LAW COURT, KINGSPORT, SULLIVAN COUNTY, TENNESSEE
DIANA L. HARSHBARGER and
ROBERT HARSHBARGER,
Plaintiffs,
Civil Action No. €32027,,
HAROLD R. PARTIN, G&R —
TRUCKING COMPANY and
CMH MANUFACTURING, INC., =
Defendants.
MOTION FOR SUBSTITUTION AND/OR JOINDER OF PARTY PLAINTIFF
Comes American Inhalation Medication Specialists, Inc., a/k/a American Inhalation
Medialist, pursuant to Tenn, R. Civ, P. Rules 19.01 and 25.03, and moves it be substituted
and/or joined as a party Plaintiff to the above-captioned action with respect to the claim for
property damage to the vehicle being driven by Plaintiff Diana L. Harshbarger for the following
reasons:
1, This action was originally filed by Plaintiffs Diana L. Harshbarger and Robert
Harshbarger, who are the shareholders of American Inhalation Medication Specialists, Inc.
2. Paragraph 10 of the original Complaint states the Plaintiff Diana L. Harshbarger
sustained among other damages property damage to the vehicle she was operating which was
involved in the automobile collision which is the subject of this litigation.
3. Subsequent investigation reveals the vehicle Plaintiff Diana L. Harshbarger was
operating at the time of the subject automobile collision was in fact owned by American Inhalation
Medication Specialists, Inc.
WHEREFORE, premises considered, American Inhalation Medication Specialists, Inc.
moves it be substituted and/or joined as a party Plaintiff with respect to the claim for property
damage sustained to the vehicle operated by Plaintiff Diana Harshbarger which was involved in
the subject automobile collision,Respectfully submitted,
AMERICAN INHALATION MEDICATION SPECIALISTS, INC.
Jesse & Jessee
P. O. Box 997
Johnson City, TN 37605-0997
(423) 928-9650
Thomas C.tessee fy 77
B.P.R. No. 000113 vh
american tp
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and exact copy of the foregoing Motion for
Substitution and/or Joinder of Party has been forwarded to the following persons by posting a copy
in the United States Mail, with sufficient postage thereon to carry the same to its destination,
addressed as stated below:
1. Rodney S. Klein
Klein & Associates
108 Main Street, Suite 212
Kingsport, TN 37660
2. W. Tyler Chastain
Bernstein, Stair & McAdams
530 South Gay Street, Suite 600
Knoxville, TN 37902
3. Ms. Debra A. Thompson
Baker, McReynolds, Byrne, O'Kane, Shea & Townsend
607 Market Street, Eleventh Floor
P. O. Box 1708
Knoxville, TN 37901-1708
4. Mr, Harold R, Partin
300 Main Street, #1
New Tazewell, TN 37825
This Z day of Ze] _, 2000.
zi in” KE
BPR O185-97
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