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HomeMy WebLinkAbout02-3799OXMAPI, LEVITAN, GOODSTADT & KREVITZ, P.C. BY: SHELDON A. GOODSTADT, ESQUIRE IDENTIFICATION NO.: 19547 1700 Market Street, Suite 3050 Philadelphia, PA 19103 (215)665-9999 Attorneys for Plaintiff SCOTT PATILLO 133 Hamilton Road Marlton, New Jersey 08053 vs. Plaintiff JEREMY STRAYER 109 N. Hanover Street, Apt. 3 Carlisle, PA 17013 ANTHONY STRAYER 1806 Suncrest Drive Carlisle, PA 17013 Defendants NO--T-I._CE COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY AUGUST TERM, 2002 NO. You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing m court your defenses or objections to the claims set forth against writing with the to do so the case may proceed without you and the court without you. You are warned that if you fail against you for any money claimed in the complaint or for any other further claim or rel of requ st d by the plaintiff. You may lose money or roe may enter J gment P P rty or other rights important to you. "YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT NCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE GO TO OR TE LEPHO E THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP." Cumberland County Bar Association Lawyer Referral and Information Service 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 AVI_SO Le ban demandado a usted en la cone. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandas en eontra de su medidas y puede continuar la demanda en contra suya sin previo aviso o notification. Ademas, la cone puede decidir a favor del demandanta y requiere que usted cumpla con todas las provisions de esta demanda. Usta puede perder dinero o sus propiedades u otros derechos importantes par usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIAT ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE P AGAR AL NE SERVICIO, VAYA EN PERSONAL, O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO P DONDA SE PUEDE CONSEGUIR ASISTENCIA LEGGAL.o AR Cumberland County Bar Association Lawyer Referral and Information Service 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 AN ASSESSMENT OF DAMAGES HEARING IS REQUIRED OXMAN, LEVITAN, GOODSTADT & KREVITZ, P.C. BY: SHELDON A. GOODSTADT, ESQUIRE IDENTIFICATION NO.: 19547 1700 Market Street, Suite 3050 Philadelphia, PA 19103 (215)665-9999 Attorneys for Plaintiff SCOTT PATILLO 133 Hamilton Road Marlton, New Jersey 08053 vs. JEREMY STRAYER 109 N. Hanover Street, Apt. 3 Carlisle, PA 17013 ANTHONY STRAYER 1806 Suncrest Drive Carlisle, PA 17013 COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY Plaintiff AUGUST TERM, 2002 NO. 02 -.3 79 Defendants CML ACTION COMPLAINT 1 • Plaintiff, SCOTT PATTILLO, is an adult individual, citizen and resident ofthe State of New Jersey, residing therein at the above-mentioned address. 2. Defendant, JEREMY STRAYER, is an adult individual, citizen and resident of the Commonwealth of Pennsylvania residing therein at the above-mentioned address. 3. Defendant, ANTHONY STRAYER, is an adult individual, citizen and resident of the Commonwealth of Pennsylvania residing therein at the above-mentioned address. 4. At all times relevant hereto, Defendant, JEREMY STRAYER, was operating the motor vehicle owned by Defendant ANTHONY STRAYER as the agent, servant, workman and/or employee of Defendant ANTHONY STRAYER and within the course and scope of such agency. 5. On or about August 20, 2000, Plaintiff, SCOTT PATTILLO , was stopped on SR 8113 in an attempt to merge onto I-83 in Cumberland County, Pennsylvania, when he was violently struck in the rear by the vehicle operated by Defendant JEREMY STRAYER and owned by Defendant ANTHONY STRAYER. As a result of this collision, Plaintiff sustained serious and permanent injuries as hereinafter set forth. 6• The above-described incident resulted solely from the negligence, carelessness, recklessness and wanton and willful misconduct of the Defendants, and was due in no way whatsoever to any act or failure to act on the part of the Plaintiff. 7. The negligence, carelessness, recklessness and wanton and willful misconduct ofthe Defendants consisted of the following: (a) Operating said motor vehicle at a high and excessive rate of speed under the circumstances; (b) Failing to give proper and sufficient warning of the approach of said vehicle or its intended direction; (c) Operating said vehicle without due regard to the rights, safety and position of the Plaintiff herein at the point aforesaid; (d) Failing to have said vehicle underproper or adequate control as to avoid the collision; (e) Operating said vehicle in violation of the ordinances of Cumberland County and the statutes of the Commonwealth of Pennsylvania pertaining to the operation of motor vehicles on the public highways, which conduct constitutes negligence as a matter of law; (fl Such other acts of negligence, carelessness and recklessness as may be determined through the course of discovery. 8. By reason of the aforesaid negligence, carelessness and recklessness of the Defendants, the Plaintiff, SCOTT PATTILLO, sustained serious personal injuries including, but not limited to: cervical strain and sprain, lumbar strain and sprain, left paracentral disc herniation at L5- S 1 causing impression upon the thecal sac, lumbar radiculopathy and bulging of the disc at L4-L5, all of which may be permanent in nature, together with a severe and permanent shock to his nervous system, as a result of which the Plaintiff has suffered and may, and probably will in the future, continue to suffer great pain, agony, mental anguish and humiliation. 9. As a further result of this incident, Plaintiff has been and probably will in the future continue to be hindered and prevented from attending to his usual and daily duties to his great financial damage of loss. 10. As a further result of this incident, Plaintiff has been or will be obliged to receive and undergo medical attention and care and to incur various expenses described in the Pennsylvania Financial Responsibility Law or the New Jersey Automobile Insurance Cost Reduction Act for the injuries he has suffered, the cost or reasonable value of which is or may be in excess of the sums provided for by said law. He may be obliged to continue to expend such sums or incur such expenditures for an indefinite length of time in the future. 11. As a further result of this incident, plaintiff has suffered injuries which may be, in full or in part, permanent, irreparable and severe. 12. As a further result of this incident, Plaintiff has or may suffer a severe loss of his earnings and an impairment of his earning capacity and power, which loss of income and/or impairment of earning capacity or power has or may exceed the sum recoverable under the limitations of the Pennsylvania Motor Vehicle Financial Responsibility Law or the New Jersey Automobile Insurance Cost Reduction Act. 13. As a direct result of this incident, Plaintiff has or may hereafter incur other financial expenses or losses which may exceed amounts which he may otherwise be entitled to recover. WHEREFORE, Plaintiffdemands judgment against the Defendants, ANTHONY STRAYER and JEREMY STRAYER in an amount in excess of Fifty Thousand Dollars ($50,000.00). OXMAN, GOODSTADT, KREVITZ& KURITZ, P.C. BY: SH ON A. GOODSTADT Attorney for Plaintiff VERIFICATION The under signed hereby verifies that the within document is based on first-hand information and on information furnished to counsel and obtained by him in the course of this lawsuit. The language of the document is that of counsel and not of the affiant. To the extent that the contents of the document are based on information furnished to counsel and obtained by him during the course of this lawsuit, affiant has relied upon counsel in taking this verification. All statements are founded upon reasonable belief. This verification is made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. o 0 =0 - ' -? _ T, , r ? i -? fJ O v Q 'LJ t7:J ? 1 Fn 03 V -c VERIFICATION The under signed hereby verifies that the within document is based on first-hand information and on information furnished to counsel and obtained by him in the course of this lawsuit. The language of the document is that of counsel and not of the affiant. To the extent that the contents of the document are based on information furnished to counsel and obtained by him during the course of this lawsuit, affiant has relied upon counsel in taking this verification. All statements are founded upon reasonable belief. This verification is made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. SCOTT PATILLO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 02-3799 JEREMY STRAYER and ANTHONY STRAYER, Defendants CIVIL ACTION -LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, Jeremy and Anthony Strayer, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. By: Brian . Sinnett, Esquire Attorney I.D. No. 84188 2411 North Front St. Harrisburg, PA 17110 Date: S/G 2- (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this 25th day of September, 2002, 1 hereby certify that I have served rance on the following by depositing a true the foregoing Praecipe for Entry of Appea and correct copy of same in the United States mail, postage prepaid, addressed to: Sheldon A. Goodstadt, Esquire Oxman, Levitan, Goodstadt & Krevitz, P.C. 1700 Market St., Suite 3050 Philadelphia, PA 19103 Brian innett, sq 'ell J?J -ri A: Ci31_.. ,r.n CZ) SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-03799 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATILLO SCOTT VS STRAYER JEREMY ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT STRAYER ANTHONY but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT FOUND as to the within named DEFENDANT STRAYER ANTHONY IN SCHOOL AT PENN STATE, MONT ALTO CAMPUS WHICH IS Sheriff's Costs: Docketing So answxs: Service 6.00 i 3.45 Not Found 5.00 Surcharge 10.00 R Thomas Kline .00 Sheriff of Cumberland County 24.45 OXMAN GOODSTADT KREVITZ 09/06/2002 Sworn and subscribed to before me this l... day of d? 9 ,2ft-2- A.D?.? Prothonotary CASE N0: 2002_03799 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PATILLO SCOTT VS STRAYER JEREMY ET AL DAV?KINNEY Sheriff or Deputy Sheriff of Cumberland County,pennsylvania who being duly sworn according to law, says, the within COMPLAINT & NOTICE STRAYER JEREMY was served upon DEFENDANT at 12 HOURS the at 408 , on the 4th da WALNUT STREET Y of September, 2002 APT A BOILING SPRINGS, pA 17007 JEREMY STRAYER by handing to 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 So Answers: Service 18.00 Affidavit 4.83 Surcharge .00 10.00 R Thomas Kline .00 32.83 09/06/2002 OXMAN GOODSTADT KREVITZ Sworn and Subscribed to before me this By. Ja ?t day of --P -,v Sheriff .7lh7..L D. `moth notary .a SCOTT PATILLO, Plaintiff V. JEREMY STRAYER and ANTHONY STRAYER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3799 CIVIL ACTION - LAW NOTICE TO PLEAD TO: Scott Patillo c/o Sheldon A. Goodstadt, Esquire Oxman, Levitan, Goodstadt & Krevitz, P.C. 1700 Market St., Suite 3050 Philadelphia, PA 19103 YOU ARE HEREBY NOTIFIED to file a response to the enclosed New Matter within twenty (20) days of service hereof. Failure by you to do so may constitute an admission. Respectfully submitted, NEALON & GOVER, P.C. By: 9?? B an . Sinnett, squire Attorney I.D. No. 84188 2411 North Front St. /U'ZU?bZ Harrisburg, PA 17110 Date: (717) 232-9900 SCOTT PATILLO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 02-3799 JEREMY STRAYER and ANTHONY STRAYER, Defendants CIVIL ACTION - LAW ANSWER WITH NEW MATTER AND NOW comes the Defendants, Jeremy and Anthony Strayer by and through their attorneys, Nealon & Gover, P.C. and in response to Plaintiff's Complaint avers the following: 1. After reasonable investigation, Defendants are without knowledge and information sufficient to form a belief as to the truth of the averments contained in this paragraph. Strict proof of same is demanded at trial. 2. Admitted in part and denied in part. It is admitted that Defendant, Jeremy Strayer, is an adult individual, citizen and resident of the Commonwealth of Pennsylvania. By way of further answer, Defendant Jeremy Strayer's address is 408A Walnut St., Boiling Springs, PA 17007. 3. Admitted in part and denied in part. It is admitted that Defendant, Anthony Strayer, is an adult individual, citizen and resident of the Commonwealth of Pennsylvania. By way of further answer, Defendant Anthony Strayer's address is 7104C Olmstead Dr., Middletown, PA 17507. 4. It is admitted that on August 21, 2000, Defendant, Jeremy Strayer, was operating a motor vehicle owned by Defendant Anthony Strayer. All the remaining averments are denied as stated pursuant to Pa.R.C.P. 1029(e). 5. Admitted in part and denied in part. It is admitted that on or about August 21, 2000, Defendant, Jeremy Strayer, was operating a vehicle attempting to merge onto Interstate 83 in Cumberland County Pennsylvania. It is further admitted that the vehicle operated by Defendant Jeremy Strayer came in contact with the rear of a vehicle which was occupied by Plaintiff. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of the remaining averments contained in this paragraph. Strict proof of same is demanded at trial. 6. Denied as stated pursuant to Pa.R.C.P. 1029(e). 7. The averments contained in this paragraph state only conclusions of law to which no response is required. To the extent that they may be deemed factual and requiring of a response, they are denied pursuant to Pa.R.C.P. 1029(e). 8.-13. After reasonable investigation, Defendants are without knowledge or information sufficient to form a belief as to the truth of averments contained in this paragraph. Strict proof of same is demanded at trial. WHEREFORE, Defendants, Jeremy and Anthony Strayer, respectfully request that this Honorable Court enter judgment in their favor and against Plaintiff Scott Patillo. NEW MATTER 14. Paragraphs 1-13 above are incorporated herein by reference as if fully set forth at length. 15. Plaintiffs claims are barred in whole or in part by the provisions of the Pennsylvania No Fault Motor Vehicle Insurance Act and/or the Pennsylvania Motor Vehicle Financiaf Responsibility Law. WHEREFORE, Defendants, Jeremy and Anthony Strayer, respectfully request that this Honorable Court dismiss Plaintiffs Complaint and enter judgment in their favor and against Plaintiff Scott Patillo. Respectfully submitted, NEALON & GOVER, P.C. G2 Date: O Z21 By: Brian ne , E ire Attorney I.D. No. 84188 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 VERIFICATION I, Anthony Strayer, verify that the statements made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: Anthony Strayer VERIFICATION I, Jeremy Strayer, verify that the statements made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date: tz to , , A : -- --::: -- '- - Jeje-my Straye CERTIFICATE OF SERVICE AND NOW, this 21st day of October, 2002, 1 hereby certify that I have served the foregoing Answer on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Sheldon A. Goodstadt, Esquire Oxman, Levitan, Goodstadt & Krevitz, P.C. 1700 Market St., Suite 3050 Philadelphia, PA 19103 --?</? I - Brian . innett, Es re r? C. ?? r-? ^ r , .. ? l.` ?? ?? OXMAN, GOODSTADT, KREVITZ & KURITZ, P.C. BY: SHELDON A. GOODSTADT, ESQUIRE IDENTIFICATION NO.: 19547 1700 Market Street, Suite 3050 Philadelphia, PA 19103 (215)665-9999 Attorneys for Plaintiff SCOTT PATILLO Plaintiff vs. JEREMY STRAYER and ANTHONY STRAYER Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL DIVISION AUGUST TERM, 2002 NO. 02-3799 PLAINTIFF'S ANSWER TO NEW MATTER OF DEFENDANTS, JEREMY STRAYER AND ANTHONY STRAYER 14. to 15. Denied. These paragraphs are conclusions of law to which no response is required under the Pennsylvania Rules of Civil Procedure. Further, if these allegations are construed as factual, the plaintiff after reasonable investigation is without knowledge or information sufficient to form a belief as to the truth of the averments of said paragraphs and strict proof is demanded at the time of trial. WHEREFORE, the plaintiff claims damages from the defendants in an amount in excess of Fifty Thousand ($50,000.00) Dollars. OXMAN, GOODSTADT, KREVITZ & KURITZ, P.C. BY: S LDON A. GOODSTADT Attorney for Plaintiff VERIFICATION SHELDON A GOODSTADT, ESQUIRE, verifies that he is the attorney for the plaintiff in the within matter and that all statements made in this pleading are true and correct. He understands that false statements made herein are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. CL . I - ?. S V LDON A. GOODSTADT, ESQUIRE I HEREBY CERTIFY that I served a true and correct copy ofthe foregoing Plaintiffs Reply to New Matter upon defense counsel by placing same in the United States Mail, first class postage prepaid on November 15, 2002 addressed to Brian R. Sinnett, Esquire. OXMAN, GOODSTADT, KREVITZ & KURITZ, P.C. BY: ? ' Amy F. Velyl ' egal Assistant to SHELDON A. GOODSTADT, ESQUIRE Attorney for Plaintiff r? ?_ -- ;: _, ?, ? - __ ?,,:, --- ?:_ _ t; , <, r` ? ? .. ? . -? ?% _ r SCOTT PATILLO, Plaintiff V. JEREMY STRAYER and ANTHONY STRAYER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3799 CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, Jeremy and Anthony Strayer, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. By.( Michael S. Ferguso , Esquire Attorney I.D. No. 83882 2411 North Front St. Date: i 2'h 5 Harrisburg, PA 17110 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this I day of December, 2003, 1 hereby certify that I have served the foregoing Praecipe to Enter Appearance on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Sheldon A. Goodstadt, Esquire Oxman, Levitan, Goodstadt & Krevitz, P.C. 1307 White Horse Rd. Building B, Suite 200 Voorhees, NJ 08043-2119 "4- Michael S. F n o o -? C7 n-„ m CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATILLO -VS- STRAYER COURT OF COMMON PLEAS TERM, CASE NO: 02-3799 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 07/05/2004 ''??p//n ?eha i CH E1L-ZS It Attorney for DE DANT DE11-501712 5 5 9 0 7- 1,0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATILLO File No. _ 02-3799 VS. STRAYER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for NOVA ARE (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 Inc 1601 Market Street Suite Roo Philadelphia. PA 19104 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESQ. ADDRESS: 2411 N FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 0 5 2004 Date: Jtuoc pI_16nV Seal of the Court BY THE COURT: Prothonotary/Clerk, Civtl Div' Deputy 55907-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NOVACARE 680 AMERICAN AVENUE SUITE 200 KING OF PRUSSIA, PA 19406 RE: 55907 SCOTT P. PATILLO 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 : SCOTT P. PATILLO 133 HAMILTON ROAD, MARLTON, NJ 08053 Social Security #: 138-70-5610 Date of Birth: 07-07-1963 SU10-508220 5 5 9 0 7- 1, 0 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATILLO STRAYER COURT OF COMMON PLEAS TERM, -VS- CASE NO: 02-3799 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/05/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-501713 5590-7-L 02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATILLO File No. _ 02-3799 VS. STRAYER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ST. PAUL COMPANY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1501 Market St eet. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESO. ADDRESS: 2411 N FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil Div' n JUL 0 5 2004 Deputy Date: e - oa0a?l . Seal of the Court 55907-02 EXPLANATION OF REQUIRED ]RECORDS TO: CUSTODIAN OF RECORDS FOR: ST. PAUL COMPANY P.O. BOX 3570 BRANDON, FL 33509 RE: 55907 SCOTT P. PATILLO CLAIM NO.WVA6806623 09WO02 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 : SCOTT P. PATH.LO 133 HAMILTON ROAD, MARLTON, NJ 08053 Social Security #: 138-70-5610 Date of Birth: 07-07-1963 SU10-508222 55907-L 02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATILLO STRAYER COURT OF COMMON PLEAS TERM, -vs- CASE NO: 02-3799 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/05/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-501714 5 5 9 0 7- L 03 C O M M O N W E A L T H OF COUNTY OF IN THE MATTER OF: PATILLO -VS- STRAYER COURT OF COMMON PLEAS TERM, CASE NO: 02-3799 TO PRODUCE DOCUbIENTS AND NOVACARE MEDICAL RECORDS ST. PAUL COMPANY MEDICAL RECORDS COMMERCE BANK EMPLOYMENT LARCHMONT IMAGING ASSOCIATES MEDICAL RECORDS DR. KENNETH GOLDSTEIN MEDICAL RECORDS ROTHMAN INSTITUTE MEDICAL RECORDS k XRAYS TO: SHELDON A. GOODSTADT, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/14/2004 CC: MICHAEL FERGUSON, ESQ. - 02-440 MICHAEL SMOLUX - 1553866847 Any questions regarding this matter, contact P E NN S Y L VAN 2 A C UMBER LAN D MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET (1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-269069 5 5 9 0 7- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATILLO File No. _ 02-3799 VS. STRAYER SUBPOENA TO PRODUCE DOCUMENTS! OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for COMMERCE BANK (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. ]nc.. 1601 Market Srreet_ Suite 800_ Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON. ESQ. ADDRESS: 2411 N FRONT ST. HARRISBUR PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant 1 JUL 05 2004 Date: L JC???>= ?I ?6!y Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Divis' Deputy __ CC 55907-03 EXPLANATION OF REQUIRED ]RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMERCE BANK 1701 ROUTE 70 EAST CHERRY HILL, NJ 080032335 RE: 55907 SCOTT P. PATILLO INCLUDING THE MOTOR VEHICLE ACCIDENT Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : SCOTT P. PATILLO 133 HAMH.TON ROAD, MARLTON, NJ 08053 Social Security #: 138-70-5610 Date of Birth: 07-07-1%3 SU10-508224 55907-Z,03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATILLO STRAYER COURT OF COMMON PLEAS TERM, -vs- CASE NO: 02-3799 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/05/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-501715 5 5 9 0 7- 1, 0 4 C O M M O N W E A L T H COUNTY IN THE MATTER OF: PATILLO -VS- O F P E NN S Y L VAN 2 A OF C UM B E R.LAN D COURT OF COMMON PLEAS TERM, CASE NO: 02-3799 STRAYER TO SERVE A TO 1 NOVACARE MEDICAL RECORDS ST. PAUL COMPANY MEDICAL RECORDS COMMERCE BANK EMPLOYMENT LARCHMONT IMAGING ASSOCIATES MEDICAL RECORDS DR. KENNETH GOLDSTEIN MEDICAL RECORDS ROTHMAN INSTITUTE MEDICAL RECORDS k XRAYS TO: SHELDON A. GOODSTADT, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoenas 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: 06/14/2004 CC: MICHAEL FERGUSON, ESQ. - 02-440 MICHAEL SMOLUK - 1553866847 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-269069 5 5 90 7-C!02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATILLO File No. _ 02-3799 VS. STRAYER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for LARCHMONT 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 Grgyp Inc 1601 Madmi Street S„rtr 800 Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON. ESO. ADDRESS: 2411 N FRONT ST HARRISBUR P A 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JULn 0 5 2004 Date: a ?/ 1 1 d " aUGy Seal of the Court BY T?II: COURT: Prothonotary/Clerk, Civil Division Deputy 55907-04 EXPLANATION OF REQUIRED ]RECORDS TO: CUSTODIAN OF RECORDS FOR: LARCHMONT IMAGING ASSOCIATES 1295 ROUTE 38 WEST HAINESPORT, NJ 08036 RE: 55907 SCOTT P. PATILLO INCLUDE ALL IMAGING FILMS 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 : SCOTT P. PATILLO 133 HAMILTON ROAD, MARLTON, NJ 08053 Social Security #: 138-70-5610 Date of Birth: 07-07-1963 SU10-508226 5 5 9 0 7- 1, 0 4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATILLO STRAYER COURT OF COMMON PLEAS TERM, -VS- CASE NO: 02-3799 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered tc 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 rece4Lved, 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: 07/05/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-502248 55907-1,05 C O M M O N W E A L T H OF P E N N S Y L VAN T -Al COUNTY OF C U M S E R.LAN D IN THE MATTER OF: COURT OF COMMON PLEAS PATILLO TERM, -VS- CASE NO: 02-3799 STRAYER NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUM3NTS AND ..,... ..r...,.,?roov . QTTAN T(1 RTTT,Tt 4009.21 NOVACARE MEDICAL RECORDS ST. PAUL COMPANY MEDICAL RECORDS COMMERCE BANK EMPLOYMENT LARCHMONT IMAGING ASSOCIATES MEDICAL RECORDS DR. KENNETH GOLDSTEIN MEDICAL RECORDS ROTHMAN INSTITUTE MEDICAL RECORDS k XRAYS TO: SHELDON A. GOODSTADT, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena- If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/14/2004 CC: MICHAEL FERGUSON, ESQ. - 02-440 MICHAEL SMOLUK - 1553866847 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-269069 5590'7-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATILLO File No. _ 02-3799 VS. STRAYER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DR KENNETH GOi D5TEIN (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 Grouo 'nc 1601 Markrl Street Suite 800 Ehilad lphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON. ESO. ADDRESS: 2411 N FRONT ST HAMSB TRG7 PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY THE COURT: Prothonotary/Clerk, Civil ivis' JUL 0 5 2004 A I eputy Date: y(l A )?g 00.1 .Zn? Seal of the Court 55907-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DR. KENNETH GOLDSTEIN 1000 BIRCHFIELD DRIVE MT. LAUREL, NJ 08054 RE: 55907 SCOTT P. PATILLO 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 stared 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 : SCOTT P. PATILLO 133 HAMILTON ROAD, MARLTON, NJ 08053 Social Security #: 138-70-5610 Date of Birth: 07-07-1963 SU10-508228 55907-L 05 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: PATILLO STRAYER COURT OF COMMON PLEAS TERM, -VS- CASE NO: 02-3799 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 07/05/2004 MICHAEL FERGUSON, ESQ. AttoIne,r for DEFENDANT DE11-502249 55907-L 06 C O M M O N W E A L T H OP IN THE MATTER OF: PATILLO COUNTY OF, -VS- STRAYER NOTICE TO NOVACARE MEDICAL RECORDS ST. PAUL COMPANY MEDICAL RECORDS COMMERCE BANK EMPLOYMENT LARCHMONT IMAGING ASSOCIATES MEDICAL RECORDS DR. KENNETH GOLDSTEIN MEDICAL RECORDS ROTHMAN INSTITUTE MEDICAL RECORDS 6 XRAYS COURT OF COMMON PLEAS TERM, CASE NO: 02-3799 TO: SHELDON A. GOODSTADT, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/14/2004 14CS on behalf of 14ICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. - 02-440 MICHAEL SMOLUK - 1553866847 Any questions regarding this matter, contact P E NN S'Y L VAN T A CUM73ER:LAND THE MCS GROUP INC. 3.601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-269069 55907-C!02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PATILLO File No. _ 02-3799 VS. STRAYER SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ROTHMAN INSTITUTE (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 ATTACHE RIDER**** at The M Group, Inr 16QI Market Stogi. Suite Rnn Philadelphia. n 43 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESO ADDRESS: 2411 N FRONT 4T HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 0 5 ?004 Date: JU-1---m o f Seal of the Court BY THE COURT: L Prothonotary/Clerk, Civil Divisio c Deputy 55907-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ROTHMAN INSTITUTE 925 CHESTNUT STREET PHILADELPHIA, PA 19107 RE: 55907 SCOTT P. PATILLO INCLUDING ALL IMAGING FILMS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : SCOTT P. PATILLO 133 HAMILTON ROAD, MARLTON, NJ 08053 Social Security #: 138-70-5610 Date of Birth: 07-07-1963 SU10-508230 5 5 9 0 7- 10 6 .= o I H f 7D r.a n 74 !,J i.J Casey G. Shore, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 cshore@ngplawfirm.com SCOTT PATILLO, Plaintiff V. JEREMY STRAYER and ANTHONY STRAYER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3799 CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, Jeremy Strayer and Anthony Strayer, with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY By: Case . Shore, Esquir I.D. #: 85321 2411 North Front Street Harrisburg, PA 17110 717/232-9900 Date: I I tm 10 6 r-.> t ) - i ; 5.:: r..- -: r -. Michael S. Ferguson, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 mferguson@ngplawfirm.com SCOTT PATILLO, Plaintiff V. JEREMY STRAYER and ANTHONY STRAYER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3799 CIVIL ACTION - LAW PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendants, Jeremy Strayer and Anthony Strayer, with regard to the above-captioned matter. Respectfully submitted, Date: r i tv 6fo NEALON GOVER & PERRY Michael S. Ferguson, Esquire I. D. #: 83882 2411 North Front Street Harrisburg, PA 17110 717/232-9900 r 11 CERTIFICATE OF SERVICE AND NOW, this ? day of January, 2006, 1 hereby certify that I have served the foregoing WITHDRAWAL OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Sheldon A. Goodstadt, Esquire Oxman, Levitan, Goodstadt & Krevitz, P.C. 1307 White Horse Rd. Building B, Suite 200 Voorhees, NJ 08043-2119 Michael S. Ferguson, Esquire s ..? 4?; 'i1 - ??? ? ? i ?? ....i .? ? a G; __ Casey G. Shore, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 cshore@ngplawfirm.com SCOTT PATILLO, Plaintiff V. JEREMY STRAYER and ANTHONY STRAYER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3799 CIVIL ACTION - LAW PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendants, Jeremy Strayer and Anthony Strayer, with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY By: qpse?G._ghore, Esquire I. . 85321 2411 North Front Street Harrisburg, PA 17110 Date: lz?ht(. ?(0 717/232-9900 CERTIFICATE OF SERVICE AND NOW, this day of October, 2006, 1 hereby certify that I have served the foregoing WITHDRAWAL OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Sheldon A. Goodstadt, Esquire Oxman, Goodstadt, Krevitz & Kurtz, P.C. 1307 White Horse Rd. Building B, Suite 200 Voorhees, NJ 08043-2119 /--0 a y G. Shore, Esquire CD 1- ? ` t / . Jenni Henley Allen, Esquire NEALON GOVER & PERRY 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 jallen@ngplawfirm.com SCOTT PATILLO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 02-3799 JEREMY STRAYER and ANTHONY STRAYER, Defendants CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, Jeremy Strayer and Anthony Strayer, with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY By: Date: , enley Allen, Esquire I. D. N 84311 2411 N h Front Street Harrisburg, PA 17110 717/232-9900 CERTIFICATE OF SERVICE AND NOW, this day of November, 2006, 1 hereby certify that I have served the foregoing Praecipe for Entry of Appearance on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to.. Sheldon A. Goodstadt, Esquire Oxman, Goodstadt, Krevitz & Kurtz, P.C. 1307 White Horse Rd. Building B, Suite 200 Voorhees, NJ 08043-2119 s--- - ? ?? ?_R ? .+s +T' T. '? t d.r" ' -. ?? •- ? r , ,, ' ? , if, ? .?} ?,? SCOTT PATILLO, VS. Plaintiff JEREMY STRAYER and ANTHONY STRAYER, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3799 CIVIL 19 RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID- COURT: Jenni Henley Allen , counsel for thec;889ddefendant in the above action (or actions), respectfully represents that: 1. The above-captioned action fOYMUM0 is mat issue. 2. The claim of the plaintiff in the action is % 1 e s s than $ 3 5 & 0 0 0.0 0 . The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Sheldon A.1Goodstadt, Esquire and Jenni Henley Allen, EsaUire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, ORDER OF COURT AND NOW, foregoing petition, Esq., Esq., and , Esq., are appointed arbitrators in the above captioned action (or actions) as prayed for. By the Court, 19 , in consideration of the P.J. f? Y I V c -44 8 ar C1 q SCOTT PATILLO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. JEREMY STRAYER and ANTHONY STRAYER, Defendants NO. 02-3799 CIVIL 19 RULE 1312-1. The Petition for Appointment of Arbitrators shall be substantially in the following form: PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID- COURT: Jenni Henley Al 1 can , counsel for theT4888 defendant in the above action (or actions), respectfully represents that: 1. The above-captioned action "Wcl is (mat issue. 2. The claim of the plaintiff in the action is $[ less than $ 3 5 ,t0 0 0.0 0 . The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Sheldon A.lGoodstadt, Esquire and Jenni Henley Allen, Esquire WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, AND NOW foregoing petition Esq., and actions) as prayed or. ORDER OF COURT inconsideration o the Esq., Esq., are appointed arb ators in the above captioned action (or By th ourt, P.J. ,J FTI ._?i. op In The Court of Common Pleas of Cumberland Plaintiff u S ? Defendant Oath County, Pennsylvania No.0 ?.,/ : -Z !Q 97, Civil Action - Law. We do solemnly swear (or affum) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fideli Signature CS Law Firm Name Name 6d7i) Pou Log PQ S7-1E K * F L-D Law Firm Law Firm + . ! - o -ems ' 1?-31 ST Address Address ?` ?,1.? Q ?`-Ta Lemoynl - f A 17 0 Y3 City, zip City, Zip Address City, Zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award• (Note: damages for delay are awarded they shall be separately stated.) ,C? dissents. (Insert name if applicable. Niw -IM-14 Date of Hearing: 0`7 $_?,? 3 NO" -,o i M'' M I (Chairrnan) Date of Award:?Q ° y x 4 ? rt ?W ry Notice of ]Entry of Aivzrd Now, the a7+h day of , 20_0_, at 3:ALI , P.M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. ,zbitrators' CG'rinPnsatirln `lo be paid upon appeal: $ 350.00 By: Prothonotary Deputy jam L?? • EK Qlt 00 rn.- t ?i.} L/ P SCOTT PATILLO, Plaintiff V. JEREMY STRAYER and ANTHONY STRAYER, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3799 CIVIL ACTION - LAW NOTICE OF APPEAL FROM AWARD OF BOARD OF ARBITRATORS TO THE PROTHONOTARY: Notice is hereby given that Defendants Jeremy Strayer and Anthony Strayer appeal from the award of the board of arbitrators entered in this case on June 27, 2007. A copy of this award is attached hereto and incorporated herein by reference. A jury trial is demanded. hereby certify that the compensation of the arbitrators has been paid. Respectfully submitted, NEALON By: R & PERRY Matt*w R. Gover, Esquire Attorney I.D. No. 47593 2411 N. Front Street Harrisburg, PA 17110 (717) 232-9900 A In The Court of Common Pleas of Cumberland Plaintiff _ County, Pennsylvania No._ 7 S C?tZ 5 Defendant Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constituti States and the Constitution of this Commonwealth and that we will discharge the dutie with fidelitv?l Signature pSitife- I Name Law Firm Name Name 66STo Pou LOS t F1o STIE 9 -r ? c? Law Firm Law Firm ' ? . 0?-ems 9-31 MA4,p<?-r ST Address Address Address 11 \ t. L?&MoS/ f- f R 17DY3 City, zip city, zip city, n of the United of our office \IXUA lw??ioo?j Zip # ! o3a7 IF Ibt?35 -? 15?aa Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award- (Note: If damages for delay are awarde they shall be separately stated.) , dissents. (Insert nape if fz?A Date of Hearing: 0`7 W_ (Cho' ) Date of Award: c7 Notice of Entry of A,,K,ard Now, the day of JUne , 20_01_, at P.M., the ab?ve award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 350.00 By: Prothonotary Dep ty C M don Jew 0. D? c-a c) 71 ..: r-- 1 _ .:G . ?Q CERTIFICATE OF SERVICE AND NOW, this day of July, 2007, 1 hereby certify that I have served the foregoing Notice of Appeal from Award of Board of Arbitrators on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Sheldon A. Goodstadt, Esquire Oxman, Goodstadt, Krevitz & Kurtz, P.C. 1307 White Horse Rd. Building B, Suite 200 Voorhees, NJ 08043-2119 Matthew R. Gover, Esquire 'Ell 0 ? V 'DO LT) -V of 0 vp LP. m m a c c4 t? ?a W -?7 r? r? Cs C'i l a, .- f ?-c OWENS, BARCAVAGE AND MCINROY, LLC BY: Stephen J. Barcavage, Esquire Attorney I.D. No. 78867 2000 Linglestown Road, Suite 303 Harrisburg, PA 17110 (717) 909-2500 SCOTT PATILLO , Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 02-3799 JEREMY STRAYER and CIVIL ACTION - LAW ANTHONY STRAYER, Defendants ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Stephen J. Barcavage, Esqurie, Matthew L. Owens, Esquire and the law firm of Owens Barcavage and McInroy, LLC. as counsel of record for Jeremy Strayer and Anthony Strayer in the above-captioned matter. OWENS BARCAVAGE AND MCINROY, LLC. DATE: z e BY: h J. DATE: l -4 1 It BY: 2000 Linglesto Harrisburg, PA (717) 909-2509 110 Suite 303 Matthew T. Owens, Esquire ID# 76080 2000 Linglestown Road, Suite 303 Harrisburg, PA 17110 (717) 909-2500 CERTIFICATE OF SERVICE We, Stephen J. Barcavage, Esquire and Matthew L. Owens, Esquire, do hereby certify that on this day of November, 2009, we served a copy of the foregoing document via First Class United States mail, postage prepaid as follows: Sheldon A. Goodstadt, Esquire Oxman, Goodstadt, Krevitz & Kurtz, P.C. 1307 White Horse Road Building B, Suite 200 Voorhees, NJ 08043-2119 n J. Barcavage, Esquire Matthew L. Owens, Esquire FILED--OFFICE OF THE FRO77PI ?NOTAAY 1009 NOV 19 PM 2: 4 2 PEZ NNS'?LVANA 1 Casey G. Shore, Esquire 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 SCOTT PATILLO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 02-3799 JEREMY STRAYER and ANTHONY STRAYER, Defendants CIVIL ACTION - LAW PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendants, Jeremy Strayer and Anthony Strayer, with regard to the above-captioned matter. Respectfully submitted, By: Date: It it 2 as Shore, Esquire .D. No. 8 321 h Front Street Harrisburg, PA 17110 717/232-9900 t , CERTIFICATE OF SERVICE 44n4w AND NOW, this day ofPm6ebtr,02009, I hereby certify that I have served the foregoing WITHDRAWAL OF APPEARANCE on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Sheldon A. Goodstadt, Esquire Oxman, Goodstadt, Krevitz & Kurtz, P.C. 1307 White Horse Rd. Building B, Suite 200 Voorhees, NJ 08043-2119 Shore, Esquire OF THE PPG °")???}TARY 2009 NOV 19 PM 2: 4 2