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HomeMy WebLinkAbout02-4498DOUGLAS LAW OFFICE 27 W. HIGH ST. POB 261 CARLISLE PA 17013 TELEPHONE 71%243-1790 WILLIAM P. DOUGLAS, ESQ. Supreme Court I.D.//37926 Marlin Edward Leidig VS Robert K. Long, Jr. Plaintiff Defendant In the Court of Common Pleas of Cumberland County, Pennsylvania No. 02 --- 846 Civil Term Civil action law Jury Trial Demanded NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY DAYS AFTER THIS COMPLA'~[NT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATI~ORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO, THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE ']?HE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle PA 17013 717-249-3166 DATE: September 5, 2003 5. 6. 7. o Complaint The plaintiff, Marlin Edward Leidig, is an adult individual residing at 872 Belair Road, Hershey, Dauphin County, Pennsylvania. The Defendant, Robert K. Long, Jr., is an adult individual residing at 300 Maple Avenue, Marysville, Perry County, Pennsylvania. On or about, September 23, 2000, at approximately 3:15 pm the plaintiff was sitting in his vehicle at the intersection of Valley Street and Routes 11 & 15, in East Pennsboro Township, Cumberland County Pennsylvania. At about the same time and place, the defendanlt was operating his vehicle behind the plaintiff. The defendant failed to stop before striking the rear of the plaintiff's vehide. The impact occurred as a direct and proximate result of the defendant's negligence. The defendant was negligent in the following respects: a) failing to maintain a proper lookout; b) failing to drive within the assured dear distance ahead; c) failing to operate her vehicle in a safe and. prudent manner; d) failing to stop her vehicle before he collided with the plaintiff. As a direct and proximate result of the negligence of the defendant the plaintiff was injured, his injuries, and/or aggravation of his pre-existing condition(s), include but are not limited to: a) b) c) injury to his nerves and nervous system; injury to his spine and supporting structures; chronic pain; As a result of his injuries, the plaintiff has ino. trred medical expenses in the past and may continue to incur the same in the future in amounts in excess of that covered by the Pennsylvania Motor Vehicle Financial Responsibility Act. 10. As a result of his injuries, the plaintiff has incurred great pain and suffering and will continue to incur the same in the future. 11. As a result of his injuries the plaintiff has incurred aggravation, inconvenience, possible future disfigurement, disability, and a loss of life's pleasures, and will continue to incur the same in the future. 12. As a result of the injuries the plaintiff sustained on September 23, 2000, the plaintiff lost wages and the plaintiff's economic horizons may be limited. Wherefore it is prayed that judgment be entered in favor of the plaintiff and against the defendant in an amount in excess of that requiring compulsory referral to arbitration. A jury trial is hereby demanded. September 5, 2003 Respectfully submitted, AFFIDAVIT I hereby swear or affirm that the foregoing is true and correct to the best of my information and belief. This is made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom falsification to authorities. Date: September 5, 2003 William P. Dp'~glas, Esq. Attorney vast Plaintiff William P. Douglas, Esq. Supreme Court I.D. #37926 Douglas, Douglas 6 Douglas 27 W. High St. Carlisle, PA 17013 Telephone (717) 243-1790_ Marlin Edward Leidig In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No. 02- yygg Civil Term Robert K. Long, Jr. 300 Maple Avenue Marysville, PA 17053 Civil action law Defendant Jury Trial Demanded Praecipe to Issue a Writ of Summons Dear Mr. Long: Please issue a writ of summons against the defendant, Robert K. Long, Jr. date: September 18, 2002 William P. Dougla Esq. Attorney for PI tiff 0 1 0 I O GJ ? (V^?11 O 0 K (111 - J L7 ?s? r.: Commonwealth of Pennsylvania County of Cumberland WRIT OF SUMMONS Marlin Edward Leidig Plaintiff Vs. Court of Common Pleas No. 02-4498 CIVIL TERM In CivilAction-Law Robert K. Long, Jr. 300 Maple Avenue Marysville, PA 17053 Defendant To Robert K. Long, Jr. You are hereby notified that Marlin Edward Leidig the Plaintiff has / have commenced an action in Civil Action-Law against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date September 18, 2002 CURTIS R. LONG Prothonotary By ?2Gr Deputy Attorney: Name: William P. Douglas, Esq Address: Douglas, Douglas, & Douglas 27 W. High St Carlisle, PA 17013 Attorney for: Plaintiff Telephone: 717-243-1790 Supreme Court ID No. 37926 SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-04498 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LEIDIG MARLIN EDWARD VS ROBERT K JR 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 LONG ROBERT , to wit: but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within WRIT OF SUMMONS On October 1st , 2002 , this office was in receipt of the attached return from PERRY Sheriff's Costs: So answers Docketing 18.00 - `" Out of County 9.00 Surcharge 10.00 R`. Thomas Kline Dep Perry County 49.20 Sheriff of Cumberland County .00 86.20 10/01/2002 DOUGLAS DOUGLAS DOUGLAS Sworn and subscribed to before me this 7 9- day of 0ait, Zvu L A. D. Prothonotary ' In The Court of Common Pleas of Cumberland County, Pennsylvania Marlin Edward Leidig vs. Robert K. Long, Jr. No. 2002 4498 civil Now, Seot. 19 20 02 , I, SEERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Perry County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now September 27, 20 02 , at 9:25 o'clock A M. served the within writ of Summons upon Robert K. Long, Jr. at 300 Maple Ave. Marysville Borough, Pa. 17053 by handing to Robert K. Long, Jr. a True & Attested copy of the original Writ of Summons and made known to Him the contents thereof. So answers, James T. lennett djvv,9-) Deputy Sh riff of Perry County, PA COSTS Sworn and subscribed before SERVICE $ me this ,2206day of 20 0 )L- MILEAGE AFFIDAVIT FNOTARIA $ MARGARET F. FLICKINGER, NOTARY ? C BLOOMFIELD BORO., PERRY COUNTY MY COMMISSION WIRES FEB. 16 2004 IN THE COURT OF COMMON PLEAS AOF CUMBERLAND COUNTY, PENNSYLVANIA MARLIN EDWARD LEIDIG, Plaintiff V. ROBERT K. LONG, JR., Defendant NO.: 02-4498 PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of George H. Eager of the Law Firm of Eager, Reinaker & Spinello as attorney of record on behalf of Defendant in the above captioned action. EAGER, REINAKER & SPINELLO BY: George H. Eage Esquire Attorney for De ndant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for Entry of Appearance upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: William P. Douglas, Esquire Douglas, Douglas & Douglas 27 West High Street Carlisle, PA 17013 EAGER, REINAKER & SPINELLO DATE: 1 036A4 - BY: Geo a H. Eager squire Attorney for Def dant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARLIN EDWARD LEIDIG, Plaintiff V. ROBERT K. LONG, JR., NO.: 02-4498 Defendant PRAECIPE FOR RULE TO FILE COMPLAINT TO: Curtis R. Long, Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387 Please enter a Rule upon the Plaintiff to file a Complaint in the above captioned matter within twenty (20) days of the Rule or suffer a judgment of non pros. EAGER, REINAKER & SPINELLO DATE: 8 BY: George . Eage squire Attorney for endant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 AND NOW, this d of A??,p above directed. y ! • , 2003, a Rule has been entered upon the Plaintiff as Prothono ary CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for a Rule to File a Complaint upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: William P. Douglas, Esquire Douglas, Douglas & Douglas 27 West High Street Carlisle, PA 17013 EAGER, REINAKER & SPINELLO DATE: CA Z5 BY: ? - George H. ager, Esqui Attorney for Defenda I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 .? c7 7 U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARLIN EDWARD LEIDIG, Plaintiff NO.: 02-4498 V. ROBERT K. LONG, JR., Defendant ANSWER WITH NEW MATTER You are hereby notified to plead to the within New Matter within 20 days from the date of service hereto or a default judgment may be entered against you. AND NOW COMES DEFENDANT, BY AND THROUGH HIS ATTORNEY, GEORGE H. EAGER, AND FILES THE FOLLOWING ANSWER: 1.- 3. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). 4. Admitted. 5.-12. Denied in accordance with Pennsylvania Rules of Civil Procedure 1029(e). WHEREFORE, Defendant asks that judgment be entered in its favor and against the Plaintiff on all claims set forth in Plaintiffs Complaint. NEW MATTER 13. Paragraphs 1 through 12 inclusive above are incorporated herein by reference and made a part hereof. 14. Plaintiff's recovery is barred and/or limited pursuant to the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Act, 75 Pa.C.S.A. 1701, et. seq., and Answering Defendant hereby assert all of the rights and defenses available to them under the aforementioned act. 15. Plaintiff's claims are barred and/or limited pursuant to the applicable Statute of Limitations, the relevant portions of which are incorporated herein by reference. 16. Plaintiff's claims are barred and/or limited by the tort thresholds, applicable by election or law, of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa.C.S.A. §1701, et. seq. 17. Plaintiffs claims are barred and/or limited by the preclusion of pleading, proving and/or recovering special damages as set forth in §1722 of the Pennsylvania Motor Vehicle Financial Responsibility Law, Pa.C.S.A. §1722. WHEREFORE, Answering Defendant respectfully demand judgment in his favor and against all other parties together with the costs of this action. EAGER, RF_INAKER & SPINELLO BY: ! /? fL George H. Eager quire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, IPA 17601 (717) 290-7971 VERIFICATION I, ROBERT K. LONG, JR., hereby verify that I am the Defendant in the foregoing action, and that the averments of the foregoing Answers with New Matter to the Complaint are true and correct to the best of my knowledge, information and belief. To the extent that any of the averments of the Answers with New Matter to the Complaint are based upon an understanding or application of law, I have relied upon counsel in making this Verification. I understand that I am subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities for any false statements made herein Dated: ??- a 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Answer with New Matter upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: William P. Douglas, Esquire Douglas, Douglas & Douglas 27 West High Street Carlisle, PA 17013 EAGER, REINAKER & SPINELLO DATE: 03 BY:? _ George H. Eager, quire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717)290-7'971 c? ?> C cx "s3 ta U i r+t z 5;O C rn L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARLIN EDWARD LEIDIG, Plaintiff NO.: 02-4498 c2 O V. c_ 7+ LB i _0 117 1 7-1 71 ROBERT K. LONG, JR., Defendant u, " Y CERTIFICATE OF SERVICE " I HEREBY CERTIFY that I have this day served an original of Interrogatories of Defendant Addressed to Plaintiffs upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: William P. Douglas, Esquire Douglas, Douglas & Douglas 27 West High Street Carlisle, PA 17013 EAGER, REINAKER & SPINELLO DATE: 09)P314 BY: /1" 1?2 George H. Eager, Wire Attorney for Defe dant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 ?L N J r-n A CJJ '< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARLIN EDWARD LEIDIG, Plaintiff NO.: 02-4498 V. ROBERT K. LONG, JR., Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of Defendant's Request for Production and Copying of Documents - Set No. 1 Directed to Plaintiff upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: William P. Douglas, Esquire Douglas, Douglas & Douglas 27 West High Street Carlisle, PA 17013 EAGER, REINAKER & SPINELLO DATE: oIL13)n z, BY: Ge rge H. eager, quire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290=7971 :? ?R , n !!S ?' . fvV ?fti ?' (_? C c?: ro ? y' ??., ?. fir` C N `err; .n (.3 ? DOUGLAS LAW OFFICE 27 W. HIGH ST. FOB 261 CARLISLE PA 17013 TELEPHONE 717-243.1790 MARLIN EDWARD LEIDIG WILLIAM P. DOUGLAS, ESQ. Supreme Court LD.# 37926 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PLAINTIFF VS ROBERT K. LONG, JR. 4y 97 No. 02-$*6CIVIL TERM DEFENDANT To: Curtis R. Long, Prothonotary PRAECIPE CIVIL ACTION LAW JURY TRIAL DEMANDED Please attach the enclosed verification signed by the plaintiff to the original Complaint filed in this case. Douglas Lahr Office Date:October 16,2003 by V-,xl? e William P. Douglas Attorney for the plaintif ? c? ? :? ?,: -?; ? ???. - --+ ??; r., " .? rI _.y .:J W 'y COMMONWEALTH OF PENNSYLVANIA 5S. COUNTY OF CUMBERLAND 1 VERIFICATION I verify that the statements made in the foregoing document are true and correct, to the best of my knowledge, information, and belief. I understand that false statements herein made are subject to the provisions of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. Oc'? 13, eo Ax-t" Date Marlin E. Leidig r> o r;. ?? :_? , n ` (f% .? '- o - i , - f;-.. ..,. .? _.. „_ ? r' ?. :Jl .U -: C,J -c MARLIN EDWARD LEIDIG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA V. CIVIL ACTION - LAW NO. 02-4498 CIVIL TERM ROBERT K. LONG, JR. JURY TRIAL DEMANDED REPLY TO NEW MATTER 13. The allegations of paragraphs 1 through 12 of the plaintiff's original complaint are incorporated herein and reference is made thereto. 14. Denied as stated. It is admitted that the plaintiff is bound by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Act. 15. Denied. The plaintiff's claim was timely filed in accordance with the applicable statute of limitations. 16. Denied. The plaintiff elected full tort and, therefore, there is no limited tort threshold that is applicable. 17. Denied as stated. It is admitted that the plaintiff is bound by the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, it is prayed that judgment be entered in favor of the plaintiff and against the defendant. Respectfully submitted, December 2, 2003 William P. Douglas, Es uire Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) AFFIDAVIT I HEREBY SWEAR OR AFFIRM THAT THE FOREGOING IS TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE AND/OR INFORMATION AND BELIEF. THIS IS MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S./4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Ae,'G &c,?, o20D ,G Date Marlin Edward Leidig a T W "tl? III - n to C ) r z O 2 N DOUGLAS LAW OFFICE 27 W. HIGH ST. WILLIAM P. DOUGLAS, ESQ. POB 261 Supreme Court I.D.# 37926 CARLISLE PA 17013 TELEPHONE 717-243-1790 Marlin Edward Leidig In the Court of Common Pleas of Plaintiff Cumberland County, Pennsylvania vs No. 02 - 4498 Civil Term Robert K. Long, Jr. Civil action law Defendant Jury Trial Demanded Statement of Intention to Proceed To the Court: The Plaintiff Marlin Edward Leidig intends to proceed with the above captioned matter. Esq. William P. Doug kntiff Attorney for date: October 9, 2006 ?Y 4° J L j-, C .ice L1 t„f"Y ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MARLIN EDWARD LEIDIG, Plaintiff NO.: 02-4498 V. ROBERT K. LONG, JR., Defendant CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 • As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendant 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: 1 'George H. Eager, Esquire Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 SUBPOENA NOTICE OF INTENT Page 1 of 3 PENNSYLVANIA COURT OF COMMON PLEAS COUNTY OF CUMBERLAND Marlin Edward Leidig Court of Common Pleas VS. Robert K. Long, 7r. 02-4498 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 Provider: Record Type: Cary Cummings All available TO: William Douglas, Esquire note: please see enclosed list of all other interested counsel Litigation Solutions, Inc. ('LSI') on behalf of George H. Eager, Esquire 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. Date of Issue: 2/14/2007 Litigation Solutions, Inc. on behalf of: CC: George H. Eager, Esquire - Court of Common Pleas George H. Eager, Esquire Defense If you have any questions regarding this matter, please contact: Litigation Solutions, Inc. (412.263.5656) Brentwood Towne Centre 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 http://rats.litsol.com/ratsevents/notice_of intent. asp?save_report_to_db=X&PLid=PL2057... 2/14/2007 SUBPOENA NOTICE OF INTENT Page 2 of 3 COUNSEL LISTING FOR MARLIN EDWARD LEIDIG VS. ROBERT K. LONG, ]R. County of Cumberland Court of Common Pleas Counsel Firm Counsel Type Douglas, Esquire, William 57 West Pomfret Street Carlisle PA 17013 Opposing Counsel ??? aua ??no ?,??> http://rats-litsol.com/ratsevents/notice-of intent.asp?save_report_to_db=X&PLid=PL2057... 2/14/2007 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Marlin Edward Leidig FileN_o. 02-4498 VS. , Robert K. Long, Jr. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO:Cary Cummings (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: PLEASE SEE ATTACHED RIDER at 101 Towne Square Way, Suite 251 Pittsburgh, PA 15227 (Address) 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;ogrge 11' Eager, Esquire ADDRESSI3Q-7 Frui tvi l 1 P Pike Lanr_a.Gter PA, 17601 TELEPHONE:? I , --2@9 - 7 ?7 l SUPREME COURT ID-9 -7 ? 4 n__ ATTORNEY FOR. T),. f e n s e Date: - 8'. o7A? 7 Seal of the Court BY THE COUR j Prothono ary, Civil Di en Deputy SUBPOENA RIDER Rider to Subpoena Explanation of Required Documents and Things TO: CUSTODIAN OF RECORDS FOR: Dr. Cary Cummings 1617 North Front Street Harrisburg PA 17102 Attention: Records Department Subject: Leidig, Marlin SS#: 167-54-0134 Date of Birth: 3/13/1959 Page 1 of 1 Requested Items: Please remit: a complete copy of any and all documents in your possession regarding the above-named patient from 3/13/1959 to present, including but not limited to: • Medical records (charts, test results, reports, correspondence, office notes) • Films (X-rays, MRIs, CTs), Film lists http://rats.litsol.com/ratsevents/subpoena rider.asp?PLid=PL205744&WRid=WR10765 2/14/2007 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Certificate Prerequisite to Service of a Subpoena upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: William P. Douglas, Esquire Douglas, Douglas & Douglas 27 West High Street Carlisle, PA 17013 EAGER, SPINELLO, QUINN & STENGEL DATE: (53 7 I r-) BY: George H. Ea r, Esquir Attorney for Defendant I.D. No. 27740 1347 Fruitville Pike Lancaster, PA 17601 (717) 290-7971 c? ? n 5i - „ r CO J _" Yin r RGIFFA I PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: for JURY trial at the next term of civil court. ? for trial without a jury. CAPTION OF CASE (entire caption must be stated in full) (check one) fl Civil Action -Law MARLIN EDWARD LEIDIG ? Appeal from arbitration (other) (Plaintiff) VS. The trial list will be called on 0 6 / 0 2 / 0 9 and ROBERT K. LONG, JR 06/29/09 Trials commence on (Defendant) Pretrials will be held on 0 6 / 10 / 0 9 VS. (Briefs are due S days before pretrials No. 02-4498 , -Term indicate the attorney who will try case for the party who files this praecipe: John P Stencil, Esquire Indicate trial counsel for other parties if known: William P. Douglas, Esquire This case is ready for trial. Signed: Print Name: Date: © Attorney for: Stenqel, Esquire Defendant 1 1 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing Praecipe for Listing Case for Trial upon the person set forth below and in the manner indicated: First class mail, postage pre-paid: William P. Douglas, Esquire Douglas, Douglas & Douglas 27 West High Street Carlisle, PA 17013 EAGER, SPINELLO, QUINN & STENGEL 71 DATE: 5 BY: Joh" I Sten I, Esquire Atto eys for efendant 1347 Fruitvill Pike Lancaster, PA 17601 (717) 290-7971 Atty. I.D. No. 64041 RLBX)FRGE OF THE i 'n-OWTARY 249 APR -1 M 2: 19 CUMK. riu?-4Lj WUNTY PBV4SYLVANIA r 7,1 MARLIN EDWARD LEIDIG, Plaintiff v ROBERT K. LONG, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02-4498 CIVIL TERM IN RE: CASE STRICKEN FROM LIST ORDER OF COURT AND NOW, this 2nd day of June, 2009, upon consideration of the call of the civil trial list, and no counsel having called the above-captioned case for trial, it is stricken from the trial list. ?william P. Douglas, Esquire 43 West South Street P.O. Box 261 Carlisle, PA 17013 For Plaintiff ?John P. Stengel, Esquire 53 North Duke Street Lancaster, PA 17602 For Defendant Court Administrator :mae GQ.? ma.?lSR? to C`oq By the Court, a6of .Ju, - 3 RPZ 16-31 (21-LmSez1 aicL 0,0s? PE-A.J J Sy (. LUG v t Ir- MARLIN EDWARD LEIDIG, IN THE COURT OF COMMON PLEA F `+ PLAINTIFF :CUMBERLAND COUNTY, PENNSY I/~`, "" fTi L3 ROBERT K. LONG, JR., ,~~ W -~- R~ DEFENDANT NO. 02-4498 CIVIL ~~' ~ ,.,_ r ~ ~ IN RE: PRE-TRIAL CONFERENCE ORDER OF COURT AND NOW, this 8th day of September, 2010, after Pre-Trial Conference with Counsel in this matter, IT IS HEREBY ORDERED AND DIRECTED that: 1. Trial counsel in this case shall be William Douglas, Esquire for Plaintiff and George Eager, Esquire for Defendant. 2. There are no schedu{ing or judicial conflicts in this matter. 3. Counsel have indicated that trial will take approximately 2 days. 4. Each party will be granted four peremptory chal{enges. 5. There is no need for a view in this matter. 6. Given the brief nature of the case, afl counsel have agreed that jurors will not be allowed to take notes. 7. All parties have been directed to prepare an exhibit list. Two copies of this exhibit list shall be provided to the Court prior to the commencement of trial. All visual aids used in the case shall be disclosed to the opposing party. 8. Counsel for each party is directed to file with the Court on or before 12:00 p.m. on September 17, 2010, a list of the numbered standard jury instructions the party is requesting. If a party is proposing a unique jury instruction or requesting significant modification of a standard instruction, it shall provide the full text of the proposed instruction to the Court. 9. On or before 12:00 p.m. on September 17, 2010, the parties will provide a proposed verdict slip to the Court for review. 10. The parties shall submit proposed voir dire questions to the Court for review on or before September 17, 2010. -~ William P. Dou las Es uire 9 ~ q Attorney for Plaintiff .~ George H. Eager, Esquire Attorney for Defendant By the Court, ~~ M. L. Ebert, Jr., J. Court Administrator - ~S bas a) ~~ ~O 1 £S I'Yt.~t 4 S~ tv l