-3672 CIVIL FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED IN RE: DEFENDANTS' MOTION TO MAKE RULE ABSOLUTE ORDER /u. AND NOW, this 7 day of March, 2003, the motion ofthe defendants to make rule absolute is granted and the plaintiff is directed to respond to all outstanding discovery in this case within thirty (30) days of service hereof. BY THE COURT, Andrew W. Norfleet, Esquire For the Plaintiff ~;".(1Ji Justin E. Murphy, Esquire For the Defendants :rlm TRUE COPY FROM RECORD III Testimony wi1ereof. I here unto set my haAd aJld tM~ of said Coort at CarlIsle. Pa. '- na~ ~ ~~~~ CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Cherri M. Whitson, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this \S-t- day of May, 2003, served a copy of the foregoing document via Certified Mail as follows: Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street PO Box 5300 Harrisburg, P A 1711 0-0300 Christopher Goins 5316 Dogwood Road Baltimore, MD 21207 ~-Y}1.~ Cheni M. Whitson \05_ A ILIAB\TJM\LLPG\102257\JMF\15000\50000 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA () c ;:,- No.: 02-3672 CHRISTOPHER GOINS, Plaintiff FLYING J INe. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION- LAW 1:,: n-,r -, , JURY TRIAL DEMANDED ;/ (, ~< r..: ;:':-:; ..-- >?:i -<. ., PLAINTIFF'S ANSWERS TO INTERROGATORIES OF DEFENDANT, FL \1NG J INC.. ADDRESSED TO PLAINTIFF :..n tll Definitions. -- The following definitions are applicable to these standard interrogatories: "Document" means any written, printed, typed, or other graphic matter of any kind or nature, however produced or reproduced, including photographs, microfilms, phonographs, video and audio tapes, punch cards, magnetic tapes, discs, data cells, drums, and other data compilations from which information can be obtained. "Identify" or "Identity" means when used in reference to -- (I) A natural person, his or her: (a) Full name; and (b) Present or last known residence and employment address (including street name and number, city or town, and state or county); (2) A document: (a) Its description (e.g., letter, memorandum, report, etc.), title, and date; (b) Its subject matter; (c) Its author's identity; (d) Its addressee's identity; (e) Its present location; and (f) Its custodian's identity; (3) An oral communication: (a) Its date; (b) The place where it occurred; (c) Its substance; (d) The identity of the person who made the communication; (e) The identity of each person to whom such communication was made; and (f) The identity of each person who was present when such communication was made; (4) A corporate entity: (a) Its full corporate name; (b) Its date and place of incorporation, if known; and (c) Its present address and telephone number; (5) Any other context: A description with sufficient particularity that the thing may thereafter be specified and recognized, including relevant dates and places, and the identification of relevant people. entities, and documents. "Incident" means the occurrence that forms the basis of a cause of action or claim for relief set forth in the complaint or similar pleading. "Person" means a natural person, partnership, association, corporation, or governmelltal agency. Standard Instructions. -- The following instructions are applicable to these standard interrogatories: (1) Duty to answer. -- The interrogatories are to be answered in writing, verified, and served upon the undersigned within 30 days of their service on you. Objections must be signed by the attorney making them. In your answers, you must furnish such information as is available to you, your employees, representatives, agents, and attorney. Your answers must be supplemented and amended as required by the Pennsylvania Rules of Civil Procedure. (2) Claim of privilege. -- With respect to any claim of privilege or immunity from discovery, you must identify the privilege or immunity asserted and provide sufficient information to substantiate the claim. (3) Option to produce documents. -- In lieu of identifying documents in response to these interrogatories, you may provide copies of such documents with appropriate references to the corresponding interrogatories. 1. General. 101. Personal information. -- State: (a) Your full name; (b) Each other name, if any, which you have used or by which you have been known; (c) The name of your spouse at the time of the accident and the date and place of your marriage to such spouse; (d) The address of your present residence and the address of each other residence which you have had during the past five years; ( e) Your present occupation and the name and address of your employer; (f) Date of your birth; (g) Your Social Security number; (h) Your military service and positions held, if any; :md (i) The schools you have attended and the degrees or certificates awarded, if any. 102. Insurance. -- If you are covered by any type of insurance, including any excess or umbrella insurance, that might be applicable to the incident in this matter, state the following with respect to each such policy: (a) The name of the insurance carrier which issued the policy; (b) The named insured under each policy and the policy number of each policy; (c) The type(s) and effective date(s) of each policy; (d) The amount of coverage provided for injury to each person, for each occurrence, and in the aggregate for each policy; and (e) Each exclusion, if any, in the policy which is applicable to any claim thereunder and any reasons, if any, why you or the carrier claim the exclusion is applicable. 103. Expenses. -- List and describe all expenses and losses that you have incurred because of the incident. 104. Factual basis for claims and defenses. -- State with particularity the factual basis for each claim or defense you are asserting in this case. 105. Witnesses. -- (a) Identify each person who (1) Was a witness to the incident through sight or hearing and/or (2) Has knowledge off acts concerning the happening of the incident or conditions or circumstances at the scene of the incident prior to, at the time of, or after the incident. (b) With respect to each person so identified, state that person's exact location and activity at the time of the incident. 106. Statements. -- If you know of anyone that has given any statement (as defined by the Rules of Civil Procedure) concerning this action or its subject matter, state: (a) The identity of such person; (b) When, where, by whom, and to whom each statement was made, and whether it was reduced to writing or otherwise recorded; and (c) The identity of any person who has custody of any such statement that was reduced to writing or otherwise recorded. 107. Reports of incident. -- Identify the documents (except reports of experts subject to Pa.R.C.P. No. 4003.5) which describe the incident or the cause thereof. 108. Demonstrative evidence. - If you know of the existence of any photographs, motion pictures, video recordings, maps, diagrams, or models relevant to the incident, state: (a) The nature or type of such item; (b) The date when such item was made; (c) The identity of the person that prepared or made each item; and (d) The subject that each item represents or portrays. 109. Trial preparation material. -- If you, or someone not an expert subject to Pa.R.C.P. No. 4003.5, conducted any investigations of the incident, identify: (a) Each person, and the employer of each person, who conducted any investigation(s); and (b) All notes, reports or other documents prepared during or as a result of the investigation(s) and the persons who have, custody thereof. 110. Trial witnesses. -- Identify each person you intend to caB as a non-expert witness at the trial of this case, and for each person identified state your relationship with the witness and the substance of the facts to which the witness is expected to testify. 111. Expert witnesses. -- Identify each expert you intend to call as a witness at the trial of this matter, and for each expert state: (a) The subject matter about which the expert is expected to testify; and (b) The substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion. (You may file as your answer to this interrogatory the report of the expert or have the interrogatory answered by our expert.) 112. Trial exhibits. -- Identify all exhibits that you intend to use at the trial of this matter and state whether they will be used during the liability or damages portions of the trial. 113. Books, magazines, etc. -- If you intend to use any book, magazine, or other such writing at trial state: (a) The name of the writing; (b) The author of the writing; (c) The publisher of the writing; (d) The date of publication of the writing; and ( e) The identity of the custodian of the writing. 114. Admissions. -- If you intend to use any admission( s) of a. party at trial, identify such admission( s). 2. Personal injury. 201. Injuries and diseases alleged. -- Identify all injuries or diseases that you allege you suffered as a result of the incident. 202. Prior or subsequent injuries or diseases. -- If, either prior to or subsequent to the incident, you suffered any injury or disease in those portions of the body claimed by you to have been affected by the incident, state: (a) The injury or disease you suffered; (b) The date and place of any accident, if such injury or disease was caused by an accident; (c) The identity of hospitals, doctors, or practitioners who rendered treatment or examination because of such injury or disease; and (d) The identity of anyone against whom a claim was made, and the tribunal and docket number of any claim or lawsuit that was filed in connection with such injury or disease. 203. Medical treatment. -- If you received medical treatment or examination (including x-rays) because of injury or disease you suffered as a result ofthe incident, state: (a) The identity of each hospital at which you were treated or examined; (b) The date on which each such treatment OJ[ examination at a hospital was rendered, and the charge by the hospital jor each; ( c) The identity of each doctor or practitioner by whom you were treated or examined; (d) The date on which each such treatment or examination by a doctor or practitioner was rendered, and the charge for each; and (e) The identity of any document(s) (except :reports of experts subject to PaRe.P. 4003.5) regarding any medical treatment or examination, setting forth the author and date of such document( s). 204. Earnings before the incident. -- For the period of three years immediately preceding the date of the incident, state: (a) The name and address of each of your employers or, if you were self- employed during any portion of that period, each of your business addresses and the name of the business while self-employed; (b) The dates of commencement and termination of each of your. periods of employment or self-employment; (c) The nature of your occupation in each employment or self-employment; and (d) The wage, salary, or rate of earnings received by your in each employment or self-employment, and the amount of income from employment and self- employment for each year. 205. Earnings after the incident. -- If you have engaged in one or more gainful occupations subsequent to the date of the incident, state: (a) The name and address of each of your employers or, if you were self- employed at anytime subsequent to the incident, each of your business addresses and the name of the business while self-employed; (b) The dates of commencement and termination of each of your periods of employment or self-employment; (c) The nature of your occupation in each employment or self-employment; (d) The wage, salary, or rate of earnings received by you in each employment or self-employment, and the amount of income from employment and seIf- employment for each year; and (e) The date(s) of any absence(s) from your occupation resulting from any injury or disease suffered in this incident and the amount of any earnings or other benefits lost by you because of such absence(s). 206. Limitation of duties and activities after the incident. --If, as a result of this incident, you have been unable to perform any of your customary occupational duties or social or other activities in the same manner as prior to the incident, state with particularity: (a) The duties and/or activities you have been unable to perform; (b) The periods of time you have been unable to perform; and (c) The identity of all persons having knowl,~dge thereof. 207. Substance impairment. -- If you consumed any alcoholi,~ beverage, sedative, tranquilizer, marijuana, cocaine, hashish, or other drug, medicine or pill during the eight hours immediately preceding the incident, state: (a) The nature, amount, and type of item consumed; (b) The amount of time over which consuIDe:d; (c) The identity of any and all persons who have any knowledge as to the consumption of those items; and (d) The identity of the physician or medical practitioner or other person who gave, purchased or prescribed any of said items, if any. 208. With respect to the allegations set forth in Plaintiffs Complaint at Paragraph 5, to wit that on August 1,2000 at approximately 2:00 a.m. Plaintiff was proceeding to the restroom of the restaurant at Flying J Travel Plaza, state when Plaintiff first arrived on August 1, 2000 at the Flying J Restaurant, by whom Plaintiff was accompanied, if anyone at that time, and the route of travel and/or path of travel from the point that Plaintiff began to proceed to the restroom up until the point where Plaintiff fell as alleged. 209. State whether Plaintiff was carrying anything in either or both of his hands at the time of the slip and fall incident alleged in his Complaint at Paragraph 5. 2] O. State whether Plaintiff observed one or more "wet floor" warning sigus or any other warning signs in the vicinity of the area where Plaintiff alleges at Paragraph 5 in his Complaint that he had fallen on August 1, 2000 at approximately 2:00 a.m. 2]]. State whether Plaintiff had ever before August 1, 2000 patronized the Flying J Restaurant located at 150 I Harrisburg Pike, Carlisle, Pellllsylvania and if so identify all dates on which Plaintiff had previously patronized this restaurant facility. DATE: A\J(€-. 14-, 'lCJ.j7.. BY: Attorney for Defendant, Flying J Inc. 101. (a) Christopher S. Goins (b) None that counsel is aware of. (c) Unknown at this time. (d) 5316 Dogwood Road Baltimore, Maryland 21207 (e) unknown at this time (f) unknown at this time (g) 212-02-9910 (h) none. (i) No degrees awarded. 102. Undersigned counsel is not aware of any available insurance coverage. 103. Medical expenses of$I,870.15 104. Plaintiff fell on a wet floor that was not properly identified so as to avoid said danger. 105. (a) Christopher Goins (I) Vicitm; witnesses by experience (2) Has knowledge of the facts (b) Robin Smith (I) Eyewitness to accident (2) Has knowledge offacts of the accident ( c) Rhonda Scott (I) Witness to the accident (2) Has knowledge of the facts of the accident 105 (b). (I) Robin Smith: was sitting at Plaintiffs table and witnessed the fall. (2) Rhonda Scott: was sitting at Plaintiffs table and witnessed the fall. 106. Undersigned believes that Plaintiff gave a recorded statement to Defendant's insurance carri er. 107. Undersigned is not in possession of any such reports. 108. Undersigned believes that photos were provided by previous counsel to Defendant's . . Insurance carner. 109. No investigation conducted at this time. 110. Witnesses identified in response to answer to #105. 280094-1 III. None at this time. Plaintiff shall supplement these answers pursuant to the Rules of Civil Procedure should they become available. 112. None at this time. Plaintiff shall supplement these answers pursuant to the Rules of Civil Procedure should they become available. 113. None at this time. Plaintiffshall supplement these answers pursuant to the Rules of Civil Procedure should they become available. 114. None at this time. Plaintiff shall supplement these answers pursuant to the Rules of Civil Procedure should they become available. 20 I. Plaintiff suffered open head injuries that required staples to close. Plaintiff also experienced headaches and blurred vision. To the best of counsel's knowledge, Plaintiff continues to receive medical care. 202. No prior injuries. 203. (a) Carlisle Hospital (b) 8/1/00 (c) Dr. Guarrac (d) 8/1/00 (e) Provided (a) Dr. Blumsom (b) 11/20/00 (c) Dr. Blumson, OD (d) 11/20/00 (e) Provided (a) Carlisle Imaging Assoc. (b) 8/1/00 (c) Unknowm (d) 8/1/00 (e) Provided 204. Undersigned will supply this information to counsel when available. 205. See response to request #204. 206. See response to request #204. 207. Unknown. It is the belief of undersigned counsel that Plaintiff had not consumed alcohol or other substances. 280094-1 208. Plaintiff was accompanied by the witnesses identified in response to request #105. Undersigned will supplement this answer pursuant to the Pennsylvania Rules of Civil Procedure when additional information is available. 209. Plaintiff was not carrying any objects. 210. Plaintiff did not observed any "wet floor" signs. 211. Plaintiff had not been patron of the Flying J prior to the night in question. 280094-1 VERIFICATION The undersigned hereby certifies that he is the attorney for Christopher Goins and that the facts in the foregoing Plaintiff's Answers to Interrogatories of Defendant Flying J, Inc. are true and correct to the best of his knowledge, information and belief, and that said matters relating to Plaintiff's Answers to Interrogatories of Defendant Flying J, Inc. are as known to the undersigned as to the client, Christopher Goins, said knowledge being based upon information contained in the file in this matter, and further states that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. ~{J,~ Andrew W. Norfleet, Esquire Date: May 9, 2003 280781-1 ---- -~_._~_._._-_.._._~------ ---- \05 _^ ILIABITJM\LLPG\102259\JMFlI5000\50000 CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED PLAINTIFF"S RESPONSE TO \: Qi :>-1 C '- ~~~ I. -<- () ; PLEASE TAKE NOTICE that you are hereby requested to produce for inspection and other REQUEST FOR PRODUCTION OF DOCUMENTS ADDRESSED TO PLAINTIFF 2: "- .r" ~.) ..' -. ., . , ::.-< purposes, including copying, pursuant to the Pennsylvania Rules of Civil Procedure, at the office of the counsel for the requesting party, or at such other location as may be mutually agreeable between counsel for you and counsel for the requesting party, not less than thirty (30) days after service of these requests, documents herein cited. The word "document" or "documents" as herein used includes but is not limited to photographs, video tapes, drawings, reports, statements and memoranda, as well as all other documents as defined in the Rilles. 1. All documents in your possession, control or custody constituting, relating to, or pertaining to the documents identified in response to Defendant's Interrogatorie,s. 2. All medical bills, reports, records, and x-rays, relating to the injury allegedly sustained in the occurrence described in the Complaint, as well as all medical bills, records, and reports relating to prior or subsequent injuries to the same parts of the body claimed by Plaintiff to have been injured in the occurrence described in the Complaint. . , . , CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Cherri M. Whitson, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this~day of June, 2003, served a copy of the foregoing document via Certified Mail as follows: Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street PO Box 5300 Harrisburg, PA 17110-0300 Christopher Goins 5316 Dogwood Road Baltimore, MD 21207 ~~;;g~ 105_ A ILIABI TJMICORRIl13919\TMFI20614100146 . . g <a q, ~~ ~ ::;1__ ".c_. .1 ~I1 f1'f~ '" -Of'; (fl.), ;;:- iJI:( ::.(. ~.~ UQ 1.:20 ... --0 ~~~ ~Q ~ ~<E r:? (5..... ... ~ c:> ~ '" CHRISTOPHER GOINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. CIVIL ACTION - LAW FLYING J. INC. and FLYING J. TRAVEL PLAZA, NO. 02-3672 Defendants. JURY TRIAL DEMANDED PETITION OF PLAINTIFF'S COUNSEL FOR LEAVE TO WITHDRAW TO THE HONORABLE JUDGE OF SAID COURT: Plaintiffs counsel, Andrew W. Norfleet, Esquire and the Law Firm of Metzger, Wickersham Knauss & Erb, P.C., petition this Court for leave to withdraw as counsel for Plaintiff and in support thereof represents as follows: 1. On July 31, 2002, undersigned counsel filed a Complaint on behalf of Plaintiff, Christopher Goins. 2. At said time, Plaintiff was residing at 5316 Dogwood Road, Baltimore, Maryland. 3. At a later date and unknown to undersigned cormsel, Plaintiff moved from the Baltimore address. 4. Undersigned counsel has received mail returned from Mr. Goins previous address and no forwarding address has been provided. J\1r. Goins did not file a forwarding address with the United States Postal Service. Document #: 260840. J 5. The telephone number assigned to Mr. Goins has been disconnected and undersigned counsel is unable to reach Mr. Goins. 6. Undersigned counsel has provided answers to counsel for Defendant, but is unable to provide a verification signed by Plaintiff. 7. Counsel for Defendant has filed a Motion seeking sanctions against Defendant and undersigned counsel. 8. Undersigned counsel has sent a copy of this :Motion to the last known address of Plaintiff via U.S. Mail and Certified Mail. WHEREFORE, Andrew W. Norfleet and METZGER, WICKERSHAM, KNAUSS & ERB, P.C., request this Honorable Court dismiss them as counsel of record in this matter Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. AOOrew .Noill-;; a$ Supreme Court I.D. No. 83894 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 (717)238-8187 Attorneys for Defendant Date: 6 /23/03 Document #: 260840. J VERIFICATION I, Andrew W. Norfleet, Esquire, do hereby verify that the facts set forth in the foregoing Petition of Plaintiff's Counsel for Leave to Withdraw are true and correct to the best of my personal knowledge or 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 23, 2003 Document #: 260840. J CERTIFICATE OF SERVICE I, Andrew W. Norfleet, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I have this 23'd day of June, 2003, served a true and exact copy of the herein Petition of Plaintiffs Counsel for Leave to Withdraw with reference to the foregoing action by first-class postage prepaid, on the following: Justin E. Murphy, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crwns Mill Road, Suite B Harrisburg, PA 17112 Mr. Christopher Goins 5316 Dogwood Road Baltimore, MD 21207 /~/ ..c..J. . Norfleet Document #: 260840.1 0 a 0 c: w -fl :;': '- =-)J ClCL S -:, ~m ., ---- ., ;q Zl I , ~S? CI) "I':" -.J ....'(.,.: ::.--.4CJ (::' U -0 ,-'. ~~ 3: ) ::'J Z (~: (") :i; C., w s"5, ,-n c: 2: > _.~ :u -< '0 -< CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 02-3672 CIVIL FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED IN RE: DEFENDANTS' MOTION FOR SANCTIONS ORDER ",. AND NOW, this ,. day of July, 2003, a brief argument on the within motion for sanctions is set for Wednesday, July 23, 2003, at 3:30 p.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, P A. BY THE COURT, fl/L Andrew W. Norfleet, Esquire For the Plaintiff Justin E. Murphy, Esquire For the Defendants 7- ~-O~ Co ~ VU' ~ :rlm g $;: -ol-:O rD'" Z;J:. ~s .:..( ~--'- ~c ZC >:; z -~ -<. G) t...' ,- ~ t CP o -n .::1 -'l;n ,-,1'1'1 <,I:? '-'j~?; ,-n :/J~ ,;'7"~ ;'i; :< :::> CHRISTOPHER GOINS, IN THE COURT OF COMMON PLEAS OF CUMBERI~AND COUNTY, PENNSYLVANIA Plaintiff, v. CIVIL ACTION - LAW FLYING 1. INC. and FLYING J. TRAVEL PLAZA, NO. 02-3672 Defendants. JURY TRIAL DEMANDED MOTION TO MAKE RULE ABSOLUTE TO THE HONORABLE KEVIN A. HESS, JUDGE OF SAID COURT: AND NOW, comes Plaintiffs Counsel, Andrew W. Norfleet, Esquire and Metzger, Wickersham, Knauss & Erb, P.C., to file the within Motion to Make Rule Absolute in support thereof avers: I. On July 31, 2002, undersigned counsel filed a Complaint on behalf of Plaintiff, Christopher Goins. 2. At said time, Plaintiff was residing at 5316 Dogwood Road, Baltimore, Maryland. 3. On August 20, 2002, undersigned counsel served upon Plaintiff, Christopher Goins, by certified mail (#7001 2510 0000 2435 7986) discovery requests from Defense Counsel. 4. Said correspondence, served on Plaintiff on August 20, 2002 was returned to undersigned counsel as "attempted not known." Undersign,ed counsel contacted the postal service and was advised that, after numerous attempts, the correspondence could not be delivered and Plaintiff did not live at the address listed. Counsel was also advised that no forwarding address was provided for Mr. Goins. (See, copy of returned correspondence attached as Exhibit "A") 284406-/ 5. Undersigned counsel made nwnerous attempts to contact Plaintiff via telephone at (410) 944-7247, the nwnber provided by Plaintiff and the number used by undersigned counsel to contact Mr. Goins. The telephone nwnber assigned to Mr. Goins was disconnected and undersigned counsel was unable to reach Mr. Goins. No forwarding information was available. 6. Unable to reach Plaintiff, undersigned counsel provided answers to counsel for Defendant, but was unable to provide a verification signed by Plaintiff. 7. Counsel for Defendant has filed a Motion seeking sanctions against Defendant and undersigned counsel. 8. Defense counsel, Justin Murphy, Esquire, has agreed to withdraw said Motion for Sanctions to allow this Honorable Court to decide undersigned l;ounsel's Motion to Withdraw. 9. Undersigned counsel has served a second copy of this Motion upon Plaintiff to the last known address of Plaintiff via U.s. Mail and Certified Mail. The correspondence has not been accepted by Plaintiff. (See attached tracking report attach(:d as Exhibit "8") 10. On July 9, 2003, Plaintiff contacted undersigned counsel and denied moving from the listed address. Plaintiff acknowledged that he has not contacted undersigned counsel since January, 2003 because he "could not afford to continue the case" and also acknowledged that his phone number was disconnected and he did not provide a new nwnber to undersigned counsel. II. Undersigned counsel respectfully requests this Honorable Court to Make Absolute the Rule signed on March 19,2003. (See, copy of Rule attached as Exhibit "C") 284406-J WHEREFORE, Andrew W. Norfleet and METZGER, WICKERSHAM, KNAUSS & ERB, P.C., request this Honorable Court dismiss them as counsel of record in this matter Respectfully submitted, Andrew . Norflee Supreme Court J.D. No. 83894 3211 North Front Street P. O. Box 5300 Harrisburg, PA 17110-0300 (717)238-8187 Attorneys for Defendant Date: 7/11/03 284406-1 Y" , .Jorfleet, Esquire I 3211 North Front Street . P.O. Box 5300 Harrisburg, PA 17110-0300 "'88 '"~ . ..-,.. ,. ". ~"'~ l m IIIIIIIIIIWIIIIIIIII'III 7001 2510 0000 2435 7986 - ~ ~ ('r~^ ' ., ~ ~, .";',. j1. '".' \.J ~ t:,'. ,'. , 't::* ,,~~\y \ \' ~'.. '~~tJ~1"',~ Mr. Christ ~. -f~6ins ... ..JJ . ../~. 531BD ood r{oad . .- C.>-. ~'!f,())o.cBalt' MD 2120". '.<,:>>>. i1,.'O~q I e, "VOt1:;<> -, ~r ~'~ I .~,...~~ -~ '.'-'. ~, 'f,r"" f,: "'~ .. ",:.~";'.., ~>. \.." ".'f .. ..~ '. "'4.~, t!.dlf".- 1. '''''''~' ;':..' ~ 0 '~.~ . ..~n,~ '- . ,..' .', .. ", (' ;:, i_; .~. ", , ~'.. - :., " / , I .".~.- ',';'''-'' l', , . "1 .. USPS - Track & ConfIrm Page 1 of 1 -_. I:!llml> Track & Confirm Current Status Track & Confirm Enter label number: I I .-".-.! (61)'0 / You entered 7002 3150 0006 77251035 We attempted to deliver your item at 10:13 am on July 02,2003 in GWYNN OAK, MD 21207 and a notice was left. It can be redelivered or picked up at the Post Office. If the item is unclaimed, it will be returned to the sender. Status is updated every evening. Please check again later. ($Np---rt_,. ) A . Track & Confirm FAQs (61),) / Notification Options . Track & Confirm by em ail What Is this? ( 60<,) . POSTAL INSPECTORS Preserving the Trust site map contact us government services Copyright@1999-2002 usps. All Rights Reserved. Terms of Use Privacy Policy ~ http://trkcnfrm1.smi.usps.com/netdata-cgi/db2www/cbd_ 243.d2w/output 7/10/2003 CHRISTOPHER GOINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. CIVIL ACTION - LAW FLYING J. INC. and FLYING J. TRAVEL PLAZA, NO. 02-3672 Defendants. JURY TRIAL DEMANDED RULE TO SHOW CAUSE "- NOW, this It( - day of March, 2003, upon consideration of the within Petition of Plaintiff's Counsel for Leave to Withdraw, a Rule is entered upon Christopher Goins to show cause, if any he has, why the relief requested and said Motion should not be granted. Rule returnable.:2IJ days after service. BY THE COURT: /s/ 1~MA : () )t4-<l I , J. cc: Andrew W. Norfleet, Esquire - Counsel for Defendant Justin E. Murphy, Esquire Prothonotary Document #: 260840.1 TR! II: t'-,>'C'.'" "",""'. .,1' ""'."'"',1"';,...,,, ~ ,~...,,~ ~y....,1 i i' fH".;';;;, iI:'"~t,:':(':""'~..Ii'H..J InT1atmmY'oidUJ,',fl.j!., I M'b,; myll<iOO a~" .1""" H'~l v' i "';' ',"'" " ". ';.!/;' Pi ;~ ,tV.....~ ,~l,.<_,,,p ,"'H',' ....., ". .~,,: " g...- ~"""-""'~W."~"";~""h'1 . rim /9 day U~ :ldv3 ~tl" , I)-Jh::/,~'), ~ PrO!~i)nt1!r" VERIFICATION I, Andrew W. Norfleet, Esquire, do hereby verify that the facts set forth in the foregoing Motion to Make Rule Absolute are true and correct to the b,est of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date: July 11, 2003 ////--) / (/.. // ~ ----/N/'~. Ancttew W. Norfl(;el . ,/ 284406-1 CERTIFICATE OF SERVICE I, Andrew W. Norfleet, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.c., hereby certify that 1 have this II th day of July, 2003, served a true and exact copy of the herein Motion to Make Rule Absolute with reference to the foregoing action by first-class postage prepaid and certified mail on Christopher Goins only, on the following: Justin E. Murphy, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 Mr. Christopher Goins 5316 Dogwood Road Baltimore, MD 21207 284406-1 r... i:" .,..~i;. 11." --;, . t,~ 1,,, r:~ ~._ ~.': - ~-, ( ~.~L~ -c () -'--J j ~.'.., .,:-'n iC) -', , f("") "1 - 71 ....,J -71'0 , -r,~ ::0 -< c- C::l CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED MOTION TO WITHDRAW DEFENDANTS' MOTION FOR SANCTIONS AND TO REMOVE FROM ARGUMENT LIST 1. Defendant has filed a Motion for Sanctions based upon Plaintiffs failure to provide timely, responsive and verified responses to discovery requests. 2. This matter has been listed for Argument Court on July 23,2003 at 3:30 p.m. before the Honorable Judge Kevin Hess. 3. Pending also is Plaintiffs counsel's Petition to Withdraw as counsel for Plaintiff. 4. Although Defendant intends to pursue sanctions against the Plaintiff for his failure to provide timely, responsive and verified answers to discovery, this Honorable Court will not rule on Plaintiffs counsel's Motion to Withdraw while Defendants' Motion for Sanctions is pending. 5. Defendant does not object to Plaintiffs counsel's Motion to Withdraw as counsel for Plaintiff and, therefore, is willing to temporarily forego presenting its Motion for Sanctions so that the Court may grant Plaintiffs counsel's request to withdraw as counsel for Plaintiff. 6. Defendant does not waive its right to present its Motion for Sanctions once Plaintiffs counsel has been permitted to withdraw from his representation of Plaintiff. WHEREFORE, Defendants respectfully request that th{:ir Motion for Sanctions be withdrawn without prejudice and removed from the Argument List on July 23, 2003. Respectfully Submitted, MARSHAI,L, DENNEHEY, WARNER, COLEMAN & GOGGIN DATE: -7(,1(0"7 BY: ~- ni~ MURPHY, ESQUIRE J.D. 8 085 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3504 Attorneys for Defendants CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Cherri M. Whitson, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this ~day of July, 2003, served a copy of the foregoing document via First Class United States Mail postage pre-paid as follows: Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street PO Box 5300 Harrisburg, P A 17110-0300 ~m.~;:) Chen'i M. Whitson 105_ A ILIABITJMICORR1113919\JMFI20614100146 () (7,\ C W ?:' "1:) l- , -- rll L, z: z: , ."';) (f) -< t~ (:::0 "'" ~ C ./-,,' C 5> C~ :~';? /~ .;:..1 -." <-:J -:.: C- o< CHRISTOPHER GOINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL ACTION - LAW v. FLYING J. INC. and FLYING J. TRAVEL PLAZA, NO. 02-3672 Defendants. JURY TRIAL DEMANDED ORDER AND NOW, this '- z.r} day of June, 2003, upon consideration of the verified Petition of Defendant's Counsel for Leave to Withdraw, IT IS HEREBY ORDERED that said Petition is granted and that Petitioner Metzger, Wickersham, Knauss & Erb, P.C. and Andrew W. Norfleet, Esquire, are permitted to withdraw their appearance of record for the Defendant in the above matter. BY THE COURT i ---/~m J. cc: ~ew W. Norfleet, Esquire - Counsel for Defendant tJ.:fistin Murphy, Esquire Prothonotary -J ~~d. 07- ~!S.a3 Document #: 260840./ \~NV!\lASi\!N3d '[' ",,-~, ~'.', ," '....,^'n'" J'- 1\:, ;;~"; , :' '-'~;"j~ ;t Iv i.. u :01 ;J\i r; llilf' CO I-t)\/l(,;'" CHRISTOPHER GOINS, Plaintiff IN THE COURT OF' COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED ORDER AND NOW this .12"" day of 1'4 , 2003, upon consideration of Defendants' Motion to Withdraw Defendants' Motion for Sanctions and Remove from Argument List, IT IS HEREBY ORDERED that Defendants' Motion for Sanctions is withdrawn without prejudice pending disposition of Plaintiffs counsel's Motion to Withdraw as counsel for Plaintiff. IT IS ALSO ORDERED that Defendants' Motion is to be removed from the Argument List on July 23, 2003 and that Defendants are permitted to present their motion after disposition of Plaintiffs Motion to Withdraw as counsel for Plaintiff. BY THE COURT: (\~ () \.)(.. \ ~ C) ~ ~,.. D \05_ A \LIABIJRM\LLPG\129324\CYW\20614\OO 146 \flrNi\\fS\'\N3d \ ,,'r'--' .,0 .'.~G!"r"lr"I f'';''\ .;, .i ~.~,:-',,-;~'IIJ v~ 0 ~~:; (' Z '''\nc CO ,n ~v }.b CHRISTOPHER GOINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. CIVIL ACTION - LAW FLYING 1. INC. and FLYING J. TRAVEL PLAZA, NO. 02-3672 Defendants. JURY TRIAL DEMANDED PETITION TO FILE AMENDED ORDER TO THE HONORABLE KEVIN HESS, JUDGE OF SAID COURT: AND NOW, comes Petitioner, Andrew W. Norfleet, Esquire, and the law firm of Metzger, Wickersham, Knauss & Erb, P.C., and respectfully submits the following: I. On June 22, 2003, upon consideration of the verified Petition of Plaintiff s counsel for leave to withdraw, this Honorable Court granted said Petition, allowing the law firm of Metzger, Wickersham, Knauss & Erb, P.C., and Andrew W. Norfleet, Esquire, to withdraw their appearance in this matter. 2. The Order signed on June 22, 2003, incorrectly identified Petitioners, Metzger, Wickersham, Knauss & Erb, P.C., and Andrew W. Norfleet, Esquire, as counsel for Defendants. 3. Petitioners, Metzger, Wickersham, Knauss & Erb, P.c., and Andrew W. Norfleet, Esquire, should have been correctly identified as counsel for Plaintiff, Christopher Goins. WHEREFORE, Petitioners, Metzger, Wickersham, Knauss & Erb, P.C., and Andrew W. Norfleet, Esquire, respectfully requests this Honorable Court to replace the Order of Jooe 22, 2003, with the attached Amended Order. 286455-1 Date: August --1!:L, 2003 286455-1 Respectfully submitted, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. ...~~ AndreW W. NorfleekE: . ' Attorney LD. No. fi894 3211 North Front Street P.O. Box 5300 Harrisburg, P A 1711 0-0300 (717) 238-8187 -2- CERTIFICATE OF SERVICE AND NOW, this --1!iI!:::day of August, 2003, I, Andrew W. Norfleet, Esquire, of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served the foregoing Petition to File Amended Order this day by depositing the same in the United States mail, postage prepaid, in Harrisburg, Pennsylvania, addressed to: Justin E. Murphy, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crumbs Mill Road, Suite B Harrisburg,PA 17112 BY~~ AndrewW. Norfleet, ui~ ( 286455-1 . CHRISTOPHER GOINS, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW FL YING J. INC. and FL YING J. TRAVEL PLAZA, NO. 02-3672 Defendants. JURY TRlAL DEMANDED AMENDED ORDER AND NOW, this z.,' day df August, 2003, upon consideration of the verified Petition of Defendant's Counsel for Leave to Withdraw, IT IS HEREBY ORDERED that said Petition is granted and that Petitioner Metzger, Wickersham, Knauss & Erb, P.C. and Andrew W. Norfleet, Esquire, are permitted to withdraw their appearance of record for the Plaintiff in the above matter. . BY THE COURT: 1. cc: Andrew W. Norfleet, Esquire Justin E. Murphy, Esquire Prothonotary ~ /I'Yl.~ J". ;} C -03 J.i;~ q 1A4~ I?~ ~ 286284_1 . VIf\'\f/ilASNN3d A1NnO~; Gtr,ni!3Bi^lno 0'1 :8 \old SZ :lnV SO Al:N10NOH.LOL:d 3HJ. dO 30I.:l.:\O-{J311:l CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of Joseph F. Murphy, Esquire, on behalf of Defendant, Flying J Inc. and Flying J Travel Plaza, in the above-captioned case. Respectfully submitted, BY: J 1. . No.: 7811 4200 Crums Mill Road, Suite B Harrisburg,PA l71I2 (717) 651-3509 MARSHALL, DEl\INEHEY, WARNER, COLEM & GO ~rGIN I i ;~, ESQUIRE Dated: ?-/(>03 -u( EJ~ 0"':'-- ;?':'L ([OJ J r:: =;-- 2:',.. .c:;:,.t ~> C:I c 1_., C) :n ;-'q -'7J ..:;' 1'0 '0 :.') PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY/OF CUMBERLAND COUNTY: Please list the within matter for the next: o Pre-Trial Argument Court 18I Argument Court ---------------------------------------------------------------------- CAPTION OF CASE (entire caption must be stated in full) CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CNIL ACTION - LAW JURY TRIAL DE]\IlANDED No. 2002-3672 Cilvil 19 1. State matter to be argued (i.e., plaintiWs motion for new trial, defendant's demurrer to compliant, etc.): Defendant Flying J Inc., Motion for Sanctions 2. Identify counsel who will argue case: (a) for Plaintiff: Christopher Goins (b) for Defendant: Joseph F. Murphy, Esquire 3. ] will notify all parties in writing within two days that this case has been listed for argument._ Dated: September 10, 2003 o ~~~ ~~v;. /. ~l" ~; ~ ;-;~ ; ,;..' (.::- (..-J U) "'"?1 ..;:-, ,-.,-, ,-,.~ -"",' -=> CD -.. C) "'i'\ CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INe. and FLYING J TRAVEL PLAZA, Defendants CNIL ACTION - LAW JURY TRiAL DEMANDED MOTION OF DEFENDANT. FLYING J. INC.. ET. AL. FOR SANCTIONS AGAINST PLAINTIFF I. This civil action arises out of an alleged slip and fall that occurred on August I, 2000 in the restroom of Defendant's restaurant. (See Plaintiff's Complaint at ~ 5). 2. On or about July 31, 2002, Plaintiff commenced this action by the filing of a Complaint. 3. On or about August 14,2002, Moving Defendant served Plaintiff with Interrogatories and a Request for Production of Documents. (A llrue and correct copy of this discovery and the answers of Plaintiff's counsel are attached hen:to as Exhibit "A"). 4. Prior to receiving the answers of Plaintiff's counsel to the aforementioned discovery, Defendant scheduled the deposition of Plaintiff to take place on November 19, 2002; however, the deposition was postponed, because Plaintiff had not provided verified answers to Defendant's written discovery. (A true and correct copy of the Notice of Deposition is attached hereto as Exhibit "B"). 5. On or about January 16, 2003, Defendants filed a Motion to Compel Plaintiffto provide verified answers to Defendant's written discovery. 6. On January 23,2003, this Honorable Court entered an order directing Plaintiff to show cause within twenty days why Defendant's Motion to Compel Verified Answers to Defendant's Written Discovery should not be granted. 7. On or about January 27,2003, counsel for Defendants served upon Plaintiffs counsel, via certified mail, a copy of the Court's Rule to Show Cause/Order. The return receipt was signed by "B. Moyer" on January 28,2003 and returned. (A true and correct copy ofthe January 27,2003 correspondence and return receipt is attached hereto as Exhibit "C"). 8. The twenty day deadline for Plaintiff to show cause why Defendant's Motion to Compel should not be granted expired on February 16, 2003. 9. On March 11,2003, Defendant's filed a Motion for Sanctions Against Plaintiff. 10. By Order dated March 14, 2003, the Honorable Kevin A. Hess granted Defendant's Motion and directed Plaintiff to respond to all outst,mding discovery within thirty days of service of the Order. 11. On March 14, 2003, Plaintiffs counsel filed a Petition for Leave to Withdraw as Counsel for Plaintiff and averred therein that Plaintiff moved from his previous address, did not provide any forwarding address, did not file a forwarding address with the United States Postal Service, had his phone disconnected, and never made any attempt to contact his counsel, despite counsel's efforts to reach him. 12. In the Petition to Withdraw, Plaintiffs counsel averred that, in light ofthe foregoing, Plaintiff was unable to provide verified answers to Defendant's written discovery and could not produce Plaintiff for a deposition. 13. On or about June 4,2003, the unverified answers of Plaintiffs counsel to Defendant's discovery was served. (A true and correct copy of Plaintiffs counsel's cover letter is attached hereto as Exhibit "D"; see also Exhibit "A"). 2 14. On June 19,2003, counsel for the Defendant sent a letter to Plaintiffs counsel requesting that Plaintiff provide verified answers to Defendant's discovery. (A true and correct copy of the June 19,2003 letter is attached hereto as Exhibit nEn). 15. On June 22, 2003, the Honorable Kevin A. Hess granted the Motion of Plaintiffs counsel to withdraw as counsel for Plaintiff; however, the proposed Order provided misidentified counsel's client. (A true and correct copy of the Order is attached hereto as Exhibit npn). 16. On June 24, 2003, Defendant filed a Motion for Sanctions, requesting that Plaintiff be precluded from introducing at trial any evidence that is the subject of Defendant's written discovery in light of Plaintiffs failure to provide full, complete, and verified answers to Defendant's discovery in compliance with this Court's March 14,2003 Order. 17. On July 7,2003, Plaintiffs counsel filed a second Petition to Withdraw as Counsel for Plaintiff. 18. On July 8, 2003, the Honorable Kevin A. Hess entered an Order scheduling argument on Defendant's Motion for Sanctions to be set for July 23, 2003. 19. On July 21,2003, Defendant's filed a Motion to withdraw their Motion for Sanctions and to remove the matter from the Argument List in light of Plaintiffs counsel's Motion to Withdraw as Counsel for Plaintiff which was granted by the Honorable Kevin A. Hess on July 22,2003. 20. On or about August 14, 2003, Plaintiffs counsel filed a Petition to File an Amended Order in order to properly identify counsel that was withdrawing from the case. 21. An Amended Order was issued by the Honorable: Kevin Hess, on August 25, 2003, permitting Plaintiffs counsel to withdraw as counsel for Plaintiff. 3 22. More than five months have passed since Judge Hess' Order directing Plaintiff to serve full, complete, and verified answers to Defendant's discov(:ry, and Plaintiff still has not provided full, complete, and verified answers to Defendant's written discovery. 23. Furthermore, Plaintiffs deposition was previously scheduled by Defendant's and Plaintiffs counsel as represented that he is unable to produce Plaintiff for a deposition. 24. Rule 4006 of the Pennsylvania Rules of Civil Procedure provides that" [A ]nswers to Interrogatories shall be in writing and verified." Pa. R.C.P. 4006. 25. Pursuant to Rule 4007.1 of the Pennsylvania Rul(,s of Civil Procedure, Defendants are entitled to depose Plaintiff by oral examination. 26. Moving Defendants have been prejudice by Plaintiffs failure to comply with the Pennsylvania Rules of Civil Procedure in that Moving Defendant's have been unable to adequately prepare a defense to Plaintiffs lawsuit since suit was instituted. 27. Rule 4019 of the Pennsylvania Rules of Civil Procedure provides as follows: Rule 4019. Sanctions. (a)(1) The Court may, on Motion, make appropriate order if (i) a party fails to serve answers, sufficient answers or objections to written interrogatories under Rule 4005; (v)(i)(i) a party, in response to a request for production or inspection made under Rule 4009, fails to respond that inspection will be permitted as requested or fails to permit inspection as requested; (v)(i)(i)(i) a party or person otherwise fails to make discovery or to obey an Order of Court respecting discovery; (c) the Court, when acting under subdivision (a) of this Rule, may make 4 (2) an order refusing to allow the disobedient party to support or oppose designated claims or defenses, or prohibiting such party from introducing in evidence designated documents, things or testimony, or from introducing evidence of physil;al or mental condition; (3) an order striking out pleadings or parts thereof... or entering a judgment of non pros or by default against the disobedient party or party advising the disobedience; (5) such order with regard to the failure to make discovery as is just. Pa. R.C.P. 4019. 28. Plaintiff's failure to comply with the Pennsylvania Rules of Civil Procedure and this Court's March 14, 2003 Order is dilatory and evinces abject indifference to the Rules of Civil Procedure and the authority of this Court. 29. Moving Defendants are simply unable to adequately prepare a defense to Plaintiff's lawsuit without Plaintiff's Answers to Discovery and Oral Testimony. 30. Moving Defendant specifically requests that this Honorable Court impose Sanctions upon Plaintiff for failure to comply with the Rules of Discovery and this Court's March 14, 2003 Order. 31. Specifically, Moving Defendants respectfully ask that this Court enter an Order granting judgment of non pros against Plaintiff, with prejudice, as this Court is permitted to do pursuant to Rule 4019 (c)(3). 32. In the alternative, Moving Defendant respectfully asks that this Court enter an Order precluding Plaintiff from introducing at trial any evidence: that is the subject of Defendant's written discovery, as this Court is permitted to do pursuant to Rule 4019. 5 WHEREFORE, Moving Defendants, Flying J Inc., respe:ctfully request that this Honorable Court enter judgment of non pros in favor of Defendants and against Plaintiff, with prejudice; or in the alternative enter an order precluding Plaintiff from introducing at trial any evidence that is the subject of Defendant's written discovery. Respectfully submitted, MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN DATE: 9/1 7/(j) BY: ~.11 JOEfI. r.. o. 78119 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3509 Attorney for Defendant Flying J, Inc. 6 CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CNIL ACTION - LAW JURY TRIAL DEMANDED ORDER AND NOW THIS day of , 2003, upon consideration of Defendants' Motion for Sanctions, it is hereby ordered that said Motion is granted. It is hereby ordered that ajudgment of non pros is entered in favor of Defendants and against Plaintiff, with prejudice. BY THE COURT: J. CHRISTOPHER GOINS, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CNIL ACTION ~ LAW JURY TRIAL DEMANDED ORDER AND NOW THIS day of , 2003, upon consideration of Defendants' Motion for Sanctions, it is hereby ordered that said Motion is granted. It is hereby ordered that Plaintiff shall be precluded from introducing at trial any evidence that is the subj ect of Defendant's Interrogatories and Request for Production of Documents. BY THE COURT: J. CHRISTOPHER GOINS, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED RULE TO SHOW CAUSE AND NOW THIS day of , 2003, upon consideration of Defendants' Motion for Sanctions, it is hereby ordered that Plaintiff is ordered to show cause why Defendants' Motion for Sanctions should not be granted. The Rule is returnable within twenty days. BY THE COURT: J. , , \05_ A ILIABITJM\LLPGI! 02257\JMFlI5000\50000 CHRISTOPHER GOINS, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA o c ;;,-- No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION- LAW ct:;: -. JURY TRIAL DEMANDED ;/ (,'" c ~.: . C,) PLAINTIFF1S ANSWERS TO INTERROGATORIES OF DEFENDANT, FLYING J INC., ADDRESSED TO PLAINTIFF 2":>: >~(,-. H :'::"i :"':"1 -:;;, (jj :'0 Definitions. -- The following definitions are applicable to these standard interrogatories: "Document" means any written, printed, typed, or other graphic matter of any kind or nature, however produced or reproduced, including photographs, microfilms, phonographs, video and audio tapes, punch cards, magnetic tapes, discs, data cells, drums, and other data compilations from which information can be obtained. "Identify" or "Identity" means when used in reference to -- (1) A natural person, his or her: (a) Full name; and (b) Present or last known residence and employment address (including street name and number, city or town, and state or county); (2) A document: (a) Its description (e.g., letter, memorandum, report, etc.), title, and date; (b) Its subj ect matter; (c) Its author's identity; (d) Its addressee's identity; (e) Its present location; and (f) Its custodian's identity; (3) An oral communication: (a) Its date; (b) The place where it occurred; (c) Its substance; (d) The identity of the person who made the communication; ( e) The identity of each person to whom such communication was made; and (f) The identity of each person who was present when such communication was made; (4) A corporate entity: (a) Its full corporate name; (b) Its date and place of incorporation, if known; and ( c) Its present address and telephone number; (5) Any other context: A description with sufficient particularity that the thing may thereafter be specified and recognized, including relevant dates and places, and the identification of relevant people. entities, and documents. "Incident" means the occurrence that forms the basis of a cause of action or claim for relief set forth in the complaint or similar pleading. "Person" means a natural person, partnership, association, corporation, or governmep.tal agency. Standard Instructions. -- The following instructions are applicable to these standard interrogatories: (1) Duty to answer. -- The interrogatories are to be answered in writing, verified, and served upon the undersigned within 30 days of their service on you. Objections must be signed by the attorney making them. In your answers, you must furnish such information as is available to you, your employees, representatives, agents, and attorney. Your answers must be supplemented and amended as required by the Pennsylvania Rules of Civil Procedure. (2) Claim of privilege. -- With respect to any claim of privikge or immunity from discovery, you must identify the privilege or immunity asserted and provide sufficient information to substantiate the claim. (3) Option to produce documents. -- In lieu of identifying documents in response to these interrogatories, you may provide copies of such documents with appropriate references to the corresponding interrogatories. 1. General. 101. Personal information. -- State: (a) Your full name; (b) Each other name, if any, which you have used or by which you have been known; (c) The name of your spouse at the time of the accident and the date and place of your marriage to such spouse; (d) The address of your present residence and the address of each other residence which you have had during the past five years; ( e) Your present occupation and the name and address of your employer; (t) Date of your birth; (g) Your Social Security number; (h) Your military service and positions held, if any; and (i) The schools you have attended and the degrees or certificates awarded, if any. 102. Insurance. -- If you are covered by any type of insurance, including any excess or umbrella insurance, that might be applicable to the incident in this matter, state the following with respect to each such policy: (a) The name of the insurance carrier which issued the policy; (b) The named insured under each policy and the policy number of each policy; (c) The type(s) and effective date(s) of each policy; (d) The amount of coverage provided for injury to each person, for each occurrence, and in the aggregate for each policy; and (e) Each exclusion, if any, in the policy which is applicable to any claIm thereunder and any reasons, if any, why you or the carrier claim the exclusion is applicable. 103. Expenses. -- List and describe all expenses and losses that you have incurred because of the incident. 104. Factual basis for claims and defenses. -- State with parti<;ularity the factual basis for each claim or defense you are asserting in this case. 105. Witnesses. -- (a) Identify each person who (1) Was a witness to the incident through sight or hearing and/or (2) Has knowledge of facts concerning the happening of the incident or conditions or circumstances at the scene ofthe incident prior to, at the time of, or after the incident. (b) With respect to each person so identified, state that person's exact location and activity at the time of the incident. 106. Statements. -- If you know of anyone that has given any statement (as defined by the Rules of Civil Procedure) concerning this action or its subject matter, state: (a) The identity of such person; (b) When, where, by whom, and to whom each statement was made, and whether it was reduced to writing or otherwise recorded; and (c) The identity of any person who has custody of any such statement that was reduced to writing or otherwise recorded. 107. Reports of incident. -- Identify the documents (except reports of experts subject to Pa.R.C.P. No. 4003.5) which describe the incident or the cause thereof. 108. Demonstrative evidence. -- If you know of the existence of any photographs, motion pictures, video recordings, maps, diagrams, or models relevant to the incident, state: (a) The nature or type of such item; (b) The date when such item was made; ( c) The identity of the person that prepared or made each item; and (d) The subject that each item represents or portrays. 109. Trial preparation material. -- If you, or someone not an (:xpert subject to Pa.R.C.P. No. 4003.5, conducted any investigations of the incident, identify: (a) Each person, and the employer of each person, who conducted any investigation(s); and (b) All notes, reports or other documents prepared during or as a result of the investigation( s) and the persons who have custody thereof. 110. Trial witnesses. -- Identify each person you intend to call as a non-expert witness at the trial of this case, and for each person identified state your relationship with the witness and the substance of the facts to which the witness is expected to testify. 111. Expert witnesses. -- Identify each expert you intend to call as a witness at the trial of this matter, and for each expert state: (a) The subject matter about which the expert is expected to testify; and (b) The substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for l~ach opinion. (You may file as your answer to this interrogatory the report of the expert or have the interrogatory answered by our expert.) 112. Trial exhibits. -- Identify all exhibits that you intend to use at the trial of this matter and state whether they will be used during the liability or damages portions of the trial. 113. Books, magazines, etc. -- If you intend to use any book, magazine, or other such writing at trial state: (a) The name of the writing; (b) The author of the writing; (c) The publisher of the writing; (d) The date of publication of the writing; and ( e) The identity of the custodian of the writing. 114. Admissions. -- If you intend to use any admission(s) of a party at trial, identify such admission(s). 2. Personal injury. 201. Injuries and diseases alleged. n Identify all injuries or diseases that you allege you suffered as a result of the incident. 202. Prior or subsequent injuries or diseases. -- If, either prior to or subsequent to the incident, you suffered any injury or disease in those portions of th(: body claimed by you to have been affected by the incident, state: (a) The injury or disease you suffered; (b) The date and place of any accident, if such injury or disease was caused by an accident; ( c) The identity of hospitals, doctors, or practitioners who rendered treatment or examination because of such injury or disease; and (d) The identity of anyone against whom a claim was made, and the tribunal and docket number of any claim or lawsuit that was filed in connection with such injury or disease. 203. Medical treatment. -- If you received medical treatment or examination (including x-rays) because of injury or disease you suffered as a result of the incident, state: (a) The identity of each hospital at which you were treated or examined; (b) The date on which each such treatment or examination at a hospital was rendered, and the charge by the hospital for each; (c) The identity of each doctor or practitioner by whom you were treated or examined; (d) The date on which each such treatment or examination by a doctor or practitioner was rendered, and the charge for each; and (e) The identity of any document(s) (except reports of experts subject to Pa.R.C.P. 4003.5) regarding any medical treatment or examination, setting forth the author and date of such document(s). 204. Earnings before the incident. -- For the period of three years immediately preceding the date of the incident, state: (a) The name and address of each of your employers or, if you were self- employed during any portion of that period, each of your business addresses and the name ofthe business while self-employed; (b) The dates of commencement and termination of each of your. periods of employment or self-employment; (c) The nature of your occupation in each employment or self-employment; and (d) The wage, salary, or rate of earnings received by your in each employment or self-employment, and the amount of income from employment and self- employment for each year. 205. Earnings after the incident. -- If you have engaged in one or more gainful occupations subsequent to the date of the incident, state: (a) The name and address of each of your employers or, if you were self- employed at anytime subsequent to the incident, each of your business addresses and the name of the business while self-employed; (b) The dates of commencement and termination of each of your periods of employment or self-employment; ( c) The nature of your occupation in each employment or self-employment; (d) The wage, salary, or rate of eamings received by you in each employment or self-employment, and the amount of income from employment and self- employment for each year; and (e) The date(s) of any absence(s) from your occupation resulting from any injury or disease suffered in this incident and the amount of any earnings or other benefits lost by you because of such absence(s). 206. Limitation of duties and activities after the incident. -- If, as a result of this incident, you have been unable to perform any of your customary occupational duties or social or other activities in the same manner as prior to the incident, state with particularity: (a) The duties and/or activities you have been unable to perform; (b) The periods of time you have been unable to perform; and ( c) The identity of all persons having knowledge thereof. 207. Substance impairment. n If you consumed any alcoholic beverage, sedative, tranquilizer, marijuana, cocaine, hashish, or other drug, medicine or pill during the eight hours immediately preceding the incident, state: (a) The nature, amount, and type of item consumed; (b) The amount of time over which consumed; (c) The identity of any and all persons who have any knowledge as to the consumption of those items; and (d) The identity of the physician or medical practitioner or other person who gave, purchased or prescribed any of said items, if any. 208. With respect to the allegations set forth in Plaintiffs Complaint at Paragraph 5, to wit that on August 1,2000 at approximately 2:00 a.m. Plaintiff was proceeding to the restroom of the restaurant at Flying J Travel Plaza, state when Plaintiff first arrived on August I, 2000 at the Flying J Restaurant, by whom Plaintiff was accompanied, if anyone at that time, and the route of travel and/or path of travel from the point that Plaintiff began to proceed to the restroom up until the point where Plaintiff fell as alleged. 209. State whether Plaintiff was carrying anything in either or both of his hands at the time of the slip and fall incident alleged in his Complaint at Paragraph 5. 210. State whether Plaintiff observed one or more "wet floor" warning signs or any other warning signs in the vicinity of the area where Plaintiff alleges at Paragraph 5 in his Complaint that he had fallen on August 1,2000 at approximately 2:00 a.m. 211. State whether Plaintiff had ever before August I, 2000 patronized the Flying J Restaurant located at 1501 Harrisburg Pike, Carlisle, Pennsylvania and if so identify all dates on which Plaintiff had previously patronized this restaurant facility. DATE: (\\J(t--. 14-, 'lc:JJ?'" BY: Respectfully submitted, MARSHALL, DENNEHEY, WARNER, ~OL & OG o T { . J.D. No. 5291 4200 Crums Mill Road, Suite B Harrisburg, P A 17112 (717) 651-3505 Attorney for Defendant, Flying J Inc. 101. (a) Christopher S. Goins (b) None that counsel is aware of. (c) Unknown at this time. (d) 5316 Dogwood Road Baltimore, Maryland 21207 (e) unknown at this time (f) unknown at this time (g) 212-02-9910 (h) none. (i) No degrees awarded. 102. Undersigned counsel is not aware of any available insurarlce coverage. 103. Medical expenses of$I,870.15 104. Plaintiff fell on a wet floor that was not properly identifi(:d so as to avoid said danger. 105. (a) Christopher Goins (I) Vicitm; witnesses by experience (2) Has knowledge of the facts (b) Robin Smith (I) Eyewitness to accident (2) Has knowledge offacts of the accident (c) Rhonda Scott (I) Witness to the accident (2) Has knowledge of the facts of the accident 105 (b). (I) Robin Smith: was sitting at Plaintiffs table and witnessed the fall. (2) Rhonda Scott: was sitting at Plaintiff s table and witnessed the fall. 106. Undersigned believes that Plaintiff gave a recorded statement to Defendant's insurance carrier. 107. Undersigned is not in possession of any such reports. 108. Undersigned believes that photos were provided by previous counsel to Defendant's . . msurance camero 109. No investigation conducted at this time. 110. Witnesses identified in response to answer to #105. 280094-1 Ill. None at this time. Plaintiff shall supplement these answers pursuant to the Rules of Civil Procedure should they become available. 112. None at this time. Plaintiff shall supplement these answers pursuant to the Rules of Civil Procedure should they become available. 113. None at this time. Plaintiff shall supplement these answers pursuant to the Rules of Civil Procedure should they become available. 114. None at this time. Plaintiff shall supplement these answers pursuant to the Rules of Civil Procedure should they become available. 20 I. Plaintiff suffered open head injuries that required staples to close. Plaintiff also experienced headaches and blurred vision. To the best of counsel's knowledge, Plaintiff continues to receive medical care. 202. No prior injuries. 203. (a) Carlisle Hospital (b) 8/1/00 (c) Dr. Guarrac (d) 8/1/00 (e) Provided (a) Dr. Blumsom (b) 11120/00 (c) Dr. Blumson, aD (d) 11/20/00 (e) Provided (a) Carlisle Imaging Assoc. (b) 8/1/00 (c) Unknowm (d) 8/1/00 (e) Provided 204. Undersigned will supply this information to counsel when available. 205. See response to request #204. 206. See response to request #204. 207. Unknown. It is the belief of undersigned counsel that Plaintiff had not consumed alcohol or other substances. 280094-1 208. Plaintiff was accompanied by the witnesses identified in response to request #105. Undersigned will supplement this answer pursuant to the Pennsylvania Rules of Civil Procedure when additional information is available. 209. Plaintiff was not carrying any objects. 210. Plaintiff did not observed any "wet floor" signs. 211. Plaintiff had not been patron of the Flying J prior to the night in question. 280094-1 VRRTFTCATTON The undersigned hereby certifies that he is the attorney for Christopher Goins and that the facts in the foregoing Plaintiff s Answers to Interrogatories of Defendant Plying J, Inc. are true and correct to the best of his knowledge, information and belief, and that said matters relating to Plaintiffs Answers to Interrogatories of Defendant Plying J, Inc. are as known to the undersigned as to the client, Christopher Goins, said knowledge being based upon information contained in the file in this matter, and further states that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. ~(;-/, ~ Andrew W. Norfleet, Esquire Date: May 9, 2003 280781-1 \05 _A ILIAB\TJMILLPG\l 02259\IMF\15000\50000 CHRISTOPHER GOINS, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL AcnON -- LAW ~, JURY TRIAL DEMANDED PLAINTIFFwS RESPONSE TO !~,I ~ :.J1 -<- () ; :.-<: PLEASE TAKE NOnCE that you are hereby requested to produce for inspection and other REOUEST FOR PRODUCTION OF DOCUMENTS ADDRESSED TO PLAINTIFF g::. ! ~-.:_. I,. ~~ ~. -' [""'J '- purposes, including copying, pursuant to the Pennsylvania Rules of Civil Procedure, at the office of the counsel for the requesting party, or at such other location as may be mutually agreeable between counsel for you and counsel for the requesting party, not less than thirty (30) days after service of these requests, documents herein cited. The word "document" or "documents" as herein used includes but is not limited to photographs, video tapes, drawings, reports, statements and memoranda, as well as all other documents as defined in the Rules. I. All documents in your possession, control or custody constituting, relating to, or pertaining to the documents identified in response to Defendant's Interrogatories. 2. All medical bills, reports, records, and x-rays, relating to the injury allegedly sustained in the occurrence described in the Complaint, as well as all medical bills, records, and reports relating to prior or subsequent injuries to the same parts of the body claimed by Plaintiff to have been injured in the occurrence described in the Complaint. 3. All employee reports, records, tax returns from 1996 to the present, attendance records, and wage statements relating to the claim ofloss of income as a result of the occurrence described in Plaintiffs Complaint. 4. Copies of all statements, memoranda, summaries of other writings, documents, diagrams and pictures obtained from your investigation, your insurance company's investigation, or your attorney's investigation into the incident involved. (You need not supply any attorney's "work product" or other material which is specifically accepted as privileged by the above Rules). 5. All documents in your possession, custody or control prepared in anticipation of litigation or trial of this case, except those documents which disclose the mental iInpressions of your attorney or your attorney's conclusions, opinions, memoranda, notes or summaries, legal research or legal theories, and except those documents prepared in anticipation of litigation by your representatives to the extent that they would disclose the representatives' mental impression, conclusions or opinions respecting the value or merit of the claim or defense. 6. To the extent that you have not already provided the same in response to previous requests herein, all statements obtained from any witnesses or memoranda of cOIlversationswith witnesses or recordings of witnesses' statements memoranda, or recordings made by parties to this lawsuit or their representative. 7. To the extent not already provided in response to previous requests herein, all statements made by any party to this action, including written statements signed or otherwise adopted or approved by the person making it or stenographic, mechanical, electrical, or other re,;ording or transcription thereof, which is a substantially verbatim recital of an oral statement and contemporaneously recorded, as allowed by Pennsylvania Rules of Civil Procedure No. 4003.4. 8. To the extent that you have not already provided the same, copies of all records, documents and memoranda, which have any bearing upon the matters alleged against the requesting party or upon the responsibility of the requesting party for the matters alleged against the requesting party. 9. To the extent not already provided, all reports of those experts who are to be called by you as witnesses at trial, which reports made or secured by you in connection with your investigation of the matters relating to this lawsuit. 10. To the extent not already provided, copies of all experts' Jreports made or secured by you in connection with your investigation of the matters relating to this lawsuit. II. To the extent not already provided, all photographs, diagrams, maps, surveys, plans and models of the site of the incident in question that are in your possession. 12. To the extent not already provided, all documents containing the names and addresses of witnesses or potential witnesses with the exception of material described above, specifically correspondence privileged by the above rules. 13. To the extent not already provided, copies of all exhibits which you intend to offer into evidence at the trial of this matter. 14. The shoes or other footwear, as applicable, which you were wearing on August 1,2000 at approximately 2:00 a.m. DATE: AoCs. Ii I 2007- Respectfully submitted, MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN BY: t..J-~ ,~ TIM~h::~ON, ESQUIRE I.D. No. 52918 4200 Crurns Mill Road, Suite B Harrisburg, P A 17112 (717) 651-3505 Attorney for Defendant, Flying J Inc. I. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 2. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 3. Requested documents not available at this time. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 4. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 5. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 6. None available. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 7. None available. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 8. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 9. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 10. None available at this time. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 11. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 12. Provided. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 13. None available at this time. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 14. Unknown at this time. Plaintiff will supplement this request pursuant to the Pennsylvania Rules of Civil Procedure. 280095-1 Irll~le, nc;spllal .- emergency uepanmenl l\ Parker St. Carlisle, PA 17013 -- (717) 245-5500 9.9'"s. cnrlstoPher 81'1f00 2:46am 843798 SPOSITION SUMMARY Patient: ooins, christopher SS#: CURRENT Address City: Age/DOB: _ Current Ph: Medical Record: 843798 Zip: Arrival: 8/1/00 2:46am Disch: 8/1/00 6:47am Disposition: MD ED: A.J. Guarracino. DO PMD: Res/PAlNP: PMD Ph: Dx #1: Laceration (Unspecified Site) ICD-9 #1: 870-897 ? #1 Dx Engl: LACERATS,ESW Dx #2: Closed Iniurv Head. Unspecified Consciousness State ICD-9 #2: 854,00 #2 Dx Engl: HEADINJ.ESW Dx #3: Cervical Strain ICD-9 #3: 847,0 #3 Dx Engl: SPNECK.ESW Med Inst, Ibuprofen #1 Dx Span: LACERATS.SSW #2 Dx Span: HEADINJ.SSW #3 Dx Span: SPNECK.SSW Med #1 Engl: IBUPROFE.EDP Rx #1: Ibuprofen 400 mo 1 tablet bY mouth eyerv 4 to 6 hours as needed.with food #30 tablets mmm Follow-up: YOUR FAMILY DOCTOR F/U MD Ph: F/U Drr: 4 Days Other Instr: seek medical attention immediatelv if sions of wound infection or concussion as described in printed instructions. keep wound clean and applY bacitracin ointment dailY for 5 days. staoles out in 7-10 days. May retum to work/school: 8/3/00 ~Y SIGNATURE BELOW INDICATES: I have received and understood the oral instructions regarding my current lledical problem. I will arrange follow-up care as instructed above. J 1 acknowledge receipt of the written instructions as outlined on this and \....~' ~"C ,ny previous pagels). I will read and reYiew these instructio~s~ -\1.- -y;/ I.Y";: J X ~vJ. t'Yl~k 'atient (or Legal Guardian) Signature Staff (Witness) Signature Name of Attending PhYSi~ ~ Date of Admission: j I. 6 0 1 t I, (0 ~ Carlisle Hospital and ~, Health Services,. CONSENT T9 HOSPITAL ADMISSION AND C;;E~ TREATMENT Time: (AM) (PM) acting on behalf oD ~meof Authorized Representative , .\Itf&ill!l from a condition requiring hospital care, hereby consent to rendering of such ame of Pent care, ,which may include routine diagnostic procedures and such medical treatment as the named attending physician (s) or other of the hospital's medical staff consider to be necessary. 2. I understand that the practice of medicine and surgery is not an exact science and that diagnosis and treatment may involve risks of injury, or even death. I acknowledge that no guarantees have been made to me as to the result of examination or treatment during this hospitalization. 3. I understand that: (A) It is customary, absent emergency or extraordinary circumstances, that no substantial procedures are perfonned upon a patient unless and until he or she has had an opportunity to discuss them with the physician or other health professional to the patienfs satisfaction; (8) Each patient has the right to consent, or to refuse consent, to any proposed procedure or therapeutic course; and (e) No patient will be involved in any research or experimental procedure without his or her full knowledge and consent. 4. I understand that many of the physicians on the staff of this hospital, including the attending physician(s) named al-ove, are not employees or agents of the hospital but, rather, are independent contractors who have been granted the privilege of using its facilities for the care and treatment of their patients. Further, I realize that among those who attend patients at this hospital are medical, nursing, and other health care personnel in training who, unless requested olherwise, may be present during patient care as a part of their education. Still or motion pictures and closed circuit television monitoring of patient care also may be used for educational purposes or for documentation of the clinical course unless a patient expressly requests otherwise. 5. I release CARLISLE HOSPITAL from all responsibility for all arti~!cs which I am retaining or will have with me during my stay at the hospital. I understand this includes clothing, bridgework. ~alse teeth, eyeglasses, jewelry, money, radio, razor or any other item kept in my possession. I understand I may deposit valuables in a safe provided by the hospital; only if this is done will the hospital assume any responsibility for the safekeeping. 6. I hereby acknowledge that I have received written infonnation on the topics of Patient Rights and Advance Directives. f) ~ J <:..JtJ Date of Signature: i.!.1 ( I (SIGNATURE OF PATIENT) (If patient is unable to consent or is a minor, compete the following): Patient (i years of age) (is unable to consent because): (SIGNATURE OF WITTNESS) -.. ~-rc.....<:"""" '" (SIGNATURE OF WITNESS) ~ E OF LEGAL GUARDIAN R CLOSEST AVAILABLE RELATNE) AD 0315 (10/91) PATIENT IDENTIFICATION NAME: (~h r l.s !voher bO ilLS I MEDICALRECORD#: gl/379f ~ /; / (JO J / DATE: g / ~~b DATE OF SERVICE: 1. FOLLOW UP ISSUE: f' Yrd-lc1- h'f1(;(/~_ ~ 2. ACTION: I~t-h ~I: /!L~ !fs~'A;}~LAN~H" boafm I ) 3. PATIENT NOTIFICATION: 1. Time/Date: 2. Time/Date: 3. Time/Date: 4. PRIMARY CARE PHYSICIAN NOl1J<lED: DYes D No Time/Date: 5. SIGNATURES: Physician ::JOhn Coy Le TirneIDate: Nurse: Time/Date: .J ~ Carlisle Hospital EMERGENCY DEPARTMENT FOLLOW-UP FORM PATIENT IDENTIFICATION ER 0630 (9/98) C{t{.Ir.5-bpAe-,~ Go'-~ IP-/J-o/70 hr- (~iG BLf3 7f b ~ti PATIENT IDENTIFICATION NAME: CrI",.,;;:::s-ro PI-€f'2... 0~-=::N~ DATE: '71/ IS- I MEDICAL RECORD #: :;>43"1- '13" DATEOFSERVlCE: . ?)/ 1. FOLLOW UP ISSUE: ~p_ h'1- ..z:-'~ ~~ ...6--- ~ -~ ;:r' J_./~ ~. ~ .-& /?~--77 --6 L'7 /"'~ - ./,~ ~....~.?zr _J;.' o. ~ pi' ~ ~'6T 2. ACTION: ~ L-~~ /" 3. PATIENT NOTIFICATION: 1. Time!Date: J-/ / S cP t4-rr? 2. TimeIDate: 3. Time!Date: 4. PRIMARY CARE PHYSICIAN NOTIFIED: DYes iArNo TimeIDate: 5.mGNA~ Physic' e~ Nurse: Tirne/Date: 0//5 Time!Date: ~ Carlisle Hospital EMERGENCY DEPARTMENT FOLLOW-UP FORM PATIENT IDENTIFICATION ER 0630 (9/98) ~ Carlisle Hospital and Health Services 246 Parker Street. P.O. Box 310. Carlisle, Pennsylvania 17013-0310. (717) 249-1212 DEPARTMENT OF RADIOLOGY CARLISLE IMAGING ASSOCIATES, P.C. GOINS, CHRISTOPHER 5316 DOGWOOD ROAD BALTIMORE, MD 21207 29Y 08/01/2000 X-RAY #150959 MED. REe. #843798 DR. GUARRACINO. ANTHONY CERVICAL SPINE This study is slightly lim~ted by the patient's condition. No subluxation or fracture seen, Soft tissue prominence in the nasal pharynx is probably due to adenoid tissue. IMPRESSION: Negative cervical sp1ne. The study is mildly limited. CHEST There is prominence of the pulmonary arterial segment of the mediastinal silhouette. This is more prominent than is usually seen. It raises the possibility of enlargement of the main pulmonary artery, as could occur with valvular disease. This does not have the configuration of an enlarged aorta and there is no upper mediastinal widening to suggest hemorrhage. The lungs and costophrenic angles are clear with acute disease. There is a small nodule projecting in the left mid lung field with the diameter of approximately 6 mm in a young patient. This would presumably represent a scar. The visualized bones are grossly intact. IMPRESSIONS: Abnormally prominent pulmonary arterial segment of the cardiac silhouette to suggest further evaluation. DAVID R. ~y,z..L' I M.D. DRR/bks D: 08/01/2000 - 10:17 am T: 08/02/2000 - 03:34 pm RADIOLOGY FILE ..lisle Hospital -- Emergency Department 16 P'i'rker St.. Carlisle, PA 17013 - (717) 245-5500 Patient: Qoins. christopher MD ED: A.J. Guarracino. DO ResIPAlNP: FTERCARE INSTRUCTIONS Ie are pleased to have been able to provide you with emergency care. Please review these instructions when you return ome in order to better understand your diagnosis and the necessary further treatment and precautions related to your )ndition. Your diagnoses/prescriptions today are: Disch: 8/1/00 6:47am Medical Record: 843798 Dx #1: Laceration (Unspecified Site) Dx #2: Closed Iniurv Head. Unspecified Consciousness State Dx #3: Cervical Strain Med Instr #1: Ibuprofen Rx #1: Ibuprofen 1 tablet bv mouth everv 4 to 6 hours as needed. with food Disp: #30 tablets 400 mQ Refill:~ General Information on LACERATIONS (CUTS) The word "laceration" is the medical term for an accidental cut in the skin. Lacerations often result from auto accidents. falls or contact with broken glass or other sharp objects. Although some lacerations are very large, most are only one to two inches long and can be easily repaired in the emergency department. Treatment usually consists of: 1. a shot of numbing medication to deaden the area around the wound, 2. opening up the wound and cleaning it with lots of water and 3. stitching the wound back together with special thread. Stitching the wound usually results in less scarring and quicker healing. What are the risks? Most lacerations heal in about two weeks and do not produce any serious medical problems. There are, however, some risks: 1. When the skin is disrupted by a laceration, germs sometimes get into the wound and start to grow and multiply. producing an infection. These wound infections occur in roughly 1 % to 3% of all lacerations and can result in serious problems. 2. Most lacerations do leave some form of a permanent scar, although it may not be very noticeable. Many scars gradually improve for the first 6 to 12 months after the initial injury. 3. Deep lacerations sometimes go into the blood vessels, tendons, nerves or bone. This can be serious. INSTRUCT/qNS 1) Keepthe wound CLEAN and dry. Cover itwitha plastic bag when bathing. 2) If the bandage gets dirty or wet, change it right away. Otherwise, you should change the bandage once a day, starting the second day after the injury. To change the bandage you should: A) remove the old bandage, B) gently wash the area with soap and water, C) if you are not allergic to it, using a Q-tip, gently apply a thin layer of antibiotic ointment and D) put on a fresh bandage. 3) Most lacerations are not painful once they have been cleaned. stitched and bandaged. Pain medications are not usually necessary. 4) Tetanus shots are good for 5 to 10 years, provided you have had all your childhood immunizations ("baby shots"). 5) SEEK IMMEDIATE MEDICAL ATTENTION if: A) you develop a fever, persistent bleeding, vomiting or B) the wound gets warm, red, swollen or tender or C) you develop red streaks on the skin near the wound or D) you notice a creamy liquid (pus) draining from the wound. 6) Be extra careful if you have a very large laceration, an animal bite, a small puncture wound or a human bite wound. These types of injuries tend to get infected more often. 7) Have the stitches removed in days by a nurse or doctor. Pg 2 General Information on HEAD INJURIES The term "head injury" refers to any injury that results from being hit on the head. Typically, there are cuts, scrapes or bruises on the face or scalp and often there is a mild headache that gets better over one to two days. More serious head injuries can also shake the brain, resulting in a momentary loss of consciousness, confusion or amnesia. This is called a concussion. Often head injuries result from motor vehicle accidents, falls or fights. What are the risks? Most minor head injuries (including mild concussions) get better over several days and do not produce any serious medical problems. There are, however, some risks: 1. If there are any cuts or scrapes, they may become infected. 2. Sometimes there is serious damage to the face, eyes, ears, jaw or teeth. 3. A serious head injury can injure the brain, resulting in permanent brain damage or even death. A serious head injury usually produces warning signs right away. On rare occasions, however, the WARNING SIGNS MAY NOT APPEAR FOR SEVERAL HOURS OR EVEN DAYS. For this reason it is important to seek immediate medical attention if any of these warning signs appear: 1. UNCONSCIOUSNESS (passing out, blacking out). 2. Unusual drowsiness. 3. Confusion. 4. A severe headache. 5. Vomiting. 6. Blurred vision. 7. Convulsions (seizures, fits). 8. A stiff neck. 9. Areas of numbness, tingling or weakness. 10. Stumbling or loss of balance. 11. Unequal size of the left and right pupils. 12. In children ALSO look for a decreased activity, trouble walking. poor feeding or fussiness. INSTRUCTIONS 1) If you are not allergic to you may acetaminophen (Tylenol) or ibuprofen (Advil) to help ease the pain. Stronger medicines are not usually required. 2) SEEK IMMEDIATE MEDICAL ATTENTION if you develop any of the warning signs listed above. 3) Unless instructed otherwise, FOR THE NEXT 24 HOURS, you should: A) stay with a friend or family member who has read this sheet and B) have someone check you every 3 to 4 hours to make sure you have not developed any of the warning signs listed above. At night they should wake you up about every 4 hours. Generallnformatlon on a 'SPRAINED NECK (Mild) The neck is formed by seven bones that are stacked on top of each other and held together by strong bands called ligaments. Any forceful bending or twisting of the neck may damage these ligaments, resulting in a "sprained neck". This is the most common cause of everyday neck pain. Neck sprains often result from auto accidents, sleeping in the wrong position, a poor posture, constant sneezing or a blow to the head or neck. Sometimes the exact cause of the neck sprain can not be determined. What are the symptoms? A sprained neck usually produces an aching or cramping pain in the back of the neck. Movement of the head usually makes this pain worse. What are the risks? Most people with a sprained neck gradually get better over several days and do not develop any serious medical problems. There are, however, some risks: 1. Some people get episodes of neck pain over and over again. This is less likely to occur if proper care is taken. 2. Exams, tests and X-rays are not 100% reliable. Although unlikely, it is always possible that the neck pain may actually be the result of another more serious medical problem such as a broken bone or an infection. This is Pg 3 I(ery uncQmmon, but it does occur. INSTRUCTIONS 1) The best thing to help reduce the pain is to avoid any activity that puts stress on your neck. Avoid leaning over, lifting. coughing or any rapid movements of the head. Laying in bed will relax the. neck even more. 2) Ice packs are sometimes helpful during the first two days. Put the ice in a plastic bag. Roll up the bag in a towel and put it on your neck for 5 to 15 minutes at a time. 3) After the first two days. warm packs may help ease the pain and speed healing. Roll up a small towel. Soak it in warm water and put it on your neck for 5 to 15 minutes at a time. 4) Maintain a good posture; this puts less stress on your neck. 5) No medicine will relieve the pain completely, but aspirin, ibuprofen (Advil) or acetaminophen (Tylenol) may help. WARNING: Do not take these drugs if you are allergic to them. Do not take these drugs if you are already taking a prescription pain medication. DON'T GIVE ASPIRIN TO ANYONE LESS THAN 18 YEARS OLD. 6) Call your doctor if the pain does not get better within a week. 7) SEEK IMMEDIATE MEDICAL ATTENTION if you develop severe neck pain, numbness, tingling or pass out. Drug Information on IBUPROFEN BRAND AND GENERIC NAMES - Advil, Medipren, Midol 200, Motrin, Nuprin, Parnprin IB, Rufen, Trendar. DOSAGE&USAGE1NFot?MATloN . Habit forming? No Prescription needed? Yes, for some brands at higher strength Available as generic? Yes Drug class: Anti-inflammatory (non-steroid) . Treatment for joint pain, stiffness, inflammation and swelling of arthritis and gout. . Pain reliever. . Treatment for dysmenorrhea (painful or difficult menstruation). . Treats juvenile rheumatoid arthritis. How to take: Tablet or capsule - Swallow with liquid or food to lessen stomach irritation. If you can't swallow whole, crumble tablet and take with liquid or food. When to take: At the same times each day. If you forget a dose: Take as soon as you remember up to 2 hours late. If more than 2 hours, wait for next scheduled dose (don't double this dose). What drug does: Reduces tissue concentration of prostaglandins (hormones which produce inflammation and pain). Time lapse before drug works: Begins in 4 to 24 hours. May require 3 weeks regular use for maximum benefit. Don't take with: See Interaction column and consult doctor. WARNINGS & PRECAUTIONS Don't take if: . You are allergic to aspirin or any non-steroid, anti-inflammatory drug. . You have gastritis, peptic ulcer, enteritis, ileitis, ulcerative colitis, asthma, heart failure, high blood pressure or bleeding problems. . Patient is younger than 15. Before you start, consult your doctor: . If you are taking aspirin, beta-blockers (high blood pressure/other), blood thinner, carteolol, cortisone drugs (steroid drugs), lithium, methotrexate, minoxidil, oxyphenbutazone, phenylbutazone, probenecid, sotalol, terazosin, thyroid hormones, water pills or any drug used to treat high blood pressure. . If you have epilepsy. . If you have Parkinson's disease. . If you have been mentally ill. . If you have had kidney disease or impaired kidney function. Over age 60: Adverse reactions and side effects may be more frequent and severe than in younger persons. Pregnancy: Studies inconclusive on harm to unborn child. Decide with your doctor whether drug benefits justify risk to unborn child. Breast-feeding: May harm child. Avoid. Infants & children: Not recommended for anyone younger than 15. Use only under medical supervision. Prolonged use: . Eye damage. . Reduced hearing. . Sore throat, fever. . Weight gain. Pg4 Ski,n & sunljght: Possible increased sensitivity to sunlight. Driving. piloting or hazardous work: Don't drive or pilot aircraft until you learn how medicine affects you. Don't work around dangerous machinery. Don't climb ladders or work in high places. Danger I;ncreases if you drink alcohol or take medicine affecting alertness and reflexes, such as antihistamines, tranquilizers, sedatives, pain medicine, narcotics and mind altering drugs. Discontinuing: Don't discontinue without consulting doctor. Dose may require gradual reduction if you have taken drug for a long time. Doses of other drugs may also require adjustment. POSSIBLE INTERACTION WITH OTHER SUBSTANCES (Combined Effect) . Alcohol: Possible stomach ulcer or bleeding. Follow-up: YOUR FAMILY DOCTOR FlU MD Ph: FlU DIT: 4 Days Other Instr: seek medical attention immediatelY if sians of wound infection or concussion as described in printed instructions. keep wound clean and apply bacitracin ointment daily for 5 days. staples out in 7-10 days. May return to work/school: 8/3/00 KGs and X-Rays: If you had an EKG or X-Ray today, it will be formally reviewed by a specialist tomorrow. If there is any lange from today's Emergency Department reading, you will be notified. IPORTANT NOTICE TO ALL PATIENTS: The examination and treatment you have received in our Emergency Jepartment have been rendered on an emergency basis only and will not substitute for definitive and ongoing evaluation md medical care. A follow-up physician has been designated for you. It is essential that you make arrangements for 'allow-up care with that physician as instructed. Report any new or remaining problems at that time, because it is mpossible to recognize and treat all elements of injury or disease in a single Emergency Department yisit. Significant ;hanges or worsening in your condition may require more immediate attention. The Emergency Department is always Jpen and available if this becomes necessary. .' ~l Catlisle Hospital 246 Parker Stred . AEG.DATEfTIME D 1\ 843798 MED. REC. NO. 08/01/00 03:29 PRE\'IOUSNAME NONE NAME I ADDRESS I PHONE f AGE I SEX I AACE I M.S GOINS, CHRISTOPHER 5316 DOGIlOOD RD BALTIMORE, MD 21207 I NAME! ADDRESS I PHONE I RELATION 100.8 ISOC SEe NO GOINS, CHRISTOPHER S. 5316 DOGWOOD RD , 'BALTIMORE, MD 21207 r--""-'-- INSUAANCE COMMENT REASON FOR VISIT lOCIITlON OF PATIENT MD (410)944 7247 S. 29Y MilS 12/20/70 000-00-0000 247 000-00-0000 FELL ON SLIPPERY FLOOR HIT BACK OF HEAD COM"'", PT TRAVELING THRU AREA IRIEF VISIT 26700 :LASS l VISIT 26710 :LASS II VISIT 26720 :LASS III VISIT 26730 :LASS IV VISIT 26740 :LASS V VISIT 26750 AINOR SUTURE EDS01 AEDIUM SUTURE EDS 02 AAJOR SUTURE EDS 03 NTUBATION EDS 04 V SET UP EDS 06 'ELVIC EXAM EDS 14 ~ITRO SET-UP EDS16 ;AST, SCOTCH SHORT ARM 26031 ;AST. SCOTCH LONG ARM 26032 ;AST, SCOTCH SHORT LEG 26033 ;AST, SCOTCH LONG LEG 26034 ;AST ROLL. PLASTER 26075 liP MONITOR 26037 'ACER PADS 79064 "'- '" CONVENIENT CARE/EMERGENCY REGISTRATION ACCIDENT DATE I TIME f'ATIENT/OTHEREf.PLOYER / GUARANTOR'S EMPLOYER REEN, NANCY (410)944-7247 9 GASTRO/HEMO SLIDE 26060 KIDDE TOURNIQUET 26048 OCL PER FOOT 79670 F.S.B.S. 80081 TUBE GAUZE PER FOOT 26074 ED STAT ESTAT PULSE OX POXED EXTENDED CHARGE I 26760 EXTENDED CHARGE II 26770 ~-------------- , I I I I I I I , '- --------------, , I I I I I I I , ----------------------------~ ,-------------- , I I I I I I , ',---------------------- ,'-------------- I I I I I I I ',-------------------- --------------, , , I I I I I I , -------, --------------', I I I I I I I , ---------, 1974005 PRE.CERT.NO UARRACINO, ANTHONY J ISOLATION ALERT N ADDITIONAL CHARGES ,'-------- -----, I I I I I I I I : A 'l'13.<i : I I , , '-.- ----------------" ,~-------- ---------, : "l73.o : I I : <jJ.j.1 : I I \ 14'1.0 J ,--------------------, -------/>----------- ( "l;:,q.Ol '. , I : el'1.S : : E'l<.{q. (.. : I I , , ,-------------------, ,--------------------, I , I I I I I I I I I I I I , , '-..- --------- -------, ~-------- --------- , , I , I I I I I I I I I I I I , , ,-.------------------, ---------, I I I I I I I , -' ,--.------- , I I I I I I ',----------------- ,---------- ---------, I ' I I I I I I I I I : I , ',--------------------, ,--------------------, : IJDOtj : I : <({".S"i : I I I I , ' ,--------------------' ---------- ---------, , , I , I I I I I I I I I I \ ) ,-------------------- ,---------- --------- I ' I I I I I ' I I I : I I ',--------------------, ,---------- ---------, I ' I I I I I I I I I : I I ',--------------------, ,~------------- -----, I ' I I I I I I I I I : I , , - ,-------------------~ ER-OSOB (REV. 6/991 ~ Carlisle Hospital A Service of Carlisle Hospital and Health Services August 8, 2000 fl./37c/2 Christopher Goins 5316 Dogwood Road Baltimore, MD 21207 Dear Mr. Goins, Please have your primary care physician contact us regarding your xray results from August 1, 2000. The number he or she should call is 717-245-5500. Johnson Coyle, M.D. Emergency Department Physician Carlisle Hospital JGClkmd 246 Park.. SIreet. P.O. Box 310. CurIis~, PA 17013-0310.71;'-249-1212 CARLISLE GOODWILL FIRE PO BOX 207 ALLENTOWN. PA 18105 IF PAYING BY MASTERCARD, DISCOVER OR VISA, FILL OUT BELOW. CHECK CARD USING FOR PA YMENT . ~STERCARD _ ~SCOVER CiC~SA CARD NUMBER I'Moum SIGNATURE EXP, DATE Account Number Inv.Date Balance Due Amt Remitted 0002927 08/14/00 $290.00 pt. Name: GOINS, CHRISTOPHER ADDRESS SERVICE REQUESTED PAGE NO. 1 1"1,1,"11"1,111".1.,,1.1.1,1,1"11,,".11.,.,11,11,,,1,,II GOINS. CHRISTOPHER 5316 DOGWOOD RD BALTIMORE, MD 21207 1".111,.1,".1111""1,1,11"",1,111".1,.,111",1,,,11,1,,1 CARLISLE GOODWILL FIRE PO BOX 207 ALLENTOWN, PA 18105 02478862 B616 Please detach and return the top portion of this STATEMENT with your payment in the enclosed enveloped. Retain the bottom portion for your records. 203-Aur DeSiination: Carlisle Hospital Amount Paid 0.00 IMPORTANT MESSAGE II Balance Due $290.00 Please complete the reverse side by providing us wit:h your insurance information and signature. Return this information using the enclosed envelope. Make Checks Payable To: CARLISLE GOODWILL FIRE SE SEE REVERSE SIDE IMPORTANT INSTRUCTIONS. IMPORTANT MESSAGE FROM YOUR PHYSICIAN This bill covers only the professional fee; Y'jU may also receive a separale hospital bill Questions? 800-666-2455 Call Monday-Friday between the hours of 9:30 AM - NOON AND 1:00 - 5:00 PM EST If insurance information or other infonnatton on this f()lm is incorrect, please correct on back of return stub. DR. GUARRAC / ER EXAM-4 DR. GUARRAC / WDUND REPAIR SERVICE AT CARLISLE HOSP-HEALTH SVC . . , . .. PAY THIS AMOUNT .. 481 IMPORTANT: rCASSURE PROPER CAEDIT, DETACH AND RETURN THE STATEMENT BelOW WITH YOUR CHECK OR MONEY ORDER PAYABLE IN us CUfl ---~- Cha,tONE. Inc. P.O. Box 1438 San Jose CA 95109-1438 (800)299-8694 INVOICE Invoice No. 101928195210 Dea, Valued Requeste,: MR # 21-74-67 Date: 01/22/2001 Pe, you, ,equest. enclosed a,e the medical reco,ds fo,wa,ded f,om st Agnes. Hospital, Baltimo,e, MD. PAYMENT IS DUE UPON RECEIPT OF THIS INVOICE. A service cha,ge of 1.5% per month (annual ,ate 18%), except Michigan state, will be cha,ged if not pa within 30 days f,om the date of this invoice. please detach the bottom po,tion of this invoice and ,eturn with your remittance to ChartONE, Inc. to ensure proper credit. Please note we accept VISA and MASTERCARD paymen If paying by credit card, please complete the necessary information below please make check payable to: ChartONE, Inc. P.O. Box 1438 San Jose, CA 95109-1438 (800) 299-8694 (Federal Tax 10#: 94-3360691) REQUESTED BY: MICHAEL KORANDA TOMASKO & KORANDA 219 STATE STREET HARRISBURG, PA 17101 (717 )238-1100 Patient '~TOPHR GO~ categor~~~~ SSN: 212-02-9910 DOB: / / DOA: / / Req'r 10: other 10: Paper Pages: 32 Micro Pages: 0 Camp Pages: 0 Clerical Fee: Basic Fee: Page Fee: Shipp:~ ng: Ha ndLl ng: Itemized: Tax: Adjus1:ment: Pre-Payment: Total Due: $ Ship to: 17.08 0.00 18.24 1.60 0.00 0.00 0.00 0.00 ~ I T: k_pJ. \hDIOI Please return this portion with your paYment payable to: ChartONE, Inc. P.O. Box 1438 San Jose CA 95109-1438 (800) 299-8694 INVOICE Invoice No. 106124103102 Dear Valued Requester: MR jj 84-37-98 Date: 12/06/2000 Per your request, enclosed are the CARLISLE HOSPITAL, CARLISLE, f'A,,';>' PAYMENT IS DUE UPON RECEIPT O~ ' rvice charge of 1.5% per month (annual rate 18%), exce- ill be charged if not paid within 30 days from the date 0 ,ease detach the bottom portion of this invo~l$i9 and return'with remittance to ChartONE, Inc. to ensure proper cr ,;., lease note we accept \IISA afld,MASTERCARD payments. If paying by credit complete the necessar;f.q.wnformation below. ;.. ,\'~',:",;:>,' ase ma ~3:chec k;;iFf'myable to: f'::'i;'~ "~R(" f')l\.u=-=1fo'~ "~ U'I"'If.-;., ;, 'Box 1 ose, C 299-:3 ral iax '" HARRISBURG, PA 17101 (717 )238-1100- FILE 95109-1438 4 wit: 94-3360691) ~. , REQUESTED BY: MICHAEL KORANDA TOMASKO & KORANDA 218 STATE ST '~" .~. Patient: Category: SSN: OB: OA: 'eq'r ID: ther ID: 3 aper Pages: cro Pages: mp Pages: CHRISTOPHE GOINS A 212-02-9910 / / / / Cle ical Fee: 15.39 Basic Fee: 0.00 Page Fee: 12.36 Shipping: 0.77 QUA D;;:;N~\1\ E d11 ~~l; 0.00 12 o o Total Due: $ 0.00 9 I~. t pA. I~IL-Ioo Pre-Payment: to: 9009920000090hElhEOOOLbhb9bh2100lb mlmlO A3NOYi lIO 11::>m1.) mOA NO 'lrnffNIlN l.NnO;:K)V mOA R.LI1IM. asv:nd UOHV ssmmav OL 'IIVW <IN:V 01. 'H'lHV J.. Vd )loma IDIVN liSVB:ld -oNl'TDH x.:>NY'tInSNI llO.i 'ilens iIlflI'iL\'irlI BHS sSIDIaav 1t\:lN.iII mr.m: ~mt:) 0 09lE~ HO snawfi~o~ SW6-~ ;Ldaa 1 Sa~I^HaS X~HaDHaHa aHOWl;L~Ya 1.1.1....11...11...11...11...11..11.1.1...11..\..1.1 LOlE <II( aHOWl;L'lYll aH aOOMDoa 9lES; SNIOD HaHdO;LSIHH~ OSO~EnE -pgIOI:l'llglunOWY OO"S9l OIlQ ,_oWV' 6S9L-L~llE ~A a~~I^HOSX~Yr 6S9n xoa "0".1 J Sa~I^HaS X~HaDHaHa aHOWI;L'lY8 06~9-S9l-00S 'OJ. SlolOIJ.S:ilJll> mII'l'lIlI J.:>:iIlUQ OSO~El~E 'mlY<flN.I.Nf10~~V SHIOD HaHdO;LSIHH;J llY<VIUNlJIJ.Vd OO/~l/ll 10/~0/10 'illva J.NaJ"i'iUVl.S 3J.VO ':IIla n..__.....n'.....__nm__......umum.. n........_..mumn.. m......h._mom ....._......mm____........m......_nnmu......nnom.__mn. .. __. __n ___._________.__ __. .lON4OlClO sn NI 'lI'IUYJ. Vi UQ'lIO A.B:NOW "10 :X::)'.nIa moA. H.IlJd 4013& .LN3P1&LV.L$ am. m.cu.n aNY HOYJ.!G 'Jlono 1I3dO'1l. nIlSSV OJ. :J.NVnOdl'il . ;LNfiOWY SIH;L XYd ..J::: 00"S9l OSO~EnE . . "XY asya~d 'aSIMHaH;LO "ado~atNa aaso a J.HaH3;LY;LS SIH;L AO 30lS ~:SlIaJ\l1lI 3SY3~d 'Sa~I^HaS 'lY~]aaw as WYHDOHd XIIY HI 3;LYdI~IJ,HYd 110 XYd lln x aHas HI ;LI NlIfi;LaH aNY a a~cDlo~ Yd ~~I H~IBM I aAYH nox AI ...... ...... ........ '. ~sa wd oo:~ 00:8Jo s.moq Ollp ~~ 1lJ>!ld- llpuoW: "'eO lSUO~ mq IVJ!dsoq ~.lll<bs 'l! ;)^!~J OS[B AnD no'~ ~J JWt'!SSQJO.Id Oltp A[UO SJ:)AOO UN S'!ttL NYI:>ISAHd 1Ill0A 1II0D 'It)YS~llll\l .lNY.lllOdJ\II . -.----" _ -.----....''''' --- - .--- U/lti.>f-UU I U1 I ll/U~/UU SORRY, WE DO NOT ACCEPT CREDIT CARDS FOR PAYMENT PO Box 100 101 Noble Blvd Ste 104 Carllskl PA 170130100 ADDRESS SERVICE REQUESTED ~ . 8STEACAAD ~ 5:SA o $ 91. 00 OTHER PAY THIS AMOUNT $ MAIL PAYMENT TO: ADDRESSEE: CARLISLE IMAGING ASSO PO Box 100 101 Noble Blvd Ste 104 Carlisle PA 170130100 Christopher S Goins 5316 Dogwood Rd BJ\LTIMORE MD 21207-5903 1".111".111.",..11"11..1"1",1111",1.1,,11,,,,..11,,11.1 1..1.1".11.,1.11I",1."1.1.1.1,1.,11",.,11....11.11,,,1,.11 o Please check box if above addressee is incorrect or insurance information has changed, and indicate change(s) on reverse side. - - -. Date Ur. Ptht Harne - -Proe. Desc'ription'- DiagCd ChglCredi t Balance-' -,' --- STATEMENT OF ACCOUNT PLEASE DETACH AND RETURN TOP PORTION WITH YOUR PAYMEN 08/01/00drr Christoph 08/01/00drr Christoph 08/01/00drr Christoph 71020 72050 72020 Chest, 2 View Front & L 959.1 Spine, Cerv, Minimum Of 953.9 Radiologic Exam Spina I 953.9 24.00 43.00 24.00 24.00 43.00 24.00 MAKE CHECKS PAYABLE TO: CARLISLE IMAGING ASSO PRQVIDEAI PRACTICE NAME Patient Accounting Services 071837-00 DATE OF lAST JOE/JOE/JUF. INSURANCE PAYMENT . PENDING FOR BILLING INQUIRIES. CALL 717-249-2482 PAYMENT DUE DATE 11/09/00 STATEMENT DATE 0.00 0.00 0.00 0.00 CURRENT OYER 30 DAYS OYERfiO DAYS OVER to DAYS OVER 120 DAYS TRANSACTIONS AFTER THE CLOSING DATE WILL APPEAR ON YOUR NEXT STATEMENT 91. 00 PLEASE PAY THIS AMOUNT CARLISL~ HOSPITAL 246 PARKER STREET .CARLISLE PA 17013 PATIENT NAME Return Service Requested lBB f VISA I .. ~ N '" DISCHARGE I SERVICE DATE 08/01100 BIlliNG DATE 09/07/00 PAYMENT OUE DATE 09/28/00 CHRISTOPHER S GOINS PATIENT NUMBER 1974005 CURRENT BALANCE 750.00 AGREEMENT AMOUNT .00 CREDIT CARD PAYMENT INFORMATION CARD TYPE I EXP.DATE ACCOUNTNUMBER CARD HOLDER SIGNATURE PLEASE PAY THIS AMOUNT L CARLISLE HOSPITAL 246 PARKER STREET CARLISLE, PA 170130310 CHRISTOPHER S GOINS 5316 DOGWOOD RD BALTIMORE MD 21207 1.,.11I...111."...11"11...11..11"...111,,1,.1.,1.11,,11,,,1 1974005 3 60 ] 1"1.1",11"1.111...1.,.1.1.1.1,1,.11,,...11.,,.11.11.,,1.,11 o o o CK PLEASE CHECK HERE AND SHOW- NAME/ADDRESS CORRECTION ON REVERSE SIDE DETACH HERE TO ASSURE PROPER cREorr PlEASE WRITE YOUR PATIENT NUMBER ON YOUR CHECK AMJ- ReTURN UPPER PORTION WITH REMITTANCE " ~ " , > li >> " , " ~ . ~ >> , > ~ J > " " > C " ill ~ 08/01100 08/01100 08/01100 08/01100 08/01100 08/01/00 08/01/00 08/01100 SPINE CERVICAL ROUTINE .MIN VIEWS CHEST ROUTINE 2V LIDOCAINE ,170 /EPI INJECT. 20ML IBUPROFEN TABLET ',', .' 40pMG BACITRACIN. TOPICAL30nnT"J."t~M ;,.: . SPINE ONE ~VIEW;o SPECn:'i';cAR~V ,/ . OXIMETRY MEASUREMENT ~'r!' ":~"" . CLASS IV VISIT EMERGENCV,DEP;r. ',--> ".<'.'-,;-' '. -'/i,;; 1 1 1 2 1 1 1 1 229.00 127.00 8.00 4.00 4.00 101.00 71.00 206.00 You may reach Patient Financial Services GOINS PRE,VlOllS BAlANCE NEW CHARGES .00 750.00 .00 ~~~~~~ 08/01/00 ~=ENT .00 750.00 09/28/00 750.00 RETAIN THIS PORTION at 717=218-8820 8:00 AM unitl 4:00 PM Monday thru Friday PAYMENTS RECEIVED AFTER BlWNG DATE WILL APPEAR ON NEXT STATEMENT .H IMPORTANT MESSAGE FFlOM YOUR PHYSICIAN ,," This bill covers only the profe~siona1 fee; you may also receive a separate hospiW bill QuestiwS1 800-666-2455 Call Monday-Fnday between the hours of 9:30 AM - NOON AND 1:00 - 5:00 PM EST If insurance information or other information on this fOlTn is incorrect, please correct on back of return stub. DR. GUARRAC / ER EXAM-4 DR. GUARRAC / WOUND REPAIR SERVICE AT CARLISLE HOSP-HEALTH SVC . . . . . .. PAY THIS AMOUNT" 481. ._m..:.~~~~~~~~~~~~~_~~~::~~.~:~~~~~~;.~H-ANri' AE~~~.~~~...~.~.~_~.~:.~.~.~.~~.~.I.:.~u:.~~?HECK ORMO~~~?~~~~.~~.:.~~~~ IN USCURR DIRECT BILLING QUESTIONS TO: 800-666-2455 RWC CORPORATION PO BOX 828340 PHILADELPHIA. PA 19182-B340 DUE DATE 11/02/00 PArmNTNAME CHRISTOPHER GOINS ACCOIINTNUMBER CAROOOO 1974005 ,u;ouilt Due $481. 00 Amount Enclosed STATEMENT DATE 10/12/00 ....11",1.....111..\...1.11..1...11..1..\1\....1..111...11,..1 CHRISTOPHER GOINS . 5316 DOGWOOD RD BALTIMORE, MD 21207 RWC CORPORATION PO BOX 828340 PHILADELPHIA. :.PA 19182-B340 o CHECK HERE IF NEW ADDRESS see REVERSE SIDE FOR INSURANCE BILLING PLEASE MAKE CHECK PAYABLE TO AND MAIL TO ADDRESS ABOVE PLEASE WRITE YOURACCOUNT NUMBER ON YOUR C~.~KOR MONEY ORDER '~'y " DATE, (f 1 ?-ol PATIENT: c...~ g c u J.']:1F EYE EXAM REPORT tJo A. EXAM SUMMARY .1 .1 , 1. VISUAL ACUITY AIDEO UNAIDED R 20 1 It! 0 L. 201 (C>-v "'__"'~_,"__-,,"_. --'-~___" '1 ..._.'f...'.',..-.... ,....;.. . J ~~~':;[.~;~+l ~_-.':'~~~~~A,.,~~~?~ R 20 1 '7...Q L.20/--z..,-) ~DNO 2. GLAUCOMA CHECK NORMAL NO~ ~ W- rY' PROBLEM o o o o o o 3. MUSCLE BALANCE 4. RETINAL HEALTH 5. CORNEAL HEALTH 6. PUPILLARY REFLEXES 7. OTHER OTHER B. DIAqN6$"IS !3'MVOPIA(NEAASlGHTEDNESS) o ~ROPIA {FARSIGHTEDNESS} C3-"'ASTlGMATISM (~lAREGlJ\ARITY) D PRESBYOPIA (REOF~~~~lOH) o OTHER o OTHER C. PATIENT EYE HEALTH PLAN: D. DOCTOR'S RECOMMENDATIONS: spe~ Contacts: ~Iy~~onate _ Daily Wear - Progressives _ Flexible Wear rail eye I near only _ Tories _ Sp' Ity lens _ Colors _ lot _ Disposables Coating _ Gas permeable _ Ultraviolet _ Sight Plus _ Anti-Reflective _ Emergency Pair _ Warranty _ Care Kit _ Emergency Pair _ Safety I I , , i I i ! i I I I Sunglasses: _ Prescription _ Piano (non-prescription) _ Occupational Other: ,., . :,--~..':",-,_._ _ <;'-";.~-~"""-;-:._-~"'-- ~_-r~:, .:-:.;;: '..:'-~~~:i ~i~;:-~~i{;i"IJ;~ E. FOLLOW-UP RECOMMENDATIONS: _____ NEXT ExAM: 06 MOS. 01YEAR 016 MOS. ~RS ~~ PATIENT COPY DOCTOR OPT E . REASON FOR NEXT EXAM: OP.S8 CODElf820851095 L -""""_~"_"'"?"X>. - ~f~;:~i:'~st>~:;~ Co." ';;;' ,~~,:~:;.;.- . . &~~~~~t~~~~~;:~ '~"::;'y'~~~i_; .-", . .. . .'~ ~*~1~,~~:;/~::i:~_'.i.:~a~;t5;:~~ :~:.' 'iil\yn'f'"'" "J~y '/ ;:Sft~~~t~i;; :', "::<:- : :,~".: ,>' ',": '. ". -."-,.:". ". <~{~~~~:~~,:~~. ...."..-,. . ,.- -,. ~~~~:~1f~~~':_~:~~~ff?~f:j~~~.~-~'o- ~~;;..~;.v.:"."., , .~..:.. :~i~~t~~:6~_:!:;,~~;~3~o~::; . , -. . .... ""... -, :~~";.. ; VF.RTFTCA TTON The undersigned hereby certifies that he is the attorney for Christopher Goins and that the facts in the foregoing Plaintiffs Response to Request for Production of Documents Addressed to Plaintiff are true and correct to the best of his knowledge, infonnation and belief, and that said matters relating to Plaintiffs Response to Request for Production of Documents Addressed to Plaintiff are as known to the undersigned as to the client, Brian W. Shields, said knowledge being based upon information contained in the file in this matter, and further states that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. ~ C~ t1AFJ-. Andrew W. Norfleet, Esquire Date: May 9, 2003 280781-1 105 ~ A ILlABlTJMILLPGI I 027 54VMF\20614100 146 CHRISTOPHER GOINS, Plaintiff v. FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.: 02-3672 CIVIL ACTION - LAW : JURY TRIAL DEMANDED NOTICE OF DEPOSITION TO: Christopher Goins, Plaintiff c/o Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.c. 3211 North Front Street PO Box 5300 Harrisburg, P A 1711 0-0300 PLEASE TAKE NOTICE that on Tuesday, November 19, 2002 beginning at 1:00 p.m. your oral deposition will be taken at the offices of your attomey, Andrew W. Norfleet, Esquire, 3211 North Front Street, Harrisburg, PA 17110, upon oral examination pursuant to the Rules of Civil Procedure before a Notary Public or some other officer authorized by law to administer oaths. The oral examination will continue from day to day until completed. DATE: AUG, 23, 'Z(XJZ- BY: Respectfully submitted, MARSHALL, Dl<;NNEHEY, WARNER, COLEMAN & GOGGIN T TH J.D. No. 5291 4200 Crums Mill Road, Suite B Harrisburg, P A 17112 (717) 651-3505 Attorney for Defendant, Flying J Inc. cc: Hughes, Albright, Foltz & Natale Court Reporting, Inc. CHRISTOPHER GOINS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Joanne M. Parr, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby ~ certify that on this .Q\Jl day of August, 2002, served a copy ofthe enclosed Notice of Deposition via First Class United States mail, postage prepaid as follows: Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street PO Box 5300 Harrisburg, PA 17110-0300 ~~\\\,~ Jo . Parr I Postal Service RtIF.lto MAil RECEIPT .f"ie?lf'cJt..19i1 ahly; No Insurance Coverage ProvIded) A I MARsHAlL, DENNElIEY, WARNER, COLEMAN to Gol~ I (; . I A P R 0 f E S S ION ALe 0 .. POll. A T ION www.marshalldenneho ~-~ Direct Dial: 717-651-3505 Email: tmcmahon@mdwcg.com IT' 17112 m 11.1 '" 0 0 0 0 0 ~ IT' r'I r'I 0 0 I'- Postag$ $ ---.-- ~~J 4200 Crums Mill Road, Suite B . Harrisburg, P A (717) 651-3500. Fax (717) 651-9630 Certified Fee R-mrrn RaceJpt Fee (Endorsement Required) Restrleted Delivery Fee (EodoffilWlElnt Required) 1bta! Postage & Fees H... $ \ \~:)'\ \~::, :I;;P;~~"~~~~~---"'._""-'''. or PO Box No. cjty,E:;;;.:Z1i;;:4.n..~.._..._--~...._--------.__._._. ;11 . . If January 27,2003 Via Certified Mail Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street PO Box 5300 Harrisburg, PA 17110-0300 RE: Christopher Goins v. Flying J Inc. and Flying J Travel Plaza, CCP (Cumberland County) No.: 02-3672 Our File # 20614-00146.061 Dear Mr. Norfleet: Enclosed please find a Rule directed to Plaintiff to show cause within twenty (20) days as to why Defendant's Motion to Compel Answers to Defendant's Interrogatories and Request for Production of Documents should not be granted. Very t~urs, TIMO H J. --- TJM/jmp Enclosure 105.. A ILlAB\TJMICORRI 114882\JMFI20614\OO 146 Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: c. Signature X B ,'Y) .-/ ~t o Addressee DYes o No D. Is delivery addre different from item 1? If YES, enter delivery address below: ~~~~~\bt \\\~~ ,\\\~~\\~\ ~~\\ ~~~'-\ ~-\". \?,\::,.~5~i0 \ '\ \\ ~_~ 4. Restricted Dellv..,,? (Extra Fee) 7001 1940 0000 8239 0581 3. Service Type R1 Certified Mail o Registered o Insured Mail [J Express Mail [J R~turn Receipt for Merchandise [] C.O.D. 2. Article Number (Transfer from service label) DYes PS Form 3811, March 2001 Domestic Return Receipt ~\\.\..-~\~ 102595-01-M-1424 June 4, 2003 Timothy J. McMahon, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crums Mill Road, Suite B Harrisburg, P A 17112 RE: Goins v. Flying J. Inc. and Flying J. Travel Plaza No: 02-3672 Dear Mr. McMahon: SINCE 1888 3211 North Front Street PO. Box 5300 Harrisburg, PA 17110-0300 717-238-8187 Fax: 717-234c9478 Other Offices Colonial Park Mechanicsburg 717-652-7020 717-691-5577 Millersburg Shippensburg 717-692-5810 717-530-7515 Enclosed herewith please find Plaintiffs Answers to Interrogatories of Defendant Flying J, Inc. and Plaintiffs Response to Request for Production of Docurnents of Defendant. Very truly yours, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. vtz~ blJ.fILt~ Andrew W. Norfleet A WN/tmn o IECfEUVie n dUff ..5:am U 282/80-1 C} James F. Carl Edward E. Knauss, IV" Jered 1. Hock Steven P. Miner Clark DeVere Milton Bernstein Bruce J. Warshawsky Francis J. Lafferty, IV David H. Martineau Andrew W. Norfleet Andrew C. Spears Young-Suh Koo .. Board Certified in civil trial law and advocacy ~!~ !'l?t!onal Board A REGIO. DEFENSE LITIGATION LAW FIRM I MARsHAll, DENNEHEY, WARNER, CoLEMAN & GoGGIN] A PROFESSIONAL CORPOR.ATION www.marshalldennehey.com PIlI'fNSYLVAIlIIA IlethI<h<m -- Eric H_ Newrown SqUln' N_ """""'p""' .....- S<nn~ - 4200 Crums Mill Road, Suite B. Harrisburg, PA 17112 (717) 651-3500 . Fax (717) 651-9630 N""JER.." (h<ny Hill llooebnd Direct Dial: 717-651-3504 Email: jemurphy@mdwcg.com DElAWARE -= OHIO Akro. FLORIDA Ft.lawktdale Odondo T'"'P' June 19,2003 II Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street PO Box 5300 Harrisburg, PA 17110-0300 RE: Christopher Goins v. Flying J Inc. and Flying J Travel Plaza CCP (Cumberland County) No.: 02-3672 Our File # 20614-00146.061 Dear Andy: Thank you for your submission of responses to our discovery requests. I have carefully reviewed your responses and noticed that they are not verified by your client. Please provide verification for the Interrogatories and Request for Production of Documents as soon as possible to avoid filing a motion. Thank you for your attention to this matter and I remain available to discuss this matter. Very truly yours, JEM/cmw 105_ AILlABI1RMICORRII27351 ICYW\2O!i 14100 146 CHRISTOPHER GOINS, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNS YL V A.NIA CIVIL ACTION - LAW v. FLYING J. INC. and FLYING J. TRAVEL PLAZA, NO. 02-3672 Defendants. JURY TRIAL DEMANDED ORDER AND NOW, this '4- ze/. day of June, 2003, upon consideration of the verified Petition of Defendant's Counsel for Leave to Withdraw, IT IS HEREBY ORDERED that said Petition is granted and that Petitioner Metzger, Wickersham, Knauss & Erb, P.C. and Andrew W. Norfleet, Esquire, are permitted to withdraw their appearance of record for the Defendant in the above matter. BY THE COURT ( J. cc: Andrew W. Norfleet, Esquire - Counsel for Defendant Justin Murphy, Esquire Prothonotary Document #: 260840. J CHRISTOPHER GOINS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CNIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Stefanie Meyers, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this ~day of September, 2003, I s(:rved copies of the foregoing documents via First Class United States mail and Certified Mail (return receipt requested), postage prepaid as follows: Christopher Goins 5316 Dogwood Road Baltimore, MD 21207 ;:~ :- t/,l r~ " _.,c.:. ;:', p C) () , ,') --, .., ul u..:, ..~.1 :""j ~.:> (1) CHRISTOPHER GOINS, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COLNTY, PENNSYLVANIA 02-3672 CIVIL FL YING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED IN RE: DEFENDANTS' MOTION FOR SANCTIONS ORDER AND NOW, this IS. day of October, 2003, a brief argument on the within motion for sanctions is set for Thursday, December 4, 2003, at 3:00 p.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, P A. BY THE COURT, vChristopher Goins 5316 Dogwood Road Baltimore, MD 21207 . ~ L;)~ll Rl\j 10 -1~-03 ,AIL . Hess, J. ../.foseph F. Murphy, Esquire For the Defendants :rlm ,. j .~- /1 i '-' ,f,."O \iiNVf.:l"SNN3d AJ}~r:~,Y'; :--;.,. 1~-':,:J',]qV'ln:) OU :'1 Hd S I lJU eo " r , :JU CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009. 2<! IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTOPHER GOINS TERM, -VS- CASE NO: 02-3672 FLYING J As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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 t:he 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: 11/12/2003 ~ DE:11-456845 32993 - L 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTOPHER GOINS TERM, -VS- CASE NO: 02-3672 FLYING J NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE GOODWILL FIRE CARLISLE IMAGING ASSOCIATES CARLISLE HOSPITAL OTHER MEDICAL RECORDS MEDICAL RECORDS TO: CHRISTOPHER GOINS (PRO SE) MCS on behalf of JOSEPH F. MURPHY, 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: 10/23/2003 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT CC: JOSEPH F. MURPHY, ESQ. - 20614-00146 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-246786 32993 - C 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRISTOPHER GOINS FileNo. 02-3672 vs. FLYING J SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE GOODWILL FIRE (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 AIT ACHED RIDER **** at The MCS Group Ine 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: JOSEPH F. MURPHY. ESO. ADDRESS: 4200 CRUMS MILl. ROAD SUITE B HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant E COURT: .12. Prothonotary/Clerk, Civil "- Dep~!'M' "{! 71t./l~ Date: Oc.J. /7, :J.6o....l, Seal of the Court 32993-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE GOODWILL FIRE P.O. BOX 207 ALLENTOWN, PA 18105 RE: 32993 CHRISTOPHER GOINS RECORDS FROM ACCOUNT NO.:59819; TRIP NO.OOO2927 Subject: CHRISTOPHER GOINS 5316 DOGWOOD ROAD, BALTIMORE, MD 21207 5UlO-47064232993-LOl CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22: IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTOPHER GOINS TERM, -VS- CASE NO: 02-3672: FLYING J As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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. MCS on behalf of DATE: 11/12/2003 JOSEPH I'. MURPHY, ESQ. Attorney for DEFENDANT D!:11-456846 32993 - L 02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTOPHER GOINS TERM, -VS- CASE NO: 02-3672 FLYING J NOTICE OF INTENT TO SERVE: A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE GOODWILL FIRE CARLISLE IMAGING ASSOCIATES CARLISLE HOSPITAL OTHER MEDICAL RECORDS MEDICAL RECORDS TO: CHRISTOPHER GOINS (PRO SE) MCS on behalf of JOSEPH F. MURPHY, 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 Dr by contacting our local MCS office. DATE: 10/23/2003 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT CC: JOSEPH F. MURPHY, ESQ. - 20614-00146 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET D800 PHILADELPHIA, PA 19103 (215) 246-0900 DEII2-246786 32993 -CO 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRISTOPHER GOINS FileNo. 02-3672 vs. FLYING J SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE IMAGING ASSOCIATES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER .... at The MCS Group Ine 1601 Market Street Snite 800 Philadelnhia 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. TIllS SUBPOENA WAS ISSUED AT TIlE REQUEST OF TIlE FOLLOWING PERSON: NAME: ADDRESS: JOSEPH F. MURPHY. ESO. 4200 CRUMS MIl.l. ROAD SUITE B HARRISBURG. PA 17] 10 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY TIlE COURT: Date: Cc:t II .,lO(;d I Deputy Seal of the Court 32993-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE IMAGING ASSOCIATES P.O. BOX 100, SUITE 104 100 NOBLE BLVD. CARLISLE, PA 17013 RE: 32993 CHRISTOPHER GOINS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical fIle, including but not limited to any and all records, correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTOPHER GOINS 5316 DOGWOOD ROAD, BALTIMORE, MD 21207 8(110-470644 3:2 993 -LO:2 CERTIFICATE PREREQUISITE TO SERVICE OF A StffiPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTOPHER GOINS TERM, -VS- CASE NO: 02 -3 672 FLYING J AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of JOSEPH F. MURPHY, 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. MCS on behalf of DATE: 11/12/2003 JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT DEll-456847 32993 - L 03 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS CHRISTOPHER GOINS TERM, -VS- CASE NO: 02-3672 FLYING J NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE IX>COMBNTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 CARLISLE GOODWILL FIRE CARLISLE IMAGING ASSOCIATES CARLISLE HOSPITAL OTHER MEDICAL RECORDS MEDICAL RECORDS TO: CHRISTOPHER GOINS (PRO SE) MCS on behalf of JOSEPH F. MURPHY, 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: 10/23/2003 MCS on behalf of JOSEPH F. MURPHY, ESQ. Attorney for DEFENDANT CC: JOSEPH F. MURPHY, ESQ. - 20614-00146 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE1l2-246786 32993 -CO 1 COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND CHRISTOPHER GOINS FileNo. 02-3672 vs. FLYING J SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun Ine 160] Market Street Suite 800 Philadelnhia PA ]9103 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 .:omply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF TIlE FOLLOWING PERSON: NAME: ADDRESS: JOSEPH F. MURPHY. ESO. 4200 CRIJMS MILl. ROAD SlJITE B HARRISBURG PA 17]10 TELEPHONE: (215) 246-0900 SUPREME COURT ill #: ATTORNEY FOR: Defendant Date: Cl::t- 17( ~ Seal of the Court 32993-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL P.O. BOX 310 246 PARKER STREET CARLISLE, PA 17013 RE: 32993 CHRISTOPHER GOINS PATIENT NO.: 1974005, MEDICAL RECORDS #843798 Please call for prior approval 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: CHRISTOPHER GOINS _5316 DOGWOOD ROAD, BALTIMORE, MD 21207 SUlO-470646 32993 -LO 3 (") c: '""C;~i rn(:l :;(. .'~,' ::7,\,,: _<.u.. ~::C-i 2(-) ~~'f-) '):;' (-- -7 ::;l. C:,) C~) : ~.) C1 '-n ! " \.f' crJ :~~'" -_.','~ "';-\ ,"":: '.: (') .'- In ~> -.-\ -"'-',~ '~"J ::< ~:j r-- {,n CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE OF DEFENDANT TO WITHDRAW MOTION FOR SANCTIONS TO THE PROTHONOTARY: Kindly withdraw Defendant's Motion for Sanctions against plaintiff. MARSHALL, DENNEHEY, WARNER COLEMAN & GOGGIN BY: CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRJAL DEMANDED CERTIFICATION OF SERVICE I do hereby certify that service of a true and correct copy of the within PRAECIPE OF DEFENDANT TO WITHDRAW MOTION FOR SANCTIONS was made on the below date to the counsel below named by First Class, U.S. Mail, postage pre-paid. Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street PO Box 5300 Harrisburg, PA 17110-0300 MARSHALL, DENNEHEY, WARNER COLEMAN & GOGGIN BY: Date: D3 I05_AILIABIJP ISLPG\1377341LZM\20614\O0146 () C -0 ~;~ nth: --:;;---- Zl co....' -<"" . !::-~ f:: ~( jii~ ~ . C'" C'_) c"). q -.- :5 ~'.) c:.' r',,) Ui ':':.J ~< CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV ANlA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw the appearance of the undersigned as counsel on behalf of the Defendants, Flying J, Inc. and Flying J Travel Plaza, in the above-captioned case. JOSE] l.D.N DATE:~ BY: VIN\/!'.lA~'\"\:.Jr! U,\i(')"'- -;' ,->', ,.C::;',,,I'1"o I I,' ',..I..' 1.,;_ -:':;::":;j~, 'v 68 :2/ j,!d 8- d3S ?DOZ liNiDNOHlOi::!::I 3H1 :10 0181:1:10-0311:1 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned as counsel on behalf of the Defendants, Flying J, Inc. and Flying J Travel Plaza, in the above-captioned case. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN ByL CHRISTOPHER M. REESER, ESQUIRE J.D. No. 73632 4200 Crums Mill Road, Suite B Harrisburg,PA 17112 (717) 651-3509 Attomeys for Defendant DATE: .,(1/0<1 CHRISTOPHER GOINS, Plaintiff v. FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No.: 02-3672 CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Christopher M. Reeser, do hereby certify that a true and correct copy of my Entry of Appearance was served to all parties herein listed via United States First-Class mail on the date below. Andrew W. Norfleet, Esquire Metzger, Wickersham, Knauss & Erb, P.c. 3211 North Front Street PO Box 5300 Harrisburg, PA 17110-0300 Christopher Goins 5316 Dogwood Road Baltimore, MD 21207 DATE: 9 (I (0<-1 MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN /A BY:~ Y-- CHRISTOPHER M. REESER, ESQUIRE J.D. No. 73632 4200 Crums Mill Road, Suite B Harrisburg, PAl 7112 (717) 651-3509 Attorneys for Defendants (') ?; 1-:.-' i c Z --; -< ....... C:) = ..,.. (/) rT1 -u I CO o -n -1 :r: n1:::!:! -o~ ~~ 7S:::d -~,,.("l ~'-jrn .~-~ ":r-" :u -< --0 ::ii: r;;> W -.I Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHER GOINS, v. CIVIL ACTION - LAW FLYING J. INC. and FLYING J. TRAVEL PLAZA, Defendants NO. 02-3672 JURY TRlAL DEMANDED PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Withdraw the appearance of Metzger, Wickersham, Knauss & Erb, P., and Andrew W. Norfleet, Esquire, as attorneys for Plaintiff pursuant to the Court Order attached hereto as Exhibit "A". METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Andre . Norfleet, Attorney J.D. No. 83894 P.O. Box 5300 3211 North Front Street Harrisburg, P A 17110-0300 (717) 238-8187 Dated: / 'Z- ~/7 -0 r 317612-1 CHRlSTOPHER GOINS, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. CIVIL ACTION - LAW FLYINGJ. INC. and FLYING J. TRAVEL PLAZA, NO. 02-3672 Defendants. mRY TRIAL DEMANDED AMENDED ORDER AND NOW, this ,2.1~ day of August, 2003, upon consideration of the verified Petition of Defendant's Counsel for Leave to Withdraw, IT IS HEREBY ORDERED that said Petition is granted and that Petitioner Metzger, Wickersham, Knauss & Erb, P.C. and Andrew W. Norfleet, Esquire, are permitted to withdraw their appearance of record for the Plaintiff in the' above matter. BY THE COURT: I~I i~~~ Q. ~ I I 1. cc: Andrew W. Norfleet, Esquire Justin E. Murphy, Esquire Prothonotary 2862&4-1 'fRUE OOPV .FRO~Jl RECORD In Testimony whereof, t hera unto 36t my hand .:nd the seal (l11 said Cow1 at C-.r1Jsje Pa. 'hi. .l~daY ~~. .~ . ~~ ~ Prothonotar" CERTIFICATE OF SERVICE I, Andrew W. Norfleet, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.e., hereby certify that I served a true and exact copy of the Praecipe to Withdraw Agearance with reference to the foregoing action by first class mail, postage prepaid, this / 7 day of December, 2004, on the following: Justin E. Murphy, Esquire Marshall, Dennehey, Warner, Coleman & Goggin 4200 Crumbs Mill Road, Suite B Harrisburg, P A 17112 ~~ 317612-1 "" ,.,.,~, n r. l' ,.,,1 L ,~ -11 J.'- r~} 1 \ , , .:.. ~; :' .) I, .l I i I ",1 -.....J , CHRISTOPHER GOINS, Plainti ff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED DEFENDANTS' PETITION FOR STATUS CONFERENCE 1. Plaintiff Christopher Goins filed his Complaint on July 31, 2002. 2. At the time he filed his Complaint, Mr. Goins was represented by Andrew W. Norfleet, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.c. 3. On June 24,2003, Defendants filed a Motion for Sanctions as a result of Plaintiffs failure to answer written discovery. 4. On July 7,2003, Attorney Norfleet filed a Petition for Leave to Withdraw as Plaintiffs counsel. 5. On August 25,2003, Attorney Norfleet's Petition was granted and he and his flrm where permitted to withdraw their appearance on behalf of Plaintiff. 6. On or about December 17, 2004, Attorney Norfleet filed a Praecipe to Withdraw the Appearance of himself and of his law firm as counsel for Plaintiff. '" 7. On February 7, 2005, Defendants1 counsel sent a letter, attached hereto as Exhibit "A", to Plaintiff himself, asking Plaintiff as to what his intentions are with regard to this lawsuit. 8. Plaintiff has not responded to Defendants' counsel letter. 9. Defendants do not know at this time whether Plaintiff has any intention of pursuing this case. 10. Defendants request a Status Conference for the purpose of establishing discovery deadlines and a trial date if Plaintiff does intend to proceed. If Plaintiff does not intend to proceed with this case or ifhe does not appear at the Status Conference, Defendants request that the Court enter a Judgment of Non-Pros. WHEREFORE, Defendants request request this Honorable Court to schedule a Status Conference to address the issues raised herein. Respectfully submitted, MARSHALL, DENNE HEY, WARNER, COLE GOGGIN DATE:31-z;,(o'j BY: TOPHER M. REESER, ESQUIRE LD. No. 73632 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3505 Attorney for Defendant, Flying J Inc. 2 r f{r~\ b} /) .---------'--. , A REGIONA, DEFENSE llIlGATION lAW FIRM " - I MARsHAll, DENNEHEY, WARNER, COLEMAN fo GoGGIN I A PP.OFBSSIOl'lAL CORPORATION www.marshalldcnnehey.com .............. Bethlehem Doylestown &j, Harrisburg Newtown $quare ,,"".,,"'" PhIladelphia ~- Sctmton -~""" 4200 Crums Mill Road, Suite B . Harrisburg, P A 17112 (717) 651-3500 . Fax (717) 651-9630 New JURY ChcrryHilI .""""" Direct Dial: 717-651-3509 Emai1: creeser@mdwcg.com Du..t.w.uu: WIlmington o.no Akron ......... Fl.l.auderdale 0""''' """" February 7, 2005 Christopher Goins 5316 Dogwood Road Apt. A Gwynn Oak, MD 21207-5903 RE: Christopher Goins v. Flying J Inc. and Flying J Travel Plaza CCP (Cumberland County) No.: 02-3672 Our File # 20614-00146.061 Dear Mr. Goins: My law firm is representing Flying J Travel Plaza in a lawsuit that you filed against it some time ago. I recently received correspondence from your former attorney, Andrew Norfleet, indicating that he is no longer your attorney in this case. He has formally filed a withdrawal of his appearance as your attorney with the Court. Do you intend to continue with this lawsuit? Do you intend to hire another attorney? If! do not hear from you within the next thirty days, I am going to assume that you do not intend to proceed with this lawsuit and I will ask the Court to dismiss it as a result of your failure to prosecute the action. Please let me hear from you as to your intentions at your earliest convenience. CHRISTOPHER M. REESER CMR:jw cc: Robert Payne, Esquire , . CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FL YING J TRAVEL PLAZA, Defendants CIVIL ACTION - LA W : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Christopher M. Reeser, Esquire, of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this March 31, 2005, I served a copy of the Defendants' Petition for Status Conference via First Class United States mail, postage prepaid as follows: C2- Christopher M. Reeser Christopher Goins 5316 Dogwood Road Apartment A Gwynn Oak, MD 21207-5903 \05 _A \L1AB\CMR\LLPG\J 81007\KPM\20614\OO J 46 """"'~v__~~...~~'_..."'.-~.,~_. ~., 'j' .... RECEI V ED "" 0 4 1Illi f' \ CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No.: 02-3672 FLYING J INC. and FLYING J TRAVEL PLAZA, Defendants CIVIL ACTION - LAW : JURY TRIAL DEMANDED ORDER AND NOW, this .;--t# day of OfJ>.d, ,2005, upon consideration of Defendants' Petition for Status Conference, it is hereby ORDERED that a Status Conference is scheduled for 5~ day Of~, 2005 at I, j 0 -.-fp.m. before Judge Kevin A. Hess-t.Yl ~12 d L/. Plaintiff and Defendants' counsel are ORDERED to attend the Status Conference. If Plaintiff does not attend the Status Conference, Judgment of Non-Pros will be ordered against him. BY THE COURT: /l~ 1. (I _ '.J. d j, .. ~ .r~~ '-1-7-6') ~ Vlt\i"~j/\ll\S:\ i\!3d l~JNnC(i '--).;--:::~:'/";nJ SZ : II fiV L - ~d'JSDOZ AtlVl.o>KJ,'-U.GLki 3H1 ~O 38U.:!Q-C:Jl!.:i CHRISTOPHER GOINS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION - LAW NO. 02-3672 CIVIL FLYING J INe. and FLYING J TRAVEL PLAZA, Defendant JURY TRIAL DEMANDED ORDER AND NOW, this f~ day of May, 2005, the plaintiff having failed to appear for status conference, in accordance with our order of April 7, 2005, a judgment of non pros is 'entered and the captioned case is DISMISSED with prejudice. BY THE COURT, vChristopher Goins $316 Dogwood Road ,l\pt.A ~wynn Oak, MD 21207-5903 Ahristopher M. Reeser, Esquire Il'or the Defendant //4 :t1m ? !~'d- ~ 05- 9 -{).5 >'~::) 6! :[q b- - \',111 r:O'J7 .'. (, l ...~, LJ