0758987.01 

 IN THE UNITED STATES DISTRICT COURT 

 FOR THE EASTERN DISTRICT OF PENNSYLVANIA 

KRISTIN PEREZ HAINES : CIVIL ACTION 

: 

v. : 

: 

RODNEY GENE LEE and : 

NORTHSTAR TRUCKING SERVICES, INC. : NO. 02-CV-4432 

ORDER

AND NOW, this day of , 2002, it is hereby ORDERED and 

DECREED that the discovery deadline is extended for sixty (60) days. All other deadlines shall 

be extended accordingly. 

BY THE COURT: 

____________________________________ 

J. 

Case 2:02-cv-04432-BWK Document 12-2 Filed 12/17/2002 Page 1 of 6
0758987.01 

 IN THE UNITED STATES DISTRICT COURT 

 FOR THE EASTERN DISTRICT OF PENNSYLVANIA 

KRISTIN PEREZ HAINES : CIVIL ACTION 

: 

v. : 

: 

RODNEY GENE LEE and : 

NORTHSTAR TRUCKING SERVICES, INC. : NO. 02-CV-4432 

 MOTION TO EXTEND DISCOVERY

Defendants, Rodney Gene Lee and Northstar Trucking Services, Inc., by and through their 

attorneys, Rawle & Henderson LLP, request this Court grant the Motion to Extend Discovery and in 

support avers as follows: 

1. On July 3, 2002, plaintiffs filed a Complaint in the United States District Court for 

the Eastern District of Pennsylvania for personal injuries allegedly arising out of a motor vehicle 

accident on August 3, 2000. 

2. An Amended Complaint was filed by plaintiff on August 1, 2002. 

3. In the Complaint, plaintiff, Kristin Perez-Haines, alleged that as a result of the 

accident with defendant, Lee, she sustained injuries to the neck and back including herniated disks in 

the cervical and lumbar spine. 

4. Plaintiff also claims that she is completely disabled as a result of the injuries 

sustained in this accident and is receiving Social Security benefits for her disability. 

5. Plaintiff is seeking recovery for a diminution in earning capacity as well claims for 

past and future medical expenses and pain and suffering. 

6. According the Scheduling Order dated October 17, 2002, discovery was to be 

completed by December 17, 2002. Plaintiff’s expert reports are due on January 30, 2003 and 

defendant’s expert reports are due on February 28, 2003. 

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0758987.01 

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7. The parties have worked diligently in an effort to complete discovery within the time 

frame set forth by the Court. However, there is still some discovery that remains. 

8. On October 31, 2002, defendants subpoenaed the records of plaintiff’s medical and 

insurance providers identified in Plaintiff’s Initial Disclosures. 

9. The parties also exchanged discovery requests. Included with defendant’s Request 

for Production of Documents to plaintiff, defendants request that plaintiff complete and return an 

authorization for income tax records, social security records, employment and education records. 

10. On December 12, 2002, defendant received plaintiff’s response to Interrogatories and 

Request for Production of Documents. Defendant has not received the requested authorizations. 

However, plaintiff has agreed to provide the authorizations for the social security records and supply 

income tax returns. 

11. Defendant is still awaiting a response to the subpoena of records to Lancaster General 

Hospital, Radiology Dept.; The MRI Group; Evan O’Brien, M.D.; Lancaster Lincoln Mercury. 

Furthermore, although defendant received some records from State Farm, they have informed 

defendants that there are other portions of the file relating to other accident claims which were not 

initially provided, but will be provided. 

12. The records recently received by defendant pursuant to discovery, reference prior 

accidents and treatment of plaintiff by other medical providers. Defendant has subpoenaed those 

records, however, they remain outstanding. 

13. Additionally, Kristin Perez-Haines and Rodney Gene Lee were recently deposed on 

December 12, 2002. At her deposition, Perez-Haines identified her previous employers and the 

educational institutions that she has attended. Defendant subpoenaed those records, however, they 

will not be received by the discovery deadline. 

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14. These records are necessary in order for defendants to adequately evaluate and 

prepare a defense to the claims asserted by plaintiff, including claims for pain and suffering and 

diminution in earning’s capacity. 

15. Plaintiff Perez-Haines also testified at her deposition that she was married on 

November 4, 2000, three months after the accident and that the event was photographed and 

videotaped. Defendant has requested a copy of the video of the wedding via a Supplemental 

Request for Production of Documents. 

16. Plaintiff has reviewed this motion and has no objection to the extension for sixty (60) 

days. Plaintiff does request that all discovery deadlines be extended accordingly. 

17. In light of the above, plaintiff and defendants request a sixty (60) day extension of the 

discovery deadline to allow time to receive the records subpoenaed, as well as those identified by 

plaintiff at her deposition and to permit defendant to obtain the complete Social Security file, income 

tax returns, education and employment records. The extension will also provide adequate time for 

plaintiff to provide a response to the request for the videotape of the November 4, 2000 wedding of 

plaintiff. 

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0758987.01 

WHEREFORE, defendants request that this Honorable Court grant the Motion to Extend the 

deadline for discovery for 60 days. All other discovery deadlines shall be extended accordingly. 

RAWLE & HENDERSON LLP

By:________________________________ 

Timothy J. Abeel, Esquire 

Identification No. 23104 

Dawn L. Jennings, Esquire 

Identification No. 68939 

The Widener Building 

One South Penn Square 

Philadelphia, PA 19107 

215-575-4200 

Attorneys for Defendants, 

Rodney Gene Lee and 

Northstar Trucking Services, Inc. 

Case 2:02-cv-04432-BWK Document 12-2 Filed 12/17/2002 Page 5 of 6
0758987.01 

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CERTIFICATION OF SERVICE

I hereby certify that on today's date I served a true and correct copy of the foregoing Motion 

to Extend Discovery by facsimile and first-class mail, postage prepaid, upon all attorneys and 

interested parties addressed as follows: 

Gregg R. Durlofsky 

111 West Germantown Pike 

Plymouth Meeting, PA 19642 

RAWLE & HENDERSON LLP

By:________________________________ 

Timothy J. Abeel, Esquire 

Identification No. 23104 

Dawn L. Jennings, Esquire 

Identification No. 68939 

The Widener Building 

One South Penn Square 

Philadelphia, PA 19107 

215-575-4200 

Attorneys for Defendants, 

Rodney Gene Lee and 

Northstar Trucking Service, Inc. 

DATED: 

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