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Home My WebLink About02-4856IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 0;-- Civil Action - (XX) Law ( ) Equity CHRISTINE E. LACKEY 319 Walton Street Lemoyne, PA 17043 EDGAR L. DYSON 1952 Chestnut Street Camp Hill, Pa 17011 versus Plaintiff(s) & Address(es) Defendant(s) & Address(es) PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. Peter B. Foster, Esquire PINSKEY & FOSTER 12t South Street Harrisburg, PA 17101 (717) 234-9321 Writ of Summons shall be issued and forwarded to ( ) Attorney (XX) Sheriff Signature of Attorney Supreme Court ID No. 15357 Date: October 4, 2002 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAtNST YOU. Prothonotary ¢. ty '/I ( ) Check here if reverse is issued for additional information. SHERIFF'S RETURN CASE NO: 2002-04856 p COMMONWEALTH OF PENNSYLVANIA: COUNTy OF CUMBERLAND LACKEY CHRISTINE E VS DYSON EDGAR L REGULAR CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland CountY, Pennsylvania, who being duly SWorn according to law, Says, the within WRIT OF SUMMONS was served upon DYSON EDGAR L DEFENDANT at 1834:00 HOURS, at 1952 CHESTNUT STREET CAMp HILL, PA 17011 EDGAR L DYSON the on the 10t_~h day of October , by handing to 2002 a true and attested Copy of WRIT OF SUMMONS together with and at the same time directing Hi~s attention to the COntents thereof. Sheriff,s Costs: Docketing Service Affidavit Surcharge 18.00 9.66 .00 10.00 .00 37.66 Sworn and Subscribed to before me this ~ day of ~-~ ~ A.D. So Answers: 10/14/2002 PETER FOSTER CHRISTINE E. LACKEY, Plaintiff Mo EDGAR L. DYSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 02-4856 Civil : : JURY TRIAL DEMANDED ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter the appearance of the undersigned as counsel on behalf of the Defendant, Edgar L. Dyson, in the above-captioned case. DATE: Iblgl j'oJk MARSHALL, DENNEHEY, WARNER, COL~.~~-GOGGIN ~'~RON ]VI. O'I~ONN~LI~ ESQUIRE ~ I.D. No. 79457 ~200 Crams Mill Road, Suite B ]Harrisburg, PA 17112 / (717) 651-3503 Attorney for Defendant CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dermehey, Warner, Coleman & Goggin, do hereby certify that on this &[,~l. day of October, 2002, a true and correct copy of the foregoing document was served via U.S. first-class mail, postage pre-paid, as follows: Peter B. Foster, Esquire PINSKEY & FOSTER 121 South Street Harrisburg, PA 17101 SUSAN M. WILLIAMS CHRISTINE E. LACKEY, Plaintiff Vo EDGAR L. DYSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-4856 Civil : : JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE A COMPLAINT TO THE PROTHONOTARY: Kindly issue a Rule upon the Plaintiffto file a Complaint within twenty (20) days hereof or suffer judgment non pros. MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN ~S~IARON M. O'DONNELL, ESQEgI~ IjD. No. 79457 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3503 Attorney for Defendant CERTIFICATE OF SERVICE I, Susan M. Williams, an employee with the law firm of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this ,~+t~ day of November, 2002, a true and correct copy of the foregoing document was served via U.S. first-class mail, postage pre-paid, as follows: Peter B. Foster, Esquire PINSKEY & FOSTER 121 South Street Harrisburg, PA 17101 SUSAN M. WILLIAMS CHRISTINE E. LACKEY, Plaintiff Vo EDGAR L. DYSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-4856 Civil : : JURY TRIAL DEMANDED RULE H AND NOW, this ~,~'~'day of~ 2002., upon consideration of the foregoing Praecipe, a Rule is hereby issued upon the Plaintiff, Christine E. Lackey, to file a Complaint within twenty (20) days or suffer judgment of non pros. BY THE PROTHONOTARY: SEAL CRRTIFICATR PRRRROUISITR TO SRRVICR OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: CHRISTINE E. LACKEY COURT OF COMMON PLEAS TERM, EDGAR L. DYSON -VS - CASE NO: 02-4856 CIVIL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of SHARON 0'DONNELL, 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: 12/12/2002 Attorney for DEFENDANT DEll-381210 13 7 73 --LO COMMONWEALTH COUNTY OF PENNSYLVANIA CUMBERLAND IN THE MATTER OF: CHRISTINE E. LACKEY -VS- EDGAR L. DYSON COURT 0F COMMON PLEAS TERM, CASE NO: 02-4856 CIVIL NOTICR OF INTRNT TO SRRVR A SUBPORNA TO P~ODU~ DOC~-~S AI~,, . TH ~ FOR DISC~J~d(~ Pu~Up~,~ ~ R~_-H,R 4009.21 [ Note: see enclosed list of locations ] TO: PETER B. POSTER, ESQUIRE NCS on behalf of SHARON O'DONNELL, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20} days fros 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 sase to ~CS or by contacting our local NCS office. DATE: 11/22/2002 CC: SHARON 0'DONI~LL, ESQ. PAMELA S. JUN~-~LLS - 13241-00200 Any questions regarding this matter, contact MCS on behalf of SHARON 0'DO1FNRLL, ESQ. Attorney for DEFENDANT T~IE ~CS GROUP INC. 1G01 NARF,~T STREET ~00 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-208129 · 3 7 7 3 --CO 2 LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS RE~SSTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL COMMUNITY FAMILY MEDICAL CTR SUSQUEHANNA VALLEY SURGERY CTR HEALTHSOUTH REHAB. CENTER COMMUNITY GENERAL OSTEOPATHIC COMMUNITY GENERAL OSTEOPATHIC NEST SHORE EMERGENCY MEDICAL JAMIE L.HETTICK,MD MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILI'.ING, AND ][-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-208129 13 773--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND - CHRISTINE E. LACKEY VS EDGAR L.DYSON File No. 02-4856 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THING£ .FOR DISCOVERY PURSUANT TO RULE 4009o* TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPIT,~/, (N~m, of F~r~on or Within twenty (20) days after service of this subp~n~ ~'l"fA~;ti~O court to produce the following document~ or things: ~u~ .ar~e.grd_ered by the at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 119103 You may deliver or mail legible copie~ of the document~ or produce thing~ requeeted by this subpoena, together with the certificate of compliance, to the party making this requ~t at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copiee or producing the thing~ sought. If you fail to produce the documents or thing~ required by this subpoena, within twenty (20) days after it~ 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: NAM~ SHARON M, 0'DONNELL~ ESQ. ADDRESS: 4200 CRUMS MILL RD., STE.B HARRISBURG, PA 17112 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT 12/12/2002 Seal of the Court (Eft. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL' 503 N. 21 ST STREET CAMP HILL, PA 17011 RE: 13773 CHRISTINE E. LACKEY Entire hospital medical billing frie including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, fries, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, tests, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis~ care, treatment, admission, discharge, Or emergency care pertaining to: Dates Re. quested: up to and including the present. Subject. CHRIS~ E. LACKEY 319 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 20%44-5025 Date of Birth: 07-23-1957 SU10-411820 ~3 7 73 --LO 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: CHRISTINE E. LACKEY COURT OF COMMON PLEAS TERM, EDGAR L. DYSON -VS- CASE NO: 02-4856 CIVIL As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of SHARON O'DONNELL, 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: 12/12/2002 MCS on behalf of SHARON O'DONNELL, ESQ. Attorney for DEFENDANT DEll-381211 1 3 7 7 3 --LO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: CHRISTINE E. LACKEY -VS- EDGAR L. DYSON COURT OF COMMON PLEAS TERM, CASE NO: 02-4856 CIVIL NOTIC~ OF INTENT TO S~RV~ & SUB~_PO]~IA TO P~OnU~ ~S AN~. · £u~z~ FOR DISC~%~Y PU~UA~ TO R~.~ 4009.21 [ Note: see enclosed list of locations ] TO: PETER B. FOSTRR, ESQUIRE NCS on behalf of S~ARON 0'DONNELL, 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 valved 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 ~CS or by contacting our local MCS office. DATE: 11/22/2002 CC: SBARON 0'DONNELL, ESQ. PAMELA S. JUN~-WELLS - 13241-00200 Any questions regarding this matter, contact MCS on behalf of SHARON 0'DONNELL, ESQ. Attorney for DEFENDANT THE ~CS GROUP INC. 1601 MA~ STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-208129 13 773 --C02 LOCATION LIST ¢<< PAGE: 1 LOCATION N~ RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL COMMUNITY FAMILY M~DICAL CTR SUSQUEHANNA VALLIP/ SURGERY CTR HEALTHSOUTH REHAB. CENTER COMMUNITY GENERAL OSTEOPATHIC COMMUNITY GENHRAL OSTEOPATHIC NEST SHORE ENI/RGENCY MEDICAL JAMIE L.HETTICK,MD MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL NEDICAL, BILl, lNG, AND X-RAY(S) MEDICAL, BILl, lNG, AND X-RAY(S) DE02-208129 i 3 7 7 3 --CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRISTINE E. LACKEY VS EDGAR L.DYSON File No. 02-4856 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THING8 FOR DISCOVERY PURSUANT TO RULE 4009-2~ TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL (Name of Per,on or Entity) Within twenty (20) days after service of this subp_oe._n_a, l,o_u_ .arg_9rd_ered by the cout~ to produce the following documents or things: . SPli~ ATTACHED at MCS GROUP INC,, 1601 MARKET ST,, #800, PHILA,,PA 19103 (Add,sa} 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 produdng the things sought. If you fail to produce the documents or things requited by this subpoena, v~lthin twenty (20} days after its service, the party serving this subpoena may seek a court order compelling you to comply wit'h it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAM~ SFtARON H, Q'DONNELL, ESQ. ADDRESS: 4200 CRUMS MILL RD., STE.B HARRISBURG, PA 17112 TELEPHONF~ 215-246-0900 SUPREME COURT ID ~. A'I'rORNEY FOR: DEFENDANT DATE: /U~-/~ [ f' ~ ~ 0 Seal of the Court 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 N. 21 ST STREET CAMP HILL, PA 17011 RE: 13773 CHRISTINE E. LACKEY INCLUDING ANY AND ALL MRI'S, CT SCANS, EEG'S ,OR OTHER DIAGNOSTIC MATERIALS AND LAB REPORTS. Any and all x-ray fdms and reports, including any and all suclh 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: CHRISTINE E. LACKEY 319 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 207-44-5025 Date of Birth: 07-23-1957 SU10-411822 13 7 73 --LO 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: CHRISTINE E. LACKEY COURT OF COMMON PLEAS TERM, EDGAR L. DYSON -VS- CASE NO: 02-4856 CIVIL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of SHARON 0'DONNELL, 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: 12/12/2002 MCS on behalf of SHARON 0'DONNELL, ESQ. Attorney for DEFENDANT DEll-381212 13 7 73 --LO 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: CHRISTINE E. LACKEY -VS- EDGAR L. DYSON COURT OF COMMON PLEAS TERM, CASE NO: 02-4556 CIVIL NOTICE OF -rt~/~,s FOR DISCx~¥~atY t~JW-_~UAiTE TO ~_Wr,~ 4009.21 [ Note: see enclosed list of locations ] TO: PETER B. FOSTER, ESQUIRE #CS on behalf of SHARON 0'DONNELL, 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 ~CS or by contacting our local MCS office. DATE: 11/22/2002 CC: SHARON O'DONI~LL, ESQ. PAMELA S. JUlY-WELLS - 13241-00200 Any questions regarding this matter, contact MCS on behalf of SHARON O'DONI~LL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215} 246-0900 DE02-208129 13 7 7 3 --CO 2 LOCATION LIST ¢<< PAGE: 1 LOCATION NAI~ RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL COMMUNITY FAMILY MEDICAL CTR SUSQUEHANNA VALLEY SURGERY CTR HEALTHSOUTH REHAB. CENTER COMMUNITY GENER/~ OSTEOPATHIC COMMUNITY GEIWgRAL OSTEOPATHIC NEST SHORE E~RGENCY ~DICAL JAMIE L.HETTICK,MD ~DICAL RECO~S & HOSPITAL BILL X-RAY ONLY ~DICAL, BILLI~, ~ X-RAY(S) ~DICAL, BILLING. AND X-RAY(S) ~DICAL, BILLING, AND X-WY(S) X-RAY ONLY ~DICAL RECO '~S & HOSPITAL BILL ~DICAL, BILLING, A~ X-RAY(S) ~DICAL, BILLING, AND X-RAY(S) DE02-208129 i 3 7 7 3 --CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRISTINE E. LACKEY VS EDGAR L.DYSON File No. 02-4856 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THING~ FOR DISCOVERY PURSUANT TO RULE 4009.29 TO: CUSTODIAN OF RECORDS FOR: COMMUNITY FAMILY MEDICINE CENTER (Name of Person or Entity} Within twenty (20) days after service of this subp_oe_n_a, lto_u_ .ar_e_p_rd_ered by the cour{ to produce the following documents or things: Sl~l~ A'I.'TAUHED at MCS GROUP INC., 1601 MARKET ST., #800, PHILA. ,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 fight 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: SHARON M, 0'DONNELL, ESQ. ADDRESS: 4200 CRUMS MILL RD., STE.B HARRISBURG, PA 17112 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: 12/12/2002 Seal of the Court (Elf. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMUNITY FAMILy MEDICAL CTR 4300 LONDONDERRY ROAD HARRISBURG, PA 17109 RE: 13773 CHRISTINE E. LACKEY INCLUDING ANY AND ALL MRI'S, CT SCANS, EEG'S OR OTHER DIAGNOSTIC MATERIALS, LAB REPORTS. 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, fries, memoranda, handwritten notes, history and physical reports, medicatiordpresc.ri.?tion records, medical billing and payment records, x-ray films, and test~s .wire subsequent reports, including any and all such items as may I~e stored m 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: CHRISTINE E. LACKEY 319 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 207-~.~. 5025 Date of Birth: 07-23-1957 SU10-411824 I 3 7 7 3 --LO 3 CRRTIFICATR PRERRQUISITR TO SRRVICR OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: CHRISTINE E. LACKEY COURT OF COMMON PLEAS TERM, EDGAR L. DYSON -VS- CASE NO: 02-4856 CIVIL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of SHARON 0'DONNELL, 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: 12/12/2002 MCS on behalf of SHARON O'DONNELL, ESQ. Attorney for DEFENDANT DEll-381213 13 7 73 --LO4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: CHRISTINE E. LACKEY -VS- EDGAR L. DYSON COURT 0F COMMON PLEAS TERM, CASE N0: 02-4856 CIVIL NOTICI~ OF INTENT TO SERVI~ A SUBPOENA TO P~ODUCB IX)CUMBNTS AND. · r~ FOR DISC.'Ovm(~' L-'UK~ TO RUI',~ 4009.21 [ Note: see enclosed list of locations ] TO: PETER B. FOSTER, ESQUIRE NOS on behalf of SHARON O'DONNELL, ES9. :intends to serve a subpoena identical to the one that is attached to this notice. You have teenty (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 NCS or by contacting our local NCS office. DATE: 11/22/2002 CC: SHARON O'DONNELL, ESQ. PAMELA S. JUN~-WELLS - 13241-00200 Any questions regarding this matter, contact MCS on behalf of SHARON 0'DONNELL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 24~-0900 DE02-208129 13 773--C02 LOCATION LIST <<< PAGE: 1 LOCATION NA~E RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL CO~04UNITY FAMILY MEDICAL CTR SUSQUEHANNA VALLEY SURGERY CTR HEALTHSOUTH REHAB. CENTER COMMUNITY GENERAL OSTEOPATHIC COMMUNITY GENERAL OSTEOPATHIC NEST SHORE EMERGENCY MEDICAL JAMIE L.HETTICK,MD MEDICAL RECOP. DS & HOSPITAL BILL X-PAY ONLY MEDICAL, BILLING, AND X-PAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL, EIL]'.ING, AND X-RAY(S) DE02-208129 13 7 7 3 --CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRISTINE E. LACKEY VS EDGAR L.DYSON File No. 02-4856 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THING~ FOR DISCOVERY PURSUANT TO RULE 4009.29 TO: CUSTODIAN OF RECORDS FOR: SUSQUEHANNA VALLEY SURGERY CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, o_u_.ar,,e.grd_,ered by the cour~to things: . -SEE ~']."l.'At;til~L~ produce the following documents or at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Add~} You may deliver or mail legible copies of the documents or produce thin~s requested by this subpoena, together with the certificate of compliance, to the pm~y m~king this request at the address listed above. You h~ve the right to seek, in advance, the reasonable cost of preparing the copies or producing the thin~ sought. If you fail to produce the documents or thin~s required by this subpoena, within twenty (20) d~ys after its service, the party serving this subpoena may s~k a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NANIE: SHARON ~, 0'DONNELL, ESQ. ADDRESS: 4200 CRUMS MILL RD., STE.B HARRISBURG, PA 17112 TELEPHON~ 215-~46-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: 12/12/2002 Se~oftheCourt EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SUSQUEHANNA VALLEY SURGERY CTR 4310 LONDONDERRY RD. HARRISBURG,, PA 17109 RE: 13773 CHRISTINE E. LACKEY INCLUDING ANY AND ALL MRI'S, CT SCANS, EEG'S, OTHER DIAGNOSTIC MATERIALS AND LAB REPORTS. 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, fries, memoranda, handwritten notes, history and iphysical 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: CHRISTINE E. LACKEY 319 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 207-4~ 5025 Date of Birth: 07-23-1957 SU10-411826 · 3 7 7 3 --LO 4 CERTIFICATR PRgRROUISITR TO SERVICg OF A SUBPORNA PURSUANT TO RULE 4009.22 IN THE MATTER OF: CHRISTINE E. LACKEY COURT OF COMMON PLEAS TERM, EDGAR L. DYSON -VS - CASE NO: 02-4856 CIVIL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of SHARON 0'DONNELL, 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: 12/12/2002 MCS on behalf of SHARON 0'DONNELL, ESQ. Attorney for DEFENDANT DEll-381214 13 7 73 --LO 5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: CHRISTINE E. LACKEY -VS- EDGAR L. DYSON COURT OF COMMON PLEAS TERM, CASE N0:02-4856 CIVIL NOTIC~ OF ~ TO S~I~V~ A SUB__PO~K_ TO PRODU_f~ ~S ANn. i'u~ FOR DISC~v~d(Y Pu-$ta%ef£ TO l~_r~.~ 4009.21 [ Note: see enclosed list of locations ] TO: PETER B. FOSTER, ESQUIRE MCS on behalf of SHARON O'DONNELL, 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 undersisned 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 completin9 the attached counsel card and returnin9 same to MCS or by contactin9 our local MCS office. DATE: 11/22/2002 CC: SHARON 0'DONNELL, ESQ. PAMELA S. JUNE-~LLS - 13241-00200 Any questions resardin9 this matter, contact MCS on behalf of SHARON O'DONNELL, ESQ. Attorney for DEFENDANT TEE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-208129 I 3 7 7 3 --CO 2 LOCATION LIST <¢< PAGE: 1 LOCATION NP24E RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL CO~9~INITY FAMILY MEDICAL CTR SUSQUEHANNA VALLEY SURGERY CTR HEALTHSOUTH REHAB. CENTER COMMUNITY GENERAL OSTEOPATHIC COMMUNITY GENERAL OSTEOPATHIC WEST SHORE EMERGENCY MEDICAL JAMIE L.HETTICK,MD NEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-208129 13 773--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRISTINE E. LACKEY VS EDGAR L.DYSON File No. 02-4856 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THING£ FOR DISCOVERY PURSUANT TO RULE 4009,99 TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH REHAB. CENTER (NameofPe~onorEn~) Withintwen~(20) days ~terserviceofthissubp_oe~,Vou ~e°rderedbytlhecou~toproducethefollowingd~umentsor things: ~ ATTACHED al MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 You may deliver or mail legible copies of the do~aments 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 preparin~ the copies o~ p~odu¢in~ the things sought. If you fail to produce the documents or things requited by this subpoena, within twenty (~0) days a~ter its service, the party servin$ this subpoena may seek a ~ourt orde~ eompeHin$ you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAM~ SF~ARON H, O'DONNELL, ESQ. ADDRESS: 4200 CRUMS MILL RD., STE.B HARRISBURG~ PA 17112 TELEPHONE: 215-246-0900 SUPREME COURT ID #: A~'rORNEY FOR: DEFENDANT 12/12/2002 DATE: -~ Se~l of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH REHAB. CENTER 503 BRIDGE STREET NEW CUMBERLAND, PA 17070 RE: 13773 CHRISTINE E. LACKEY INCLUDING ANY AND ALL MRI'S, CT SCANS, EEG'S OR OTHER DIAGNOSTIC MATERIALS AND LAB REPORTS. Entire medical, billing, and diagnostic file, including but not limited to any a~,d .all. reco~d.s, correspondence to and from the consulting and/or treating physicians, roes, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests wire subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electror~ic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINE E. LACKEY 319 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 207-44-5025 Date of Birth: 07-23-1957 SU10-411828 13 7 73 --LO 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: CHRISTINE E. LACKEY COURT 0F COMMON PLEAS TERM, EDGAR L. DYSON -VS - CASE NO: 02-4856 CIVIL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of SHARON 0'DONNELL, 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 iden'tical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/12/2002 MCS on behalf of SHARON O'DONNELL, ESQ. Attorney for DEFENDANT DEll-381215 13 773 --LO 6 COMMONWEALTH OF PEiNNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: CHRISTINE E. LACKEY -VS- EDGAR L. DYSON COURT 0F COMMON PLEAS TERM, CASE NO: 02-485G CIVIL NOTIC]g OF ~ TO SR]a_VE A SUBPOENA TO PRODUCE ~S AND '£m~t~S FOR DTSC~I(Y PUI~UP~'i' ~9 R~.R 4009.21 [ Note: see enclosed list of locations ] TO: PETER B. FOSTER, ESQUIRE ECS on behalf of SNARON O'DONNELL, 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 ECS office. ' DATE: 11/22/2002 CC: S~%RON 0'D01FI~LL, ESQ. PAMELA S. JUN~-#ELLS - 13241-00200 Any questions regarding this matter, contact ECS on behalf of S~iRON 0'DONNELL, ESQ. Attorney for DEFENDAI~ THE NCS GROUP INC. 1601 NARKRT STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-208129 13 773--CO2 LOCATION LIST <¢< PAGE: 1 LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL COMMUNITY FAMILY MEDICAL CTR SUSQUEHANNA VALLI~Y SURGERY CTR HEALTHSOUTH REHAB. CENTER COMMUNITY GENERAL OSTEOPATHIC COMMUNITY GENERAL OSTEOPATHIC NEST SHORE EMERGENCY MEDICAL JAMIE L.HETTICKoMD MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-208129 13 773--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRISTINE E. LACKEY VS EDGAR L.DYSON File No. 02-4856 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGE FOR DISCOVERY PURSUANT TO RULE 4009.~9 TO: CUSTODIAN OF RECORDS FOR: COMMUNITY GENERAL OSTEOPATHIC HOPSITAL (Name of Pemon or Entity) Within twenty (20) days after service of this subpge_n_a, ~o_u_ .ar_e.9_rd_ered by the cout~ to produce the following documents or things: . 5~1~ ~'i"I'A(..;H 1',~ I ) at MCS GROUP INC., 1601 I~q~ET ST., #800, PHILA.,PA 19103 You may deliver or mail legible copies of the document~ or produce thin~ requested by this subpoen~ to~ether with the certificate of compliance, to the pm~y m~kin$ this request at the address listed above. You h~ve the right to ~eek, in advance, the reasonable co~t of prep~rin$ the copies or produ¢in$ the thin~ ~ought. If you fail to produce the document~ or thin~ required by this subpoena within twenty (20) days after it~ ~erviee, the party serving this subpoerm may ~eek a court order compellin$ you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: SHARON M. O' DONNELL, ESQ. ADDRESS: 4200 CRUMS MILL RD., STE.B HARRISBURG, PA 17112 : TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT 12/12/2002 DATE: ~.J~- /~'. ~:~ O 0,~ Seal of the Con.--t (Elf. ?/e7) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMUNITY GENERAL OSTEOPATHIC 4300 LONDONDERY P.O. BOX 3000 HARRISBURG, PA 17105 RE: 13773 CHRISTINE E. LACKEY INCLUDING ANY AND ALL LAB REPORTS, MRI'S, CT SCANS, EEG'S OR OTHER DIAGNOSTIC MATERIALS. Any and all x-ray f'flms and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form pertaining to: ~ua.tes Re. quested: up to and including the present. bject. CHRISTINE E. LACKEY 319 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 207.~.~. 5025 Date of Birth: 07-23-1957 SU10-411830 13 7 73 --LO 6 CERTIFICATE PRRR~0UISITE TO SERVICE OF A SUBPOENA PURSUANT TO RUL~ 4009.22 IN THE MATTER OF: CHRISTINE E. LACKEY COURT OF COMMON PLEAS TERM, EDGAR L. DYSON -VS- CASE NO: 02-4856 CIVIL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of SHARON 0'DONNELL, 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. DA?E: 12/12/2002 MCS on behalf of SHARON 0'DONNELL, ESQ. Attorney for DEFENDANT DEll-381216 13 7 73 --LO 7 COMMONWEALTH OF PEiNNSYLVANiA COUNTY OF CUMBERLAND IN THE MATTER OF: CHRISTINE E. LACKEY -VS- EDGAR L. DYSON COURT OF COMMON PLEAS TERM, CASE NO: 02-4856 CIVIL NOTIC~ OF INTENT TO SERVI~ A SUBPOI~NA TO PRODUC~ DOCUMENTS AND TH~ FOR DIS~y PURSIIANT TO RULE 4009.21 [ Note.: see enclosed list of locations ] TO: PETER B. FOSTER, ESQUIRE MCS on behalf of S~%RON 0'DOl~mnS, 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 NOS office. DATE: 11/22/2002 CC: SHARON 0'DONNELL, ESQ. PAMELA S. JUNE-WELLS - 132~1-00200 Any questions regarding this matter, contact MCS on behalf of SHARON O'DONN~LL, ESQ. Attorney for DEF~NDAIFI' THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-208129 13 773--C02. LOCATION LIST <<¢ PAGE: LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL COMMUNITY PA~ILY MEDICAL CTR SUSQUEHANNA VALLEY SURGERY CTR HEALTHSOUTH REHAB. CENTER COM~3NITY GENERAL OSTEOPATHIC CO~UNITY GENERAL OSTEOPATHIC NEST SHORE EMERGENCY NEDICAL JAMIE L.HETTICK,MD MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S} MEDICAL, BILLING, AND X-RAY(S) X-RAy ONLY MEDICAL RECORDS & HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-208129 i 3 7 7 3 --CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRISTINE E. LACKEY VS EDGAR L.DYSON File No. 02-48~6 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS .FOR DISCOVERY PURSUANT TO RULE 4009.99 TO: CUSTODIAN OF RECORDS FOR: COMMUNIYT GENERAL OSTEOPATHIC HOSPITAL (Name of Per~on or Entity} Within twenty (20) days after service of this subpoena, l,o_u__ar_e _o_rd_ered by the corn{ to produce the following documents or things: . SEE ATTACHED at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA ].9103 (Add~} You may deliver or mail legible copies of the documents or produce thin~s requested by this subpoena, together with the certificate of compliance, to the par~ making this request at the address listed above. You have the right to sesk. in advance, the reasonable cost of preparin~ the copies or producing the thin~s If you fail to produce the documents or thin~s required by this subpoena, within twenty (20) days afte~ its service, the party serving this subpoena may seek a court order compellin$ you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: SHARON M, Q'DONNELL~ ESQ. ADDRESS: 4200 CRUMS MILL RD., STE.B HARRISBURG, PA 17112 :. TELEPHONE: 215-246-0900 SUPREME COURT ID #: A'I'rORNEY FOR: DEFENDANT 12/12/2002 DATE: 7~'/'' / q. O~ ~,~ Seal of the Court (c=~. ?/~/) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: COMMUNITY GENERAL OSTEOPATHIC 4300 LONDONDERY P.O. BOX 3000 HARRISBURG, PA 17105 RE: 13773 CHRISTINE E. LACKEY Entire hospital medical billing ~e including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, fries, memoranda, handwritten notes, history and physical rel:n~rts, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, tests, and/or medication, lab and diagnostic test results, including a~.y and all such items as may be stored in a computer database or otherwme m elecmmic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINE E. LACKEY 319 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 207-44-5025 Date of BLrth: 07-23-1957 SU10-411832 13 7 73 --LO 7 CERTIFICATE PREREOUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: CHRISTINE E. LACKEY COURT OF COMMON PLEAS TERM, EDGAR L. DYSON -VS - CASE N0: 02-4856 CIVIL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of SHARON 0'DONNELL, 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: 12/12/2002 MCS on behalf of SHARON 0'DONNELL, ESQ. Attorney for DEFENDANT DEll-381217 13 773 --LO 8 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: CHRISTINE E. LACKEY -VS- EDGAR L. DYSON COURT OF COMMON PLEAS TERM, CASE N0: 02-4856 CIVIL NOTIC~ OF ~ TO SBRV~ A SUBPO__~I~ TO PRODU~ DOCUMENTS A~m FOR DISCx)9=,KY ~uK~tmuwr TO RU~.~ 4009.21 [ Note: see enclosed list of locations ] TO: PETER B. POSTER, ESQUIRE MCS on behalf of SHARON O'DONNELL, 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 ~CS or by contacting our local MCS office. DATE: 11/22/2002 CC: SHARON O'DONNELL, ESQ. PAMELA S. J--UNE-kq~LLS - 13241-00200 Any questions regarding this matter, contact MCS on behalf of SHARON O'DONNELL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 ~KET STREET ~800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-208129 13 773 --C02 LOCATION LIST ,<.: PAGE: 1 LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL COMMUNITY FAMILY MEDICAL CTR SUSQUEHANNA VALLEY SURGERY CTR HEALTHSOUTH REHAB. CENTER COMMUNITY GENEl~ OSTEOPATHIC COMMUNITY GENERAL OSTEOPATHIC WEST SHORE EMERGENCY MEDICAL JAMIE L.HETTICK,MD MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILI, ING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, ~ X-RAY(S) X-RAY ONLY MEDICAL RECORDS & HOSPITAL BILL MEDICAL, BILLING, ~ X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-208129 13 7 7 3 --CO 2 COMMONWEALTH OF PENNSYLVANL· COUNTY OF CUMBERLAND CHRISTINE E. LACKEY VS EDGAR L. DYSON File No. 02-4856 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGg FOR DISCOVERY PURSUANT TO RULE 4009,79 TO: CUSTODIAN OF RECORDS FOR: WEST SHORE EMERGENCY MEDICAL SERVICES (Name of Person or Entity) Within twenty (20) days after service of this subp~oe_n_a, ~o_u_ .ar_e_9_rd_ered by the courf to produce the following documents or things: Sli~J A'I'TAUHED at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19103 (Address) You may deliver or n~il legible copies of the d(x'uments or produce thin~s requested by this subpoen~ to~ether with the certificate of compliance, to the party making this request at the address ii,ted above. You have the right to seek, in advance, the reasonable co~t of preparing the copies or producing the thing~s sought. If you fail to produce the documents or thinp required by this subpoena, within twenty (20) days after its ~ervice, the party serving this subpoena may seek a court order comlMlling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAMF~ SHARON M. O' DONNELL, ESQ. ADDRESS: 4200 CRUMS MILL RD., STE.B HARRISBURG, PA 17112 TELEPHONF~ 215-246-0900 SUPREME COURT ID #: A~'rORNEY FOR: DEFENDANT DATE: 12/12/2002 Seal of the Court (Eff. EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: WEST SHORE EMERGENCy MEDICAL 503 NORTH 21 ST ST. CAMP HILL, PA 17011 RE: 13773 CHRISTINE E. LACKEY INCLUDING ANY AND ALL LAB REPORTS, MRI'S, CT SCANS, EEG'S OR OTHER DIAGNOSTIC MATERIALS AND LAB REPORTS. 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: CHRISTINE E. LACKEY 319 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 207-44-5025 Date of Birth: 07-23-1957 SU10-411834 13 7 73 --LO 8 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOBNA PURSUANT TO RULE 4009,.22 IN THE MATTER OF: CHRISTINE E. LACKEY COURT OF COMMON PLEAS TERM, EDGAR L. DYSON -VS- CASE NO: 02-4856 CIVIL AS a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of SHARON 0'DONNELL, 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: 12/12/2002 MCS on behalf of SHARON 0'DONNELL, ESQ. Attorney for DEFENDANT DEll-381218 1 3 7 73 --LO 9 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER 0F: CHRISTINE Eo LACKEY -VS- EDGAR L. DYSON COURT OF COMMON PLEAS TERM, CASE N0:02-4856 CIVIL NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND '"~ FOR DISCO~KY PU~u~uANT TO RII~.~ 4009.21 [ Note: see enclosed list of locations ] TO: PETER B. FOSTER, ESQUIRE MCS on behalf of SHARON 0'DONNELL, 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: 11/22/2002 CC: SHARON 0'DONNELL, ESQ. PAMELA S. JUNE-WELLS - 13241-00200 Any questions regarding this matter, contact MCS on behalf of SHARON 0'DONNELL, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-208129 13 773--CO2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED HOLY SPIRIT HOSPITAL HOLY SPIRIT HOSPITAL COMMUNITY FAMILY MEDICAL CTR SUSQUEHANNA VALLEY SURGERY CTR HEALTHSOUTH REHAB. CENTER COMMUNITY GENERAL OSTEOPATHIC COMMUNITY GENERAL OSTEOPATHIC WEST SHORE EMERGENCY MEDICAL JAMIE L.HETTICK,MD MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) X-RAY ONLY NEDICAL RECORDS & HOSPITAL BILL MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-208129 13 773--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRISTINE E. LACKEY VS EDGAR L.DYSON File No. 02-4856 CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.~ TO: CUSTODIAN OF RECORDS FOR: JAMIE HETTICK, M.D. (Name of Per,on or Entity) Within twenty (20) days after service of this subp_oe__n_a, ~fo_u_ .ar_e.prd_,ered by the ¢our~to produce the following do(uments or things: ~lS~; A'I'TAU tiPiO at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA i[9103 (Addre#) You may deliver or mail legible copies of the documents or produce thinl~s requested by this subpoena, to~ether with the certificate of compliance, to the party makins this request at the address listed above. You have the right to seek. in advance, the reasonable cost of preparirt~ the copies or producin$ the thinss sousht. If you fail to produce the documents or' thinl~s required by this subpoena, within twenty (20) days after its service, the party servin$ this subpoena may seek a court order compellinf you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: SHARON M. Q'DONNELL, ESQ. ADDRESS: 4200 CRUMS MILL RD., STE.B HARRISBURG, PA 17112 TELEPHON~ 215-246-0900 SUPREME COURTID #: A'I'rORNEYFOR: DEFENDANT 12/12/2002 Seal of the Court EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JAMIE L.HETTICK,MD 319 LONDONDERRY RD. HARRISBURG, PA 17109 RE: 13773 CHRISTINE E. LACKEY 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, fries, 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 electromc form, relating to any examination, consultation, diagnosis, care.or treatment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINE E. LACKEY 319 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 207-44-5025 Date of Birth: 07-23-1957 SU10-411836 13 7 73 --LO 9 CHRISTINE E. LACKEY, Plaintiff Vo EDGAR L. DYSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW · NO. 02-4856 Civil · JURY TRIAL DEMANDED STIPULATION The parties, by and through their counsel, as indicated below, hereby Stipulate and Agree that Paragraph 6 (1) from Plaintiffs Complaint shall be deleted and that no answer to that paragraph shall be required. ~4-'I~N M; O'DONN~LL, ESQUIRE I.D. 1~O. 79457 420g Crums Mill Road, Suite B Harrisburg, PA 17112 (71.7) 651-3503 Attorneyfor[DCndant DATE: L. RE'II'KLEX, ESQUIRE 121 South Stry~ Harrisburg, ,P'A 17101 (717) 234-0577 Attorney for Plaintiff DATE: /r~.,~~//~ \05_A\LIAB\SMO\LLPG\I 1232 I\CYWX13241\00200 CHRISTINE E. LACKEY, Plaintiff Vo EDGAR L. DYSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-4856 Civil : : JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Christine E. Lackey, Plaintiff c/o L. Rex Bickley, Esquire 121 South Street Harrisburg, PA 17101 You are hereby notified to plead to the enclosed Answer with New Matter within twenty (20) days from service hereof or a default judgment may be filed against you. DATE: \05_A\LIA B\SMO\LLPG\ 112312\C YW~ l 3241 \00200 MARSHALL, DENNEHEY, WARNER, /~~~/AN & GOGGIN ~HARON m. O DONNELL, ESQUIRE /I.D. No. 79457 / 4200 Crams Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3503 Attorney for Defendant, Edgar Dyson CHRISTINE E. LACKEY, Plaintiff EDGAR L. DYSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW NO. 02-4856 Civil : JURY TRIAL DEMANDED ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT The Defendant, Edgar L. Dyson, by and through his counsel, Marshall, Dennehey, Wamer, Coleman & Goggin, hereby makes answer to Plaintiff's Complaint and in support thereof states the following. 1. Admitted upon information and belief. 2. Admitted. 3. Admitted upon information and belief. 4. Denied. The allegations and averments on Paragraph 4 of Plaintiff's Complaint are denied pursuant to the provisions of Pa. R.C.P. 1029 (e). 5. Denied. The allegations and averments on Paragraph 5 of Plaintiff's Complaint are denied pursuant to the provisions of Pa. R.C.P. 1029 (e). 6.(a-k) Denied. After reasonable investigation, the answering Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of paragraph 6, subparagraphs (a)-(k) of Plaintiffs Complaint. By way of further answer, the same are denied pursuant to the provisions of Pa. R.C.P. 1029(e). 7. Denied. The allegations and averments of paragraph 7 of Plaintift~s Complaint are denied pursuant to the provisions of Pa. R.C.P. 1029(e). 8. Denied. The allegations and averments of paragraph 8 of Plaintiff's Complaint are denied pursuant to the provisions of Pa. R.C.P. 1029(e). 9. Denied. The allegations and averments of paragraph 9 of Plaintiffs Complaint are denied pursuant to the provisions of Pa. R.C.P. 1029(e). 10.-12 Denied. The allegations and averments of paragraph 10-12 of Plaintiffs Complaint are denied pursuant to the provisions of Pa. R.C.P. 1029(e). WHEREFORE, the Answering Defendant demands judgment in his favor and against the Plaintiff together with such other relief as the Court may deem appropriate. NEW MATTER 13. Plaintiff's claims are barred by the applicable statute of limitations. 14. Plaintiff has failed to state a cause of action upon which relief can be granted. 15. Plaintiff is barred and/or limited by all applicable provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law. 16. No act or omission on the part of Defendant was a substantial or contributing factor in bringing about Plaintiff' s alleged injuries and/or damages, all such injuries and/or damages being expressly denied. 17. Any and all injuries and/or damages as described by Plaintiff in her Complaint, the same being expressly denied, were caused in whole or in part by the acts or omissions on the part of Plaintiff and/or others over whom Defendant had no control nor right of control. 18. Plaintiff's claims are barred and/or limited by the doctrine of res judicata and/or collateral estoppel. 19. Defendant breached no duty of care owed to Plaintiff under the circumstances. 20. Plaintiff's claims are barred and/or limited by the Pennsylvania Comparative Negligence Act. 21. Plaintiff's claims are barred and/or limited by the applicable provisions of the Pennsylvania Worker's Compensation Act. At all times material hereto, Defendant acted in a safe, legal and non-negligent 22. Plaintiff's negligent operation of her motor vehicle was the sole and proximate cause of all alleged injuries and damages. 24. Plaintiff's Complaint and or claims are barred by her selection of limited tort as set forth by 75 Pa.C.S.A. §1705. 25. Plaintiff's claims are barred by the doctrine of comparative negligence in that Christine E. Lackey operated her vehicle in a negligent manner and inappropriately maneuvered her vehicle into an unsafe section of the subject roadway where the accident occurred. DATE: \LIAB\SMO\LLPG\I 12313\CYWX13241 \00200 MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN ~]~ARON M. O'DONNELL, ESQUIRE I.~D. No. 79457 ~/200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3503 Attorney for Defendant, Edgar VERIFICATION The undersigned hereby verifies that the statements in the foregoing Answer with New Matter are based upon information which has been furnished to counsel by me and information which has been gathered by counsel in the preparation of the defense of this lawsuit. The language of the Answer with New Matter is that of counsel and not my own. I have read the Answer with New Matter, and to the extent that it is based upon information which I have given to counsel, it is tree and correct to the best of my knowledge, information and belief. To the extent that the contents of the Answer with New Matter are that of counsel, I have relied upon my counsel in making this verification. The undersigned also understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. DATE: \05_A\LIA B\S MO\LLPG\ 112316\CYW~13241\00200 CHRISTINE E. LACKEY, Plaintiff Vo EDGAR L. DYSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CWIL ACTION - LAW : : NO. 02-4856 Civil : : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, Cherri M. Whitson, an employee of Marshall, Dennehey, Warner, Coleman & Goggin, do hereby certify that on this ]r}'~day of January 2003, served a copy of the foregoing document via First Class United States Mail, postage prepaid as follows: L. Rex Bickley, Esquire 121 South Street Harrisburg, PA 17101 CCh~e~. ~.~Wh'itso~n~ \05_A\LIAB~SMO\L LPG\ 112315\CYW~13241 \00200 CHRISTINE E. LACKEY, Plaintiff EDGAR L. DYSON, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 02-4856 JURY TRIAL DEMANDED ANSWER TO NEW MATTER 13. Denied. The allegations contained in this Paragraph constitute conclusions of law and therefore no further responsive pleading is required. By way ,of further answer and to the extent that a responsive pleading is deemed required, denied pursuant to Pa.R.C.P. 1029(e). 14. Denied· The allegations contained in this Paragraph constitute conclusions of law and therefore no further responsive pleading is required. By way of further answer and to the extent that a responsive pleading is deemed required, denied pursuant to Pa.R.C.P. 1029(e). 15. Denied· The allegations contained in this Paragraph constitute conclusions of law and therefore no further responsive pleading is required. By way of further answer and to the extent that a responsive pleading is deemed required, denied pursuant to Pa.R.C.P. 1029(e). 16. Denied. The allegations contained in this Paragraph constitute conclusions of law and therefore no further responsive pleading is required' By way of further answer and to the extent that a responsive pleading is deemed required, denied pursuant to Pa.R.C.P. 1029(e). 17. Denied· The allegations contained in this Para[~aph constitute conclusions of law and therefore no further responsive pleading is required. By way of further answer and to the extent that a responsive pleading is deemed required, denied pursuant to Pa.R.C.P. 1029(e). 25. Denied. The allegations contained in this Paragraph constitute conclusions of law and therefore no further responsive pleading is required. By way of further answer and to the extent that a responsive pleading is deemed required, denied pursuant to Pa.R.C.P. 1029(e). Respectfully submitted, Date: L. Rex Bi~kley 121 South St. Harrisburg, PA 17101 (717) 234-0577 (717) 234-7832 Attorney for Plaintiff VERIFICATION I, Christine E. Lackey, verify that the statements made in the foregoing Answers to New Matter are true and correct to the best of my information, knowledge and belief. I understand that false statements made herein are made subj eot to Pa. C. S.A. §4904 relating to unsworn falsification to authorities. Date: Christine E. Lackey CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER 0F: CHRISTINE E. LACKEY COURT OF COMMON PLEAS ~ERM, EDGAR L. DYSON -VS- CASE N0: 02-485~ CIVIL AS a prerequisite to service of a subpoena for documents and things Pursuant to Rule 4009.22 MCS on behalf of SHARON 0'DONNELL 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: 04/17/2003 Attorney for DEFENDANT DEll-407370 13 7 73 --L10 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: CHRISTINE E. LACKEY -VS- EDGAR L. DYSON COURT 0F COMMON PLEAS TERM, CASE N0: 02-4856 CIVIL NOTICIE OF INTENT TO SERV~ A SUBPO~qA TO PRODUCE DOCUMENTS AND · J.'li~ FOR DISC~IsKY wu~u~t~.efl' TO RUT.R 4009.21 REHAB NRDICAL ASSOCIATES NRDICAL RECORDS, BILLING AND DIAGNOSTIC FILES TO: PETER B. FOSTER, ESQUIRE ..-. NCS on behalf of SHARON 0'DONNELL ESQ. intends to serve a subpoena identical to-the one that is attached to this notice. You have teenty (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: 03/28/2003 CC: SHARON O'DONNELL ESQ. PAMELA S. JUNE-WELLS 13241-00200 Any questions regarding this matter, contact MCS on behalf of SHARON 0'DONNELL ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-220967 13 773--C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CHRISTINE E. LACKEY VS EDGAR L.DYSON File No. 02-4856- CIVIL SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009:2~ TO: CUSTODIAN OF RECORDS FOR~ REHAB MEDICINE ASSOCATIES (Name of Person or Entity) Within twenty (20) days a~ter service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATT~I-IF.r~ at MCS GROUP INC., 1601 MARKET ST., #800, PHILA.,PA 19IO3 (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: SHAI~N M. O'DONNELL~ ESQ. ADDRESS: 4200 CRUMS MILL RD.~ STE B HARRISBURG, PA 17112 TELEPHONE: 215-246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT DATE: Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: REHAB MEDICAL ASSOCIATES 5124 E. TRINDLE RD. MECHANICSBURG, PA 17055 RE: 13773 CHRISTINE E. LACKEY Entire medical, billing, and diagnostic ~e, including but not limited to any dy .all. recor...ds, correspondence to and from the consulting and/or treating s~c~ans, rues, memoranda, handwritten notes, history and physical repons, medication/prescription records, medical billing and payment records, dia~o, stic ~ms and tes~, including MRI films, CAT Scans, EEGs, EKGs, EMGs, aha su0sec[uen, t repons, mclu. ding any and all such items as may be stored in a computer oataoase or otherwise m electronic form, relating to any examination, consultation, diagnosis or trealment pertaining to: Dates Requested: up to and including the present. Subject: CHRISTINE E. LACKEY 319 WALTON STREET, LEMOYNE, PA 17043 Social Security #: 207-44-5025 Date of Birth: 07-23-1957 SU10-432830 13773 --LiO \05_A\LIABXJPM\LLPG\126426\RYM\ 13241 \00200 CHRISTINE E. LACKEY, Plaintiff EDGAR L. DYSON, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-4856 Civil : : JURY TRIAL DEMANDED WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw the appearance of the undersigned on behalf of Defendant, Edgar Dyson, in connection with the above-referenced case. MARSHALL, DENNEHEy, WARNER, A~ & GOGGIN · Q_~ARON 0 DONNELL, ESQUIRE I/D. No. 79457 ~200 Crums Mill Road, Suite B 'Harrisburg, PA 17112 (717) 651-3503 ENTRY OF APPEARANCE Kindly enter the appearance of the undersigned as counsel on behalf of the Defendant, Edgar Dyson, in the above-captioned case. BY: MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN 4200 Crums Mill Road, Suite B Harrisburg, PA 17112 (717) 651-3509 Attomey for Defendants 2 CHRISTINE E. LACKEY, Plaintiff EDGAR L. DYSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02-4856 Civil : : JURY TRIAL DEMANDED PRAECIPE FOR DISCONTINUANCE TO THE PROTHONOTARY: ~ Kindly mark the above-referenced matter settled, discontinued, and ended with prejudice. 121 South Street / Harrisburg, p~01