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Home My WebLink About00-03069 " .1, i" IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA No. ~ - 3C1oL CI~;L 'T~ Civil Action - (X) Law ( ) Equity Terry W. Tingle 508 East Marble STreet Mechanicsburg, PA 17055 Frederick Lloyd Lamason 807 North Arch Street Mechanicsburg, P A 17055 versus Plaintiff Defendant PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. Writ of Summons shall be issued and forwarded Jonathan M, Crist. Esq. Latsha Davis & Yohe. P.C, P.O, Box 825 Harrisburg. P A 17108-0825 (717) 761-1880 Names/Address/Telephone No, of Attorney Attorney (X) Sheriff Si e of Attorney upreme Court ID No. 29936 Date: tf~ ;; e;/ZO(J d ( WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. Date: fYl~y 17 ;;[QO{) , It (L,-h~ J ~~ P othonotary ~ a~oQ~~~ D puty ( ) Check here if reverse is issued for additional information 56817,1 ,.'". -' ~tBM*.~lI' ~""litiii~ , ~.iIIi' 1'~iSil' " " ,,"~'~"> - -j -~"~- & iq f>J ~ ~ 0 0 0 ~. C 0 " ~ B 8 6 s:: ::il: ::;i -om "'" -.-..,-, G'- ;-nrr~ -< .-jlf= z-:.r.:.). ~3~ ~ cS ( I Z'C f~ ci5",,-:: ....; 'J -<~, --I, . 'G' ~o -u :::r::B ~,-.. :::< Qo zl...J om ~ ={j ~ );., C:: ~ z 0 -. ::0 =< 0"\ -< ~,,= "' , . . - ' ~, " ' .;, ""i SHERIFF'S RETURN - REGULAR CASE NO: 2000-03069 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TINGLE TERRY W VS LAMASON FREDERICK LLOYD CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon LAMASON FREDERICK LLOYD the DEFENDANT , at 0020:00 HOURS, on the 22nd day of May , 2000 at 809 NORTH ARCH MECHANICSBURG, PA 17055 by handing to FREDERICK L. LAMASON a true and attested copy of WRIT OF SUMMONS together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.20 .00 10.00 .00 34.20 So Ans~ // ~ . rt."<:-r~t R. Thomas Kline Sworn and Subscribed to before OS/23/2000 LAT SRA , LAV'S & YOHE ':~~ By:. ~. i~" ~ ;;:j} ;he ff me this o? ~ day of 9"L-- ~avo A.D. ~08r~'~ ~ ., = '-'"'- , .-" ","'--<- " .. -. ".-,t--'-"-'~_"'" ,-.,",~; - -",:-" ' ' < '-"',O,+d"~,_'-'""_,, "-.h.n,' """"~'~~do:;>X",-;,,,_~,_ '':' ,_~ " !i.j " '" THOMAS, THOMAS & HAFER, LLP Jeffrey B. Rettig, Esquire Identification Number: 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 717/255-7639 Attorneys for Defendant Lloyd Frederick Lamason IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW TERRY W. TINGLE, Plaintiff v. NO. 2000-3069 FREDERICK LLOYD LAMASON, Defendant PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please Issue a Rule directing Plaintiff to file a Complaint against Defendant within twenty (20) days or non pros seq. reg. RULE TO FILE C AND NOW, ./UrlO c52{ ,2000, A RULE IS ISSUED AS ABOVE. :114467.1 - " ,-<,< ~~"""".__ :8-'..~-",;.",.-",,-i"-:-_'';:'_ ,,-,,, ''';-{_'','',,:,~~-'lk. ,";J-" ",",,,,,,-,,,,--", N,'ii>;~'"l,-;; _ ...," " ~" " CERTIFICATE OF SERVICE I, JEFFREY B. RETTIG, ESQUIRE, hereby certify that I have served a true and correct copies of the foregoing document on the following pe~ ~Cing same in the United States mail, postage prepaid, on the YO day of ., 2000. . Jonathan Crist, Esquire P,O. Box 825 Harrisburg, PA 17108-0825 THOMAS, THOMAS & HAFER, LLP iill~ 'I"~b' ~ .~>'~ '!III! .....~'~.' , ~-"'.J. c., I,,,", ~ ^' "~ ' ~ 'lliW ". -' .~- "" ,J~">~"~ " ,,'.' "-"_, ," ~-- -";-ll.dl ,~'"" ' 'we' () C ~ --::-~ ,j '.~ r;'lf'! ""/"--" 21._, S':~_c:, r.:::: c-, ~~z3 Pc z ::2 ",,~ 1J&l' C::i C -". :'_::-l I I ! ... \'.j- 1--\ :'::'f1 -r; ,,-) ,"I;:) j(~-) '.:- -,., ~~~;}~ '-~', :;::.: :0 -< --0 -:;.,. ~, ':-: ::::> 4="' l' ~~.-~" " THOMAS, THOMAS & HAFER, LLP Jeffrey B. Rettig, Esquire Identification Number: 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 717/255-7639 Attorneys for Defendant Lloyd Frederick lamason IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVil DIVISION - LAW TERRY W. TINGLE, Plaintiff v. NO, 2000-3069 FREDERICK lLOYD LAMASON, Defendant PRAECIPE TO THE PROTHONOTARY: Please enter the appearance of Jeffrey B. Rettig, Esquire of Thomas, Thomas & Hafer, llP on behalf of Lloyd Frederick lamason, erroneously referred to as Frederick Lloyd lamason, Defendant, in the above captioned matter. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP ~0,l ',s.' .;t..' 1 Po :114433,1 -- =<= ~~-.'-, .'j I I I .t I ~. . ~ ~ ^~ ~, ^"~ ,. -~~~-.< -"^'--,' ',,<' '", -di.',;,,:~-,"->""",,-"'~ ~.~, "'-"".c""!""",,,," "',^'~'C ';';"iiti CERTIFICATE OF SERVICE I, JEFFREY B. RETTIG, ESQUIRE, hereby certify that I have served a true and correct copies of the foregoing do~ument on the following persons by placing same in the United States mail, postage prepaid, on the 1'2,/0 day of 'fJ>J\'., , 2000, Jonathan Crist, Esquire P.O. Box 825 Harrisburg, PA 17108-0825 THOMAS, THOMAS & HAFER, LLP ,~ .'~_L'j'_'" '" ." - "= ~ - ~ ,~ --'-'1;' ,-., ,C'_':; ;,_c: =', ""'-"'1'-' "~~ ,-, , '. ,,",,' ""."'" '"11 T C) '_.' ~') C a "' ~~- ~}": , r11 i.~~: C;::-l :z: ?~ i'"'- r",) I; 0) , , ':"") -< t:; ~.;~ ~ ~, --! '-t-'" i .~. .-.-'> C -,-i Z --.-:.' (~ (....:-~ )> {--..- t\,,) " ,T; .-~:.- .:.---t ~- :::> <>- -, ,< j'-- :D -, , ~ ~ , , <'" 'r.' 'j,d , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERRY W. TINGLE, Plaintiff No. 2000-3069 v. CIVIL LLOYD FREDERICK LAMAS ON, Defendant 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 (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717) 249-3166 (800) 990-9108 62362,1 i";i ;~.' ,'" ,0." ^.~ , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERRY W. TINGLE, Plaintiff No. 2000-3069 v. CIVIL LLOYD FREDERICK LAMAS ON, Defendant JURY TRIAL DEMANDED COMPLAINT AND NOW, COMES, Plaintiff, Terry W, Tingle, by and through his attorneys, Latsha Davis & Yohe, P.e., and files the within Complaint against Defendant, Lloyd Frederick Lamason, and in support thereof, provides as follows: 1. Plaintiff, Terry W. Tingle, is an adult individual residing at 508 East Marble Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant Lloyd Frederick Lamason, ajkj a Frederick Lloyd Lamason is an adult individual residing at 809 North Arch Street, Mechanicsburg, Cumberland County, Pennsylvania 17055, 3, The facts and circumstances of the accident herein described took place on June 4, 1998, at or about 7:08 p.m. on Silver Spring Road at its intersection with Carlisle Pike (Route 11) in Cumberland County, Pennsylvania. 62362,1 " ,~: '<"'C ;:, II\Jt I ! - ,""- 1 -, ':"] "'! 4. At the aforesaid time and place Plaintiff had stopped in his automobile on Silver Spring Road for a red light at the traffic signal controlling the intersection of Silver Spring Road and Carlisle Pike. 5. At the aforesaid time and place Plaintiff then pulled his automobile forward, intending to make a right turn on red, and again brought his vehicle to a stop to ascertain that traffic was clear on Carlisle Pike when his vehicle was struck in the rear by a vehicle operated by the Defendant. 6. As a result of the collision as aforesaid, Plaintiff has suffered certain bodily injury, including but not limited to: (a) bilateral posterior neck pain; (b) bilateral shoulder pain; and (c) aggravation! extension of preexisting migraine headaches. 7. The aforesaid collision was due to the negligence of the Defendant in the following particulars: (a) failure to keep a careful and diligent watch upon the highway; (b) failure to have his vehicle under adequate and proper control; (c) failure to observe that Plaintiff had brought his vehicle to a stop in sufficient time to avoid a collision therewith; (d) inattentively operating his vehicle; 62362,1 2 , ,"" , I,. " -,i.'''. >Ol,;, , (e) operating his vehicle at such a speed or in such a manner that would not permit him to bring his vehicle to a stop within the assured clear distance ahead; and (f) driving his vehicle too closely to the vehicle being operated by the Plaintiff in violation of 75 Pa, C.S. S 3310. 8. Solely as a result of the negligence of the Defendant as aforesaid, Plaintiff has incurred expenses for medical care and treatment and may be forced to incur additional expenses for medical care and treatment for an indefinite time in the future. 9, As a result of the negligence of the Defendant as aforesaid, Plaintiff has suffered and will continue to suffer great pain, suffering, inconvenience, embarrassment, mental anguish, and loss of the enjoyment of life, 10. As a result of the negligence of the Defendant as aforesaid, Plaintiff may, in the future, suffer a loss of wages and earnings. 11. As a result of the negligence of the Defendant as aforesaid, Plaintiff may suffer a loss of earning power and capacity. [the remainder of this page left intentionally blank] 62362,1 3 , 1~'" ~~ .~ ,;' , )--,.- ~ WHEREFORE, Plaintiff, Terry W. Tingle demands judgment of the Defendant, Lloyd Frederick Lamason, in an amount in excess of Twenty-Five Thousand Dollars ($25,000), the amount requiring compulsory arbitration in Cumberland County, Pennsylvania. Date: 62362,1 {:Z/0 VItf1J I By: J na an M. Crist, Esq. A orney No. 29936 p.o, Box 825 Harrisburg, PA 17108-0825 (717) 761-1880 Attorneys for Plaintiff, Terry W, Tingle 4 . ' ~ '"<'-" "Iii ,- J, '~, '. 1-, 'Mili'L " IN THE COURT OF. COMMQN PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERRY W. TINGLE, PLAINTIFF v. NO. 2000-3069 CHlIL JURY TRIAL DEMANDED LLOYD FREDERICK LAMASON, DEFENDANT VERIFICATION The above COMPLAINT is based upon information which I have furnished to my counsel and information which has been gathered by my counsel in preparation of this matter. The language of the COMPLAINT is that of counsel and not of me. I have read the COMPLAINT and to the extent that the COMPLAINT is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the COMPLAINT is that of counsel, I have relied upon counsel in making this verification, I hereby acknowledge that the facts set forth in the aforesaid COMPLAINT are made subject to penalties of 18 Pa, c.s. 84904 relating to unsworn falsification to authorities, Date: /.2. /;- /00 I r ~ ~ /L- -d/. Ter~y~le 564721 ,-'-'- '-"~'''''W:'-'''' , ~""'''!i~t , , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERRY W. TINGLE, Plaintiff No. 2000-3069 v. CIVIL LLOYD FREDERICK LAMASON, Defendant JURY TRIAL DEMANDED CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the foregoing document was served by first-class United States mail, postage prepaid, upon the following: Jeffrey B. Rettig, Esq, Thomas, Thomas & Hafer, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 Dated: /(;YIIYX l}/A ~ ,J (){j) ~oJ (J. c?~ Deborah A Peterson Legal Secretary 62362,1 _1,,_'0"",0<, ". "~O" /~'!'" ' ~-",,_,>,-;, "-',' '",",,' ,-,', ",",';;' . THOMAS, THOMAS & HAFER, LLP Jeffrey B. Rettig, Esquire Identification Number: 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 717/255-7639 Attorneys for Defendant Lloyd Frederick Lamason IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW TERRY W TINGLE, Plaintiff v. NO. 2000-3069 FREDERICK LLOYD LAMASON, Defendant NOTICE TO PLEAD TO: Terry W Tingle, Plaintiff and Jonathan Crist, Esquire, his attorney You are hereby notified to plead to the enclosed New Matter within twenty (20) days from service hereof or a default judgment may be entered against you, Respectfully submitted, THOMAS, THOMAS & HAFER, LLP ";--." ,,-, "" "r""~-'-' .." -, -_^,'" -k~ ,_,~",_ ~c_<<,' - '-' ",~ffl'-' '-~ ,'.' -- , --'-',;;,-~,,:.t ' ~"" ,"0 "_,; ,.":<'~:: . THOMAS, THOMAS & HAFER, LLP Jeffrey B. Rettig, Esquire Identification Number: 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 717/255-7639 Attorneys for Defendant Lloyd Frederick lamason IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVil DIVISION - LAW TERRY W. TINGLE, Plaintiff v. NO. 2000-3069 FREDERICK LLOYD LAMASON, Defendant DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT WITH NEW MA ITER AND NOW, comes the Defendant, by his attorneys, Thomas, Thomas & Hafer, llP, and answers Plaintiff's Complaint as follows: 1, It is admitted that the Plaintiff is who he says he is, As to the balance of the allegations of this paragraph, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of these allegations and proof thereof is demanded, 2, Admitted except that the address is 809 North Arch Street. 3. Admitted. 4. Admitted, 5. Denied as stated. It is admitted that Plaintiff brought his vehicle forward and that his vehicle was strucK in the rear by the vehicle operated by the Defendant. As to the balance ,.. ,- - ~-- - , ~ -, I,,' , --,~"-~___,,, .-Co' '"",'; ,:' ^,''-''_;.:i;o '''''''''0'_"'''----' <,..,;, " , ,'{,->~-c,,'"'' -c, C~.li.l'~ of the allegations of this paragraph, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of these allegations and proof thereof is demanded. 6. Denied. After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of these allegations and proof thereof is demanded. 7. Denied pursuant to Pa, RC.P. 1029, 8-11. The allegations of negligence are denied pursuantto Pa. RC.P, 1029. As to the balance of the allegations of these paragraphs, after reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of these allegations and proof thereof is demanded. WHEREFORE, Defendant requests that Plaintiff's Complaint be dismissed without cost to him. NEW MATTER 12. Plaintiff's claims are subject to the provisions of the Pennsylvania Financial Responsibility Act, the limitations of which are incorporated herein by reference thereto, 13. Plaintiff's claims for non-economic detriment are or may be barred by the limited tort option. 14. Plaintiff has or may have failed to mitigate his damages. WHEREFORE, Defendant requests that Plaintiff's Complaint be dismissed without cost to him. Respectfully submitted, THOMAS, THOMAS & HAFER, LLP :116917,1 , " T~ - __" f ,,' , ",' _."'~ "^-.'. -- '---~" ,,~,'~, -'"'''~" .;r.._',"'__ ,',d,; ,." ',"", ___ '"iIll I I VERIFICA liON I hereby verify that the averments made in the foregoing Answer to Plaintiff's Complaint with New Matter are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unswom falsification to authorities. Dated: ~" &" , . " ._ ' , _'J,' __"-_"""~;",,,~~.~, ",,<,o"ffd"'>-' ': ',,-,,<- . <",__",..,"' -, ~'~"",,,,c',-, ,,, .. ,-,. '","'-'-"c -c; i,'-. ; " < '"" ,_,_-_-_.-',"___,_' .-~.-; ;j . . . CERTIFICATE OF SERVICE I, JEFFREY B. RETTIG, ESQUIRE, hereby certify that I have served a true and correct copies of the foregoing docum~on the following pe~laCing same in the United States mail, postage prepaid, on the day of , 2000. Jonathan Crist, Esquire P,O. Box 825 Harrisburg, PA 17108-0825 THOMAS, THOMAS & HAFER, LLP ...;,;..1 ~ - .......- '.' ~ '" .^,~"- ,'~, " - () C~) :) ....- '~t , , ~:;; :"":: C."J \.:; ~~~; '1 --" ni :;:: " .' , :2. ,..., r'-,,) -,-1 r-;', -~':~ , C' ) (l) C , -< C~i :: C.'::.~ ~ -~ .-;'OJ ~~ '," c> C~ :1;: " ('j 2 :PC () , , l_.J rn c: ,_u ,..j :z >' :<! :u (J1 -< ..'" .l!'"L' ,.;;, ,~ "" l,,~ - ,I',' L'~"...,,,, -~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY .. TINGLE Vs. LAMASON NO. 2000 3069 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 AS a p~erequisite to service of a subpoena{s) for documents and things pursuant to Rule 4009.22 JEFFREY B RETTIG, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena{s) with a copy of the subpoena{s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena{s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena{s) is attached to this certificate, 3. No objection to the subpoena{s) has been received, and 4. The subpoena{s) which will be served is identical to the subpoena{s) which is attached to the Notice of Intent to Serve the Subpoena{s). te: 1/26/01 File #: M270717 JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LANDIS 305 N FRONT ST 6TH F HARRISBURG, PA 17108 717-255-7237 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3590 By: Christine Janiszewski ~~ ~ ..... .~ - ~ . " > 'it IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~ TINGLE Vs. LAMASON No. 2000 3069 TO: JONATHAN CRIST, ESQ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND TIDNGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) 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 no objection is made the subpoena may be served. Date: 1/4/01 JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LANDIS 305 N FRONT ST 6TH F HARRISBURG, PA 17108 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 By: Christine Janiszewski Enc(s): Copy of subpoena(s) Counsel return card File #: 1(270717 " <nHJIiIWElU,TH OF PENEYLVANIA o:xJNfY OF <:lJMllElU,NID 0\ TINGLE Vs. Fi Ie No. 2000 3069 LAMASON SUBpOENA TO PROOUCE DOCl.J'ENTS OR lli I NC3S . FOR 0 I SCOVERY ~SUANT TO RULE 4009.22 DR BARRY MOORE, 920 CENTURY DR, MECHANICSBURG FA 17055 TO: {Nane of Person 01" Entity} Within twenty (20) days after service of this subpoena, you are OI"dered by the court to produce the following docunentSEE ~rr~CBED ADDENDUM at ~DXCAL LEGAL REPRODUCTXONS, XfR~~J)O DXSSTON ;- ; , I.' 5".1:'. , ...EULA., li'A You may deHver 01" mail legible copies of the doct.rnents or produce things requested h) this subpoena, together with the certificate of carp Hance, to the party making thi~ request at the address 1 isted above. You have the right to seek in advance the rea<;onab IE cost of preparing the copies or producing the things sought. 'f you fai I to produce the docunents 01" things required by this subpoena within t",enty (20) days after its serv~,ce, the Party ,serving ,thi:; ~'Ubpoena may seek a court ord..-' c.:arpelling you to carply with it. ..' ',,,, , , lli'S SUBpOENA WAS NAME: ADDRESS: ISSUED AT lliE REQUEST OF THE FOLLCWING PERSON: .JF.FFREY B RETTIG, ESQ -, e~eT. ~,71j.IDIS b."f u, . ~,~ "" HARRISBURG, j,'A .L 7108' Tl;LEP.MC:il'lE: SUPREl"E <XlURT 10 ,# ATTORNEY FOR: 2:15-335-3212 1 Clh1 6 DEFENDANT y M2707:17-01 ; 1>1,), J~"', . . 'P/~ ~~~Jjl - " ; thE! CoUrt' " . DATE:' 'seal ," ," " ,.', .i ,~ 1 ~ \ " .' ",,' ' . ',\1 ," 1 ',," I;".; ; ", . ",.. '.\ : '~ 11 : , ..;1, (Eff. 7/97) "~ ~~~ ,,~^ ..~ ' '- ~, ,- . ~ -- ~- ,- <--~, ADDENDUM TO SUBPOENA TINGLE VS. No. 2000 3069 LAMASON CUSTODIAN OF RECORDS FOR: DR BARRY MOORE ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: TERRY TINGLE ADDRESS: 508 E MARBLE ST MECHANICSBURG PA DATE OF BIRTH: 08/22/46 CERT11<lED PHOTOCOPIES OF THE RECORDS WILL BE ACCEPI'ED IN LIEU OF YOUR PERSONAL APPEARANCE. County of: CUMBERLAND MLR File #: M270717-01 ~OF~ CXJUmY OF aJMBEmAND 'TINGLE , VS. Fi Ie No. 2000 3069 LAMASON , SUBPOENA TO PROOUCE DOa.tENTS OR 11-11 NGS FOR D I SOOVERY PURSUANT TO RULE 4009. 22 DR MICHAEL FUHRMAN, 908 S GEORGE ST, YORK PA 17403 TO, (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the fo I lowing docunentSEE tt;\'flt~CHED ADDENDUM: ,',' at TTONS T~~,4es9s~O DI:SSTON ST., HEDI:CAL LEGAL REPRODUC.. '''(AtJuc;) .t"A.LLA. I :fA You may deliver or mail legible copies of the docunents or produce things requested b\ this subpoena, together with the certificate of' c:arj:,liance. to the party making thi2 request at the address I isted above. You have the right to seek in advance the reasonab IE cost of pre9a17ing the copies or producing the things sought. 11-11 S SUBPOENA WAS I SSUEO AT THE REQUEST OF THE FOLLGW I ~lG PERSON, NAI'E: ,TF.FFREY B RETTIG, ESQ ADDRESS: A'Il'H. CAROL I>>WIS HARRISBURG, t'A .1.7108 TELEPHONE: 5U>REI'E COURT I D# ATTORNEY FOR: 215-335-3212 19616 DEFENDANT BY THE CXlURT: M270717-02 DATE: ""'" 0)- db1l1_ 'Seal of Ule"'COUrt .' '..': "~I', . ',' , , , , ,', (Eff. 1/97) ,-.. '", ~ ",,"': ADDENDUM TO SUBPOENA . ' TINGLE VS. No. 2000 3069 LAMASON CUSTODIAN OF RECORDS FOR: DR MICHAEL FUHRMAN ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANl)A, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: TERRY TINGLE ADDRESS: 508 E MARBLE ST MECHANICSBURG PA DATE OF BIRTH: 08/22/46 CER'lUIED PHOTOCOPffiS OF THE RECORDS WILL BE ACCEPTED IN LffiU OF YOUR PERSONAL APPEARANCE. County of: CUMBERLAND MLR File #: M270717-02 _~~i@:~~n:~~_W;;jim!oj!!ffi"--"'I"..!l<l",,~ii1"l;,~_' ,.. . ,.' " f: '" -0'" ,..."Q7 !..'...In.;" ~~' ' 2~X.' 05.r;;. ;:;$~':",' . C' 1~? ;z :< ." ~) l'0 --.1 '~- , . <::> ~ 1''1 en ~? , '--.J );''1 :(.-:; ,,-:1,-'-; <c :"~-i c~/~ .);! :J) '"'" .~ '" ^' ...~ ,'--:'~ - """ ' ~ 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY TINGLE Vs. LAMAS ON NO. 2000 3069 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 JEFFREY B RETTIG, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s)is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s) . Date: JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LANDIS 305 N FRONT ST 6TH F HARRISBURG, PA 17108 717-255-7237 ATTORNEY FOR DEFENDANT //~ ,/'- " INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) 335-3590 File #: M270047 By: Christine Janiszewski \ ~~ ~-~~ ~~ " ~. , j" ' ,.". ",,' -, -'U:iii;; " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY TINGLE Vs. LAMASON No. 2000 3069 TO: JONATHAN CRIST, ESQ NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) 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 no objection is made the subpoena may be served. Date: 2/9/01 JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LANDIS 305 N FRONT ST 6TH F HARRISBURG, PA 17108 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 By: Christine Janiszewski Enc(s): Copy of subpoena(s) Counsel return card File #: M270047 -, , , J , ~TH OF PENlSYLVANIA COONl'Y OF aJMBERIAND TINGLE VS. File No. 2000 3069 LAMAsON SUBPCENA TO PR<XllX:E [)()CUo1ENTS OR lH I NGS FOR 0 I SCOVERY PURSUANT TO RULE 4009.22 ERIE INS, PO BOX 2013, MECHANICSBURG PA 17055 (NcrnElo( j>e;:s;x;-.;r Entity) TO: Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the fo I lowing docunentSiE ~':M'AClIED ADDENDUM: I I I , I You may deliver or mail legible copies of the documents or produce things requested h\ I this subpoena, together with the certificate of carpliance, to the party making thi, request at the address listed above. You have the right to seek in advance the rea~onablE cost of preparing the copies or producing the things sought. at ---;-EDICAL LEGAL REPRODUCTIONS, INC,' 'l~'lO u!SSYON ST., PIIILA., PA (Address) I f you fai I to produce the docunents or things required by this subpoena within twent, (20) days after its service, the party serving thi:; subpoena may seek a court orde' carpel 1 ing you to carply with it. lH I S SUBPOENA WAS NA1'E : ADDRESS : TELEPI-Pr!E: SUPREI-E OOURT 10# ATTORNEY FOR: ISSUED AT THE REQUEST OF THE FOLlOHING PERSON: JEFFREY B RETTIG, ESQ 1\T'l'N' [')\ROL LANDIS BAR~IgBURG, ~~ 17108 215-335-3212 19616 DEFENDANT DATE: 316\0\ seal of the Court BY TtiE <XlURT: I~/ ;;6:I~' /,~ Prothonotary/Cl ,Civi I Division ~jkn?t: )<~. 9iuty M270047-01 (Eff. 1/97) - " -~, ' ; ,"it, .. '" ADDENDUM TO SUBPOENA TINGLE VS. No. 2000 3069 LAMASON CUSTODIAN OF RECORDS FOR: ERIE INS ANY AND ALL RECORDS, MEDICAL AND OR ACCIDENT CORRESPONDENCE, NOTES, RECEIPTS, BILLS, ETC., AND ANY OTHER INFORMATION PERTAINING TO: N~iE: TERRY TINGLE ADDRESS: 508 E MARBLE ST MECHANICSBURG PA ENTIRE CLAIM FILE FOR POLICY #Q06 1702399 H FOR D/A OF 6/4/98. CERTIFIED PHOTOCOPIES OF THE RECORDS WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. County of: CUMBERLAND MLR File #: M270047-01 bi.li_ .-, ~A Wj'~Uiii~iiM~lii_-""'''''1il~.~~_",,~IJ<1:<1;j>ilii!;;1iJlR~~~'- ..."""" -~ . - " ,.W.' ~~ ' -, . '~J f' -~ a 0 b c .j :;:: :x :::1 ,~j '"0 CD ;po c'--n ~'gj ;;0 1~,lC ZS;; -(:?,rn "9 en " N --"./ ~"" C~(j ;<:C:; -0 ~f~~j ~o ::x ''7'fl 5>~ ~ L-," q " ~ :;;: .s:"" ~ . '.' . ,-.' , ,', ,~-" - ''-r-"J- .c.' '.i"-, -,-& ..0". ,"'." ".-; ...;,; -"""'"'1;~' I:.' ~ If L I' j; i THOMAS, THOMAS & HAFER, LLP ATTORNEYS AT LAW JOSEPH P. HAFER JAMES K. THOMAS, II ROBERTSON B. TAYLOR JEFFREY R RETTIG PETER J. CURRY R. BURKE McLEMORE, JR. EDWARD H. JORDAN, JR. C. KENT PRICE RANDALL G. GALE DAVID L. SCHWALM PETER J. SPEAKER DOUGLAS B. MARCELLO PAULJ.DELLASEGA 305 NORTH FRONT STREET SIXTH FLOOR P.O, BOX 999 HARRISBURG, PA 17108 (717) 237,7100 FAX (717)237,7105 WRITER'S DIRECT DIAL NUMBER SARAH W. AROSELL EUGENE N. McHUGH STEPHEN E. GEDULDlG KAREN S. COATES TODD B. NARVOL JAMES J. DODD-O KEVIN C. McNAMARA BROOKS R. FOLAND JOHN FLOUNLACKER JOHN M. POPILOCK MICHELE J. THORP G. CHRISTOPHER PARRISH CLAUDIO J. DiPAOLO STEPHANIE L. HERSPERGER DRUMMOND B. TAYLOR OF COUNSEL JAMES K. THOMAS 717/255-7639 JBR@tthlaw.com April 26, 2001 Cumberland County Prothonotary Cumberland Coulity Courthouse One Courthouse Square Carlisle, PA 17013 Re: Tingle v. Lamason No. 2000-3069 Dear Sir or Madam: Enclosed for filing please find Defendant's Motion to Compel Answers to Interrogatories and Request for Production of Documents in the above-captioned case, Also enclosed please find a self-addressed stamped envelope to return the clocked-in copies to me. Thank you for your attention to this matter. Very truly yours, JBRlbsw Enclosures cc: Jonathan Crist, Esquire (w/enc) :114573,3 $'- -4 -D/ (7 ~UeL ~. )J-/o---L.~Ur1 V ~ O~LbL i~ /:::1 S~(~ 7'\uL h)A-~ ~ Quu, " iJ- 21- 01 I . . LEHIGH VALLEY OFFICE: I 2,JLMARKET STREET, P,O, BOX 1172. BETHLEHEM. PA 18016 (610) 868,1675 FAX (610) 868,1702 ~ --,- . . ~ , ' , '" '", "_,', ~" ~",~_ > ~-,.;.~ ~"-_ " -~Md" '..,,, ,_,' ,.'~^ "~~ <,,.-~,,-&,,,,,,,,,-,,"~~,,~,,, ~ --> THOMAS, THOMAS & HAFER, LLP Jeffrey B. Rettig, Esquire Identification Number: 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 717/255-7639 Attorneys for Defendant Lloyd Frederick lamason IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVil DIVISION - LAW TERRY W TINGLE, Plaintiff v. NO. 2000-3069 FREDERICK LLOYD LAMASON, Defendant ORDER AND NOW, this day of . 2001, upon consideration of Defendant's Motion to Compel Answers to Interrogatories and Responses to Request for Production of Documents it is hereby ORDERED and DECREED that Plaintiffs shall have fifteen (15) days from the date of this Order to supply the Defendants with full and complete Answers to I nterrogatories and Responses to Request for Production of Documents, or suffer an order entering judgment against Plaintiff with prejudice, BY THE COURT: ,,-" , -,~ '~j I I I J, ~ ~. ,- ". - . ~ ~ -~-"," "< . _ _ "'"M"<''',,',_. i-~i , THOMAS, THOMAS & HAFER, LLP Jeffrey B, Rettig, Esquire Identification Number: 19616 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 717/255-7639 Attorneys for Defendant Lloyd Frederick lamason IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVil DIVISION - LAW TERRY W. TINGLE, Plaintiff v. NO, 2000-3069 FREDERICK LLOYD LAMASON, Defendant RULE TO SHOW CAUSE AND NOW, this day of , 2001, upon consideration of the attached Motion of Defendant, Lloyd Fredrick lamason to Compel Plaintiff's Answers to Interrogatories and Responses to Request for Production of Documents, shall be produced or show cause why Defendant's Motion should not be granted. RULE RETURNABLE DAYS FROM DATE OF SERVICE BY THE COURT: J. " . ~ ,><, ,~.' - .., ,-,-,---_.""'....''"1'-'" ~",",''''~~'.. =,~'" __, ."'""~,~-"',,_"_P' ,_'~, ~W' ,'''' -"_'"_'~" '--t,~_" ' ~mi~ , THOMAS, THOMAS & HAFER, LLP Jeffrey B. Rettig, Esquire Identification Number: 19616 305 North Front Street P,O. Box 999 Harrisburg, PA 17108-0999 717/255-7639 Attorneys for Defendant Lloyd Frederick Lamason IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW TERRY W. TINGLE, Plaintiff v, NO. 2000-3069 FREDERICK LLOYD LAMASON, Defendant DEFENDANT'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS AND NOW, comes Defendant, Lloyd Fredrick Lamason, by and through his attorneys, Thomas, Thomas & Hafer, LLP, and files the within Motion to Compel Answers to Interrogatories and Responses to Request for Production of Documents and in support thereof, aver as follows: 1, On or about November 17,2000, Defendant served Interrogatories and Request for Production of Documents to Plaintiff Terry Tingle (A copy of the Interrogatories, Request for Production of Documents, and Certificate of Service, all of which are dated November 17, 2000, are attached hereto, made a part hereof and marked Exhibit "A."). 2. Pursuant to the Pennsylvania Rules of Civil Procedure, Plaintiff's answers or objections, if any, were due on or before December 18, 2000. 3. By letter dated April 2, 2001, the undersigned counsel for Defendant notified, in writing, counsel for Plaintiff that Plaintiff's responses to the Interrogatories were overdue and requested the Interrogatories be answered promptly. (A true and correct copy of the April 2, 2001 letter is attached hereto, made a part hereof and marked Exhibit "8."), ~, ,- " ~ ~~" . ,,- _,,- ~G. ,",-'".".,~,,--, ;;,_". .\o-;F""," --~'" ~ --.' -- "~,,,~,,,"_c,,,_ -"'" ,-__~_, _;U1>_,"~"""_q'-,,, '-'";"~''';''''''''' ',,_,__, ,-,,"~~ 4, Plaintiff has not, as of the date of this filing, answered or responded to the requested discovery. 5, Plaintiff has not moved this Honorable Court to enter a protective order pursuant to Rule 4012, Pa.R.C.P., or made any objection thereunder. 6. Plaintiff has not requested or moved for an extension of time to answer the discovery requests. WHEREFORE, Defendant Lloyd Fredrick Lamason requests this Honorable Court enter an Order compelling Plaintiff to fully and completely answer all of the Interrogatories and fully respond to Defendants' Request for Production of Documents within fifteen (15) days, or to suffer an order entering judgment against them with prejudice. Respectfully submitted, -' ,,~ '" ^~,' ' EXHIBIT A ~, '" '~',,-..., ,.-~,' ,""b,'", ., 'I, ,~ ~"" ",c,,,-"_"~_"', "'-f;', rlW,~i ,1- "' ,,;. ~" , -J.' "c_t,,', '. - -~ 'b "'^', "'<' , -" ~ ' , ,'1': TERRY W TINGLE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs v, NO, 2000-3069 CIVIL ACTION - LAW FREDERICK LLOYD LAMASON JURY TRIAL DEMANDED Defendant INTERROGATORIES OF DEFENDANT ADDRESSED TO PLAINTIFF PURSUANT TO THE PROVISIONS of the Pennsylvania Rules of Civil Procedure, as amended, you are required to forward a copy to the undersigned and retain the original, of your answers and objections, if any, in writing and under oath, to the following Interrogatories, within thirty (30) days of service hereof. The Answers shall be inserted in the spaces provided following the Interrogatories, If there is insufficient space to answer an Interrogatory, the remainder of the answer shall follow on a supplemental sheet. '. loo"," . DEFINITIONS AND INSTRUCTIONS A, "DOCUMENT" - writings or recordings of any kind, whether handwritten, typed, or printed, and including, but not limited to, letters, memoranda, bulletins, orders, photographs, microfilms, resolutions, books, computer printouts, computer cards, papers, pamphlets, notebooks, diaries, notes, recording tapes, recording discs, recording wires, manuals, regulations, rules, and forms, B. "IDENTIFY" - when used with reference to a person, shall mean and include the full name, present or last known business address, and if an individual, present or last known home address; each of his or her employers titles with respect to the period covered by these Interrogatories; a description of each duty and responsibility held by each such individual. When used with references to a document or writing, the word "identify" shall mean to include the date it was written; identify each person to how it was addressed and identify each person to whom a copy was identified as being directed, identify each person who received a copy of the document or writing with a description of the document or writing as for instance, "letter", "memorandum"; include the present location and identify its custodian. If any document or writing is no longer in your possession or subject to your control, state what disposition was made of it, the reason for such disposition, the date thereof, and identify its current or last known location and custodian, Whenever you are asked to "identify" an oral communication, the following information should be given as to each oral communication or which you are aware, whether or not you or others were present or participated therein, This information includes the means of communication (e,g, telephone, personal conversation, etc,); where it took place; its date; the names, addresses, employers and positions of all persons who participated in, or who were involved in the communication, all other persons who were present during or who overheard that communication, , ~ , ~ ~ ~,'~' -, the substance of who said what to whom and the order in which it was said, and whether that communication, or any part thereof, was recorded or referred to in any document. C, "CONCERN", "CONCERNED", or "CONCERNING" - means referring or relating to, pertaining to, commenting on, or connected with, in any manner whatsoever, D. "YOU", "YOUR" - means the person in whose name this action is brought, his employees; officers, representatives, agents, and attorneys, or any person working for such persons. E, If you claim that the subject matter of a document or oral communication is privileged, you need not set forth the brief statement of the subject matter of the document, or the substance of any oral communication called for above. You shall, however, otherwise "identify" such document or oral communication and shall state each ground on which you claim that such document or oral communication is privileged. F, As used herein, the term "STATEMENT' means a written statement signed or otherwise adopted or approved by the person making it, or a stenographic, mechanical, electrical or other recording, or a transcription thereof, which is a substantially verbatim recital of an oral statement by the person making it and contemporaneously recorded, These Interrogatories are deemed to be continuing nature, in accordance with the provisions of the Pennsylvania Rules of Civil Procedure, as amended. If between the time of forwarding your original answers to these Interrogatories, and the time of trial of this matter, you or anyone acting on your behalf learn the identify and location of additional persons having knowledge of discoverable facts and the identity of persons expected to be called as an expert witness at trial not disclosed in your Answers, or if you or an expert witness obtain information upon the basis of which you or he knows that an Answer, was incorrect when made, or knows that an Answer, though correct when made, is no longer true, then you shall promptly supplement your "' - ~ " ~' "1,-" original Answers under oath to include such information thereafter acquired, and promptly furnish such a supplemental Answer on the undersigned, THOMAS, THOMAS & HAFER, LLP Date: /;j;Jjou ,JEFy EY B, RETTI}d, QUIRE /905 NORTH FRON REET 'P,O, BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7639 IJt... 'C_"", " 1, Please state: (a) Your full name; (b) Each other name, if any, which you have used or by which you have been known; (c) The name of your spouse at the time of the accident and the date and place of your marriage to such spouse; (d) The address of your present residence and the address of each other residence which you have had during the past five years; (e) Your present occupation and the name and address of your employer; (f) Date of your birth; (g) Your Social Security number; (h ) Your military service and positions held, if any; and (i) The schools you have attended and the degrees or certificates awarded, if any. ANSWER: . , . '~ " -,-co ~, 2, List and describe all expenses and losses that you have incurred because of the incident [Please do not simply refer to the allegations contained in the Complaint], ANSWER: " .~" -'~ . ., d , ~"" ~i,'; 3, Identify each person you intend to call as a non-expert witness at the trial of this case, and for each person identified, state your relationship with the witness and the substance of the facts to which the witness is expected to testify, ANSWER: '" ',.- 4, Identify each expert you intend to call as a witness at the trial of this matter, and for each expert state: (a) The subject matter about which the expert is expected to testify; and (b) The substance of the facts and opinions to which the expert is expected to testify and a summary of the grounds for each opinion, (You may file as your answer to this interrogatory, the report of the expert or have the interrogatory answered by your expert,) ANSWER: --1i ~;~ ,_c, ",' 5. State in detail the nature of the injuries that you allege have been suffered as a result of this incident and with specificity. state the following information: a, the nature and extent of such injuries; b, the location of any injuries sustained; and c. whether any restraint from normal activities was suffered due to the injuries allegedly sustained, ANSWER: ,-, ~, ' , ....j,,~ , .1<1. --,',-.,,'.-' 6, State the medical treatment or procedures that have been performed in any connection with the injuries allegedly sustained in this incident. Please also state the name and address of any and all physicians or doctors who performed any and all procedures and the dates in which any and all procedures were performed, ANSWER: '- " ".~-" , ~ fi,' -' ,Ii"' ~. ' . . '_I "n "c,,1 J l,^ ^ - ~~, , , ..~., 1 ';';' '~,i,:' ^' ;",:<._ 7. If, either prior to or subsequent to the incident, you suffered any injury or disease in those portions of the body claimed by you to have been affected by the incident state: (a) The injury or disease you suffered; (b) The date and place of any accident, if such injury or disease was caused by an accident; (c) The identity of hospitals, doctors, or practitioners who rendered treatment or examination because of such injury or diseases; and (d) The identity of anyone against whom a claim was made, and the tribunal and docket number of any claim or lawsuit that was filed in connection with such injury or disease. ANSWER: HJ .~ ,~ " 0_,_ ~, "'ilih. 8, For the period of three years immediately preceding the date of the incident, state: (a) the name and address of each of your employers, or if you were self-employed during any portion of that period, each of your business addresses and the name of the business while self-employed; (b) The dates of commencement and termination of each of your periods of employment or self-employment; (c) The nature of your occupation in each employment or self-employment; and (d) The wage, salary, or rate of earnings received by you in each employment or self- employment, and the amount of income from employment and self-employment for each year. ANSWER: -~ ,ll ~ , r- ,~'! -,'_ - , _", '~.o .--".;, 9, If you have engaged in one or more gainful occupations subsequent to the date of the incident. state: (a) The name and address of each of your employers or. if you were self-employed at anytime subsequent to the incident. each of your business addresses and the name of the business while self-employed; (b) The dates of commencement and termination of each of your periods of employment or self-employment; (c) The nature of your occupation in each employment or self-employment; (d) The wage. salary or rate of earnings received by you in each employment or self- employment. and the amount of income ,from employment and self-employment for each year; and (e) The date(s) of any absence(s) from your occupation resulting from any injury or disease suffered in this incident, and the amount of any earnings or other benefits lost by you because of such absence(s), ANSWER: , -' , ,---, ,.. ,.-, , , - ~, "-,, "ilk! 1 O. If, as a result of this incident, you have been unable to perform any of your customary occupational duties or social or other activities in the same manner as prior to the incident, state with particularity: (a) The duties and/or activities you have been unable to perform; (b) The periods oftime you have been unable to perform; and (c) The identity of all persons having knowledge thereof. ANSWER: - -, .--", . - ,~, " 11, Please state the name, address, and telephone number of your family physician and each and every physician you have consulted in the last five (5) years prior to the date of this incident, as well as indicate the date in which Plaintiff last consulted any physician for any type of physical complaint and the reason for such consultation, ANSWER: "^ ''''-',,-.,-~ -_" -"" if ''-'';:,,' "~ . -~ " " 1 L~ ' ;-~ '", -~ ~d' 12, Do you currently receive treatment or medication for the injuries allegedly suffered in this incident? If so, please identify the type of treatment and/or medication. ANSWER: ~ " ,~.',..h "'-_ 13, Please state for a five (5) year period prior to or at any time subsequent to the date of this incident, whether you sustained any injury, illness, or disability other than what you have described in answer to any of the preceding Interrogatories. ANSWER: o' -,;,__. _.',j '_',' 'Ifu,-; < -,<", . "' ,'~ ~. .~~--" 14, If you are making a claim for lost wages as a result of the injuries you allegedly received in this incident, please indicate the amount of wages lost and specify the source(s) of any and all lost wages, ANSWER: ~",- 15. Are you now receiving, or have you ever received, any disability pension, income, or insurance of workmen's compensation from any agency, company, person, corporation, state, or government? If so, please state: a. The nature of any such payment; b. The date you received such income; C. For what injuries or disability you received it, and how such injury occurred or disability arose; d. By whom paid; e. Whether you now have any present disability as a result of such injuries or disability; f. If so, the nature and extent of such disability; g. Whether you had any disability at the time of the incident referred to in the Complaint; h. If so, the nature and extent of such disability. ANSWER: .' . 16. Have you made a claim for any benefits under any medical pay coverage or policy of insurance relating to the alleged injuries suffered in this incident? If so, please state: a. The name of the insurance company or organization to whom such claim was made; b. The date of the claim or application; c. The claim and policy numbers; d. Whether or not such claim was paid, and if so, the nature of the amount received; e. Whether the company required you to assign to it any rights of recovery you may have against others. ANSWER: ,', .",~ 17. Please give an account, itemized as fully and as carefully as possible, of all losses and expenses which you claim were incurred by you as a result of this incident, and please include in your answer, those losses or expenses which are attributable to hospitals, doctors, medicines, and/or loss of earning capacity. ANSWER: 1h-' ~~, ~"'-i --" " '~ ",-~"",,~ "" "" 18. Have you ever been involved in any other legal action for personal injury, or property damage, either as a Plaintiff or as a Defendant? If so, please state: a. the date and place each such action was filed, identifying the name of the Court, docket nurnber, and attorneys representing each party; b. a brief description of each such incident or lawsuit; and c. the result of each such action, whether or not there was an appeal, and the nature and result of any such appeal. ANSWER: , " ,-, -.-, ,~ ' , .;;.. 19. Please identify each document which you intend to introduce at the time of trial of this matter, and give a brief description of the contents of the document or thing, and attach copies to your Answers to these Interrogatories. ANSWER: '" ," "=~ -, -~ ",,, 20. Please identify all first party benefits which have been paid under the policy for medical services rendered to the Plaintiff as a result of the accident which forms the basis of this litigation. For each bill, identify the health care provider, the date(s) of service, the service(s) rendered, the amount of the bill and the amount of the payment. ANSWER: ;." - . " ;. 21. Please identify all bills of medical services rendered to Plaintiff as a result of the accident, which have not been paid under the policy. For each such bill identify the health care provider, the date(s) of service, the service(s) rendered, and the amount of the bill which remains outstanding. ANSWER: .'" '- - '~ --.."' '-"'---,d; "",'" ~~,' '" "= .' ~, 22. Please identify all first party benefits which have been paid under the policy for Plaintiff's lost wages as a result of the accident which forms the basis of this litigation. For each such payment, identify Plaintiffs employers, the dates missed from work and the amount of the payment. ANSWER: , ,lI." ~ t.l >=. " ~,' , "~,~, PI 23. Is Plaintiff seeking recovery of any lost wages which have not been paid under their PIP policy? If so, please identify the dates of employment, the employer and the amount of lost wages. ANSWER: -" "" '="'-~~ ',' 24. Please identify each "program, group contract or other arrangement" as those terms are defined by 75 Pa.C.SA S1719(b), which has paid, or is obligated to pay, any benefits to the Plaintiff for injuries and/or damages allegedly sustained in the accident which forms the basis of this litigation. For each such "program, group contract or other arrangement," please provide the following information: (a) Identify the "program, group contract or other arrangement"; (b) Identify the amount of benefits paid or payable to Plaintiffs as a result of their injuries and/or damages sustained as a result of the accident; and (c) For each benefit which has been paid identify the health care provider which rendered the service, the date(s) of service, the service(s) rendered, the amount of the billa nd the amount of the payment. ANSWER: " ~~ ", , '.d-, '" '~- .'il';;~ :liJ- ~~ 25. Does Plaintiff require corrective lenses? If so, was Plaintiff wearing any corrective lenses at the time of the incident in question? ANSWER: . ""C,,,.,', ""'0}, ~ ','M ,'. " CERTIFICATE OF SERVICE I, Jeffrey B. Rettig, Esquire, hereby certify that I have served a true and correct copy of the foregoing document on the following person by placing same in the United States mail, postage I1J prepaid, on the~ day of November, 2000: Jonathan M. Crist, Esquire P.O. Box 825 Harrisburg, PA 17108 THOMAS, THOMAS & HAFER, LLP :114154.1 -i " ' '-', ~~ ';" ..;' ,"^ -'~';."~' -, tki,~: . ' . TERRY W. TINGLE Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-3069 v. CIVIL ACTION - LAW FREDERICK LLOYD LAMASON JURY TRIAL DEMANDED Defendant DEFENDANT'S REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF Defendant hereby requests that you furnish pursuant to Rule 4009 of the Pennsylvania Rules of Civil Procedure, at our expense, or permit the Defendant or someone acting on its behalf to inspect, examine, and copy the following items concerning this action which are in the possession, custody, or control of the Plaintiff, counsel for Plaintiffs, or any other person or entity acting on behalf of Plaintiffs, including any insurer(s) for Plaintiffs. Said items shall be produced or made available for inspection at the office of Defendants' attorneys located at 305 North Front Street, Harrisburg, Pennsylvania within thirty (30) days after service of this Request, on a date and time to be arranged between counsel: -",' 3~ ~ ,', "'e ,'"" ";,,, "." ,",',..;..., j,."j , I. All photographs showing, representing or purporting to show any of the persons, property, injuries and any and all other matters related to the subject matter of this litigation. 2. All statements, including but not restricted to those defined by Pa.R.C.P. 4003.5, signed statements, transcripts of recorded statements or interviews, or any memoranda or summary of transcripts of statements or interviews of any party, person or witness, or their agents or employees, who have any knowledge or information of the facts concerning or pertaining to the incident, the subject matter, the claims, the damages, injuries, or any other matter involved in or pertaining to this case. 3. A curriculum vitae as to each expert or experts you have retained to testify on your behalf at the trial of this case. 4. All documents prepared by you or by any insurer(s), representative(s), agent(s) or anyone acting on your behalf, except your attorney(s), during an investigation of any aspect of the incident in question. Such documents shall include any documents made or prepared through the present time with the exclusion of mental impressions, conclusions or opinions respecting the value or merit of a claim or defense or respecting strategy or tactics. (NOTE: As referred to herein, "documents" includes written, printed, typed, recorded or graphic matter, however produced or reproduced, including correspondence, telegrams, other written communications, data processing storage units, tapes, videos, films, microfilm, microfiche, contracts, agreements, notes, memoranda, summaries, analyses, projections, indices, work papers, studies, test reports, test results, surveys, diaries, cal~ndars, films, photographs, videos, movies, diagrams, drawings, sketches, minutes of me~tings or any other writing [including copies of the foregoing, regardless of whether the parties to whom this request is addressed is not in the possession, custody or control of the original] now in the possession, custody or control of Plaintiffs, their former or present counsel, agents, employees, officers, insurers or any other persons acting on their behalf.) 5. If not otherwise covered by the above Requests, any and all documents regarding your investigation of the incident in question, with the exclusion of the mental impressions, conclusions or opinions respecting the value or merit of a claim or defense, or respecting strategy or tactics. -"", " , ,"~,- iJ~1.,i 6. All documents relating in any way to all injuries, damages and losses sustained by Plaintiff. This should include, but not be limited to repair invoices, bills, medical invoices, medical reports, medical records, medical bills, receipts, hospital records, charts and x-rays, wage and employment information, and ail other documents in any way relating to Plaintiff's aileged injuries and damages. 7. Ail documents or exhibits which you intend to offer or identify as exhibits and/or evidence at any depositions or at the trial of this matter. 8. All financial records concerning the Plaintiff including but not limited to any and all tax returns, W-2's, and other filings, employment records, and wage or salary information, for a period of three (3) years prior to the date of this incident and the year of the incident. 9. All documents which would support any claims for injuries/damages averred in Plaintiffs Complaint. 10. A copy of Plaintiff's insurance policy for any policy of auto insurance which was in effect at the time of this incident. 11. Copies of all records and documents reflecting the payment of medical bills for Plaintiff and the amounts paid in satisfaction of such bills. THOMAS, THOMAS & HAFER, LLP I FE. RETTI NORTH FRON , .0. BOX 999 HARRISBURG, PA 17108-0999 (717) 255-7639 Date: II f7/6 C) ~-,j".' " t, CERTIFICATE OF SERVICE I, Jeffrey B. Rettig, Esquire, hereby certify that I have served a true and correct copy of the foregoing document on the following person by placing same in the United States mail, postage prepaid, on the !tflday of November, 2000: Jonathan M. Crist, Esquire P,O. Box 825 Harrisburg, PA 17108 THOMAS, THOMAS & HAFER, LLP uire ~__ ,'" ~ " ,'",c u,,;' "' __ ''>-" " ' ".," __ .,-,,'" ,,,o,;~,~:,,=~:;" "-':'-':'-:'~'="""-'-;' .',,' "__ ~';-~, EXHIBIT B alS - , . Jonathan M. Crist, Esquire P.O. Box 825 Harrisburg, PA 17108 Re: Tingle v. Lamason 717/255-7639 JBR@tthlaw.com April 2, 2001 -,' .,~,~ I,. "' ',-~'~ ,~~~'''''' 'f-~ ~~ \ This letter follows up on our recent telephone conversation during which I advised you that I must insist on answers to our discovery which is now several months overdue. We need to move this case forward and your failure to file timely responses to our discovery has impeded that effort. Please file answers within the next two weeks or we will have no alternative but to file a Motion to Compel. Thank you. JBRlbsw Very truly yours, Thomas, Thomas & Hafer, LLP Jeffrey B. Rettig ~ , '0:'::"" ~ ',;"'. ,~_'~""~,,,~ ",'j,.,';;",-.'.;..,;',"~"" ,,;,:',S"'~" :"':""'_,l\".(.<__:I '& """"J""',,,,:,~ - , CERTIFICATE OF SERVICE I, JEFFREY B. RETTIG, ESQUIRE, hereby certify that I have served a true and correct copy of the foregoing docum~"on the following p(!pn b~ing same in the United States mail, postage prepaid, on the day of '{U , 2001. Jonathan M. Crist, Esquire P.O. Box 825 Harrisburg, PA 17108 THOMAS, THOMAS & HAFER, LLP -~~~.. ,~ ., ~";'lIli<iiidiMi:lfJil_ .. ._~~ "" '_i1,d ~, ~" , ;',,"'~ - ,."," ~ ".."",'~......" "'.. , ,~,," ,~,",", '0 ' ..h,j~' ,-,. ,'," ' "'",' ~..-'.-. o C '2.", -af~\ Cic\:" ~~' tn ':0. ~f5 '.2.- ?;.Q ~g ",)7_ 3. C) -- ~:Y "'V -;:0 '" -' ~ - ..- .' ....I i I ! ~ Sf. "'" t.;l -<! """ ':~~~ '('-::,t!:) ::;~ :E6 ()'?J ~;,,~-\'n 1") '::-I ~ ;..::, , ~ . .. - "'~"~=", IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , '. li' TINGLE Vs. NO. 2000 3069 LAMAS ON CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 JEFFREY B RETTIG, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpo~na(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 06/27/01 JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LANDIS 305 N FRONT ST 6TH F HARRISBURG, PA 17108 717-255-7237 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) By: Christine Janiszewski File #: M275916 . , ;" l' "">~';'A';'" "'~"Ilil IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY "tINGlE Vs. . LAMAS ON No. 2000 3069 TO: JONATHAN CRIST NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) 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 no objection is made the subpoena may be served. Date: 06/06/01 JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LANDIS 305 N FRONT ST 6TH F HARRISBURG, PA 17108 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 By: Christine Janiszewski Enc(s): Copy of subpoena(s) Counsel return card File #: M275916 COMMJNWEI\LTH OF PENNSYLVANIA <XXlNrY OF aJMBERIAND ;,I ,rINGLE Vs. Fi Ie No. 2000 3069 LAMASON SUBPOENA TO PRODUCE D<X:Lt1ENTS OR TH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 WHARTON WELLNESS CTR, 5257 SIMPSON FERRY RD, MECHANICSBURG PA 17055 TO: (Nane of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doct.rnent>: or thin9~: SEE ATl'AC~1J ADDENDl.J1VI at - MEDICAL LEGAL REPRODUCTIONS(A~~~sj940 DISSTON ST., PHILA., PA You may deliver or mail legible copies qf the ~ts or produce things requested b) t.his subpoena, together with the certificate Of "c:CiTpliance, to the party makingthi~ request at the address I isted above. You have the right to seek in advance the reasonab IE cost of preparing the copies or producing the 'things sought. If you fail (20) days after o::rrpe 11 i ng you to to produce the documents or things required by this subpoena within t~enty its servjce, :the party. ,serving .thi<; subpoena may seek a court orde" ccrrply with ,'it; ,::. ',.:',' , . , . THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLCWING PERSON: NAI'E: JEFFREY B RETTIG, ESQ ADDRESS : l\.TTN, C.lI..ROI. LANDIS ... .' , .. ~" ".j '" ~Klo~UKG; ~Ai7108 TELEP.~E:', '-, SUPREI"E ~T I D ,# ATTORNEY FOR: ,'., .. 215-335-3212 19616 DEFENDANT, DATE,;""~ &rt11 IF~!',&(y;f , .' " "1 6f'> the'" rt ' , " ' , ". ,,-;> ii' i";.; i,:'~,"t ,,';,. , ;:'''''- M275916-01 , ,;' .. ,"' i...," '. ~, , " [, J. '~ . . ",:' . ': >: ,~ ,;:, '. " . ".,' . '"~, ,"I :j I. ';' .' J ". ,. ~.' . ~'.- '.j; "," ,','.''-:'', .', ",~' . ,. .: ; ':" ' ,~. ';, ,i, ~ ;. \; '::~ " , ':~ .' '-: ;";' , " ',,',;,' .'..'''' L;):' '.. ~. ".," " A'. ;, ',i,; >,'C,',; "'.. ' (Eff. 7/97) d ,~ .:'f.~.{.:"t::, ~.:__,.'.. ;;;'.:i,;,-,,,,, ,;., , " ';: ~.~">'~ ,.- . , ,'. , (:~ . '. .. ~",,),^ ADDENDUM TO SUBPOENA TI]>TGLE.\ Vs. No. 2000 3069 LAMAS ON CUSTODIAN OF RECORDS FOR: WHARTON WELLNESS CTR ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE, MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO: NAME: TERRY TINGLE ADDRESS: 508 E MARBLE ST MECHANCISBURG PA DATE OF BIRTH: 08/22/46 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - -- ------- ---------- ---- --- -- -- RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ J NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ) RECORDS ( ) X-RAYS ) PATIENT BILLING ) RECORDS / XRAYS have been destroyed Date Authorlzed signature for WHARTON WELLNESS CTR CUMBERLAND M275916-01 *** SIGN AND RETURN THIS PAGE *** ..11 ,": -,,",-, . %""~,~ ~IM~;r@~~ '~<' '" ~,,' -q , ,--~"<', '-' ~, " w 0 ~~ c.'~_ ' 'I .t. , . (") c:: [-:-J c:: OJ I ~ ,- fTj r. , , ;:-:-: .- r::-- ""-'- " 1 ~ (". " (~. : -<: s: C h1:J - .-..- .J'''> C' -? :::<'--.:: C )> f' ~ c__:: " , Z ,"'-.,) :;~ -~ ::0 -' ~. -< '~, ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY TINGLE Vs. NO. 20003069 LAMASON CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena(s) for documents and things pursuant to Rule 4009.22 JEFFREY B RETTIG, ESQUIRE certifies that: 1. A Notice of Intent to Serve the Subpoena(s) with a copy of the subpoena(s) attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena(s) is sought to be served, 2. A copy of the Notice of Intent, including the proposed subpoena(s) is attached to this certificate, 3. No objection to the subpoena(s) has been received, and 4. The subpoena(s) which will be served is identical to the subpoena(s) which is attached to the Notice of Intent to Serve the Subpoena(s). Date: 08/07/01 JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LANDIS 305 N FRONT ST 6TH F HARRISBURG, PA 17108 717-255-7237 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA PA 19135 (215) By: Christine Janiszewski File #: M277141 ~ , u"" "~'-- ,';"',' '-, . ';~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY TINGLE Vs. LAMASON TO: JONATHAN CRIST No. 20003069 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 DEFENDANT intends to serve a subpoena(s) identical to the one(s) 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 no objection is made the subpoena may be served. Date: 07/17/01 Enc(s): Copy of subpoena(s) Counsel return card File #: M277141 JEFFREY B RETTIG, ESQUIRE ATTN: CAROL LANDIS 305 N FRONT ST 6TH F HARRISBURG, PA 17108 ATTORNEY FOR DEFENDANT INQUIRIES SHOULD BE ADDRESSED TO: MEDICAL LEGAL REPRODUCTIONS, INC. 4940 DISSTON STREET PHILADELPHIA, PA 19135 (215) 335-3336 By: Christine Janiszewski [.u . " ~',,'~ , ~. , , ~ "~~j . OJMM)NWEALTH OF PENNSYLVANIA <XXlNl'Y OF aJMBERLAND TINGLE Vs. File No. 20003069 LAMAS ON ORIGINAL X-RAYS REQUESl~ED SUBPOENA TO PROCllX::E DOCU1ENTS OR TI-lI NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 MECHANICSBURG FAMILY PRAC, 122 S FILBERT ST, MECHANICSBURG PA 17055 TO: (N<rne of Person or Entity) within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunent!l orSmtn9!TTACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS~ INC, 4940 DISSTON ST., PHILA., PA ,Address) You may deliver or mail legible copies of the documents or produce things requested b\ this subpoena, together with the certificate of carpliance, to the party making thi, request at the address 1 i sted above. You have the right to seek in advance the rea sonab 1 E cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within t~enty (20) days after its servke, the party serving thi:; ~;ubpoena may seek a court ordeo' corpelling you to carply with it. TI-lIS SUBPOENA WAS ~SSUED AT TI-lE REQUEST OF THE FOLLCNlING PERSON: ~: JEFFREY B RETTIG, ESQ ADDRESS: ATTN: CAROL LANDIS I~RIDDURa; rA 17108 TELEPHONE: SUPREI'E <XlURT I D# ATTORNEY FOR: 215-335-3212 19616 DEFENDANT DATE: ~1~ ::1~ rl36J Seal the COUrt y M277141-01 (Eff'. 7/97) '~""/tj: ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMASON CUSTODIAN OF RECORDS FOR: MECHANICSBURG FAMILY PRAC ANY AND ALL MEDICAL RECORDS, MEDICAL REPORTS, DIAGNOSTIC STUDIES, NOTES, CORRESPONDENCE, MRI FILMS, CAT SCANS AND/OR X-RAY FILMS. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ." - - - RECORD CUSTODIAN - COMPLETE AND RETURN ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ) RECORDS ) X-RAYS ( ) PATIENT BILLING ( ) RECORDS / XRAYS have been destroyed Authorized signature for MECHANICSBURG FAMILY PRAC Date M277141-01 *** SIGN AND RETURN THIS PAGE *** . ~ " "', , ~l!t\ ' . ~TH OF PENNSYLVANIA COONl'Y OF aJMBERLAND TINGLE VS. File No. 20003069 LAMASON ORIGINAL X-RAYS REQUES'l'ED SUBPOENA TO PRODUCE [)()C:UoENTS OR TH I NGS FOR D I SCX>VERY PURSUANT TO RULE 4009.22 ORTHO INST OF PENNA, 875 POPLAR CHURCH RD, CAMP HILL PA 17011 TO: (Nane of Person or Entity) within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunents os~n1ttTACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS '( INC, 4940 DISSTON ST. I PHILA. I H----'-- Address) You rray del iver or mai I legible copies of the docunents or produce things requested b) this subpoena, together with the certificate of carpliance, to the party rraking thi, request at the address listed above. You have the right to seek in advance the reasonablE cost of preoaring the copies or producing the things sought. I f you fai I to produce the docunents or things required by this subpoena with'in t"!enty (20) days after its serv~ce, the party serving thin subpoena may seek a court orde" ccrrpelling you to carply with it. THIS SUBPOENA .WAS ISSUED AT THE REOOEST OF THE FOLLCWING PERSON: JEFFREY B RETTIG, ESQ NAME: ADDRESS: ATTN: CAROL LANDIS IU~RIeBURG, PA 17108 TELEPHONE: SUPREI1: <:x:UlT I D# ATTORNEY FOR: 21~-33~-32l2 , 19616 DEFENDANT DATE: 3~ ;)~, ~l Sea I 0 the Court M277141-02 (Eflf. 1/97) , ,- ,;, '.< ,;0" ", ".L, " .. ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMASON CUSTODIAN OF RECORDS FOR: ORTHO INST OF PENNA ANY AND ALL MEDICAL RECORDS, MEDICAL REPORTS, DIAGNOSTIC STUDIES, NOTES, CORRESPONDENCE, MRI FILMS, CAT SCANS AND/OR X-RAY FILMS. PERTAINING TO: NAME: TERRY TINGLE AnDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - .~ - - - RECORD CUSTODIAN - COMPLETE AND RETURN RECORDS ARE ATTACHED HERETO: I hereby certify. as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ( RECORDS ( ( PATIENT BILLING RECORDS / XRAYS have been destroyed X-RAYS Date Authorized signature for ORTHO INST OF PENNA M277141-02 *** SIGN AND RETURN THIS PAGE *** "-- ';".' !Jl;ti o::MoONWE!\LTH OF PENNSYLVANIA <XXlNl.'Y OF CUMBERU\ND TINGLE VS. File No. 20003069 LAMAS ON ORIGINAL X-RAYS REQUES'l'ED SUBPOENA TO PRClOlX:E DCCU-ENTS OR TH I NGS FOR D I SCX>VERY PURSUANT TO RULE 4009.22 HEALTHSOUTH REHAB, PO BOX 2016, MECHANICSBURG PA 17055 TO: (Ncrne of Person or Ent ity) Within twenty (20) days after service of this subpoena, you are ordered by the c<:>urt to produce the fo I lowing docunent~ OSEltin!srTACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS,( INC, 4940 DISSTON ST., PHILA., PA Address) You may deliver or mail legible copies of the documents or produce things requested bl t.his subpoena, together with the certificate of carp1iance, to the party making thi, request at the adc:lress I isted above. You have the right to seek in advance the reasonab IE cost of preoaring the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within tw.enty (20) days after its serv~ce, the party serving thi'l subpoena may seek a cour't orde.' carpelling you to carp1y with it. TH I S SUBPOENA WAS .1 $SUED AT THE REOOEST OF THE FOl..LCY/I NG PERSON: NA/'E:' JEFFREY B RETTIG, ESQ ADDRESS: ATTN: CAROL LANDIS IlZ'.RRIt::BURG, I']\' 17108 TELEPH:lNE: SU'REI"E CXlURT I D ,~ ATTORNEY FOR: 21t>-.:Ut>-3:l1:l 19616 DEFENDANT DATE: :S:UJ1/\ :23. .)()~ ~~oOurt M277141-03 (Eff. 7/97) .,~ "". "/I~ ADDENDUM TO SUBPOENA TINGLE Vs. LAMAS ON No. 20003069 CUSTODIAN OF RECORDS FOR: HEAL THSOUTH REHAB ANY AND ALL MEDICAL RECORDS, MEDICAL REPORTS, DIAGNOSTIC STUDIES, NOTES, CORRESPONDENCE, MRI FILMS, CAT SCANS AND/OR X-RAY FILMS. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 ORIGINAL X-RAYS REQUESTED CERTIFffiD PHOTOCOPffiS WILL BE ACCEPTED IN LffiU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ( RECORDS ( ( PATIENT BILLING RECORDS / XRAYS have been destroyed X-RAYS Date Author1zed signature for HEALTH SOUTH REHAB M277141-03 *** SIGN AND RETURN THIS PAGE *** - ~,',kl' .. a:J!M)NWEALTH OF PENNSYLVANIA COUNrY OF OJMBERIAND TINGLE VS. File No. 20003069 LAMASON ORIGINAL X-RAYS REQUES1~ED SUBPOENA TO PRCOUCE [)()CU1ENTS OR TH I NGS FOR D I SCX>VERY PURSUANT TO RULE 4009. 22 MAGNETIC IMAGING CTR, 4665 TRINDLE RD, MECHANICSBURG PA 17055 TO: (Nane of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produc:e the following docunentR osE1tn]{TTACHED ADDENDUM ___ at MEDICAL LEGAL REPRODUCTIONS'(Aa~~ess)940 DISSTON ST., PHILA., PA ------ You may deliver or mail legible copies, of the docunents or produce things requested bl this subpoena, together with the certifiicate of carpliance, to the party making thi~ request at the address listed above. You have the right to seek in advance the rea.,onabIE cost of pre~aring 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 serv~ce, the party serving thi:; !;ubpoena may seek a court orde;- c;arpelling you to carply with it. TH I S SUBPOENA WAS NAME: ADDRESS : ISSUEq AT THE REQUEST OF THE FOLLONING PERSON: "JEFFREY B RETTIG, ESQ TELF.PH:lNE: SUPREI"C exulT I D# ATTORNEY FOR: ATTN: CAROL LANDIS lIARRIODURO, rA 17108 215-335-3212 19616 DEFENDANT BY M277141-04 DATE: .:rL~:l~ dool Seal of. e Cou (Ef'f. 7/97) ,''';'',," C_,~ ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMASON CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CTR ANY AND ALL MEDICAL RECORDS, MEDICAL REPORTS, DIAGNOSTIC STUDIES, NOTES, CORRESPONDENCE, MRI FILMS, CAT SCANS AND/OR X-RAY FILMS. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN [ RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ) RECORDS ( ) X-RAYS PATIENT BILLING RECORDS / XRAYS have been destroyed Date Authorized signature for MAGNETIC IMAGING CTR M277141-04 *** SIGN AND RETURN THIS PAGE *** "" '0 ". ~ CCJ!.M)NWE!\LTH OF pmN$YLVANIA COUNl'Y OF aJMBERIAND TINGLE VS. File No. 20003069 LAMASON ORIGINAL X-RAYS REQUESTED SUBPOENA TO PR()[JlX:E [)()CU>ENTS OR lH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 KEYSTONE SPINE CTR, 1521 CEDAR CLIFF DR, CAMP HILL PA 17011 TO: (N<rne of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doa.rnent" orsmtn1tTTACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS,( INC, 4940 DISSTON ST., PHILA., PA Address) You may deliver or mail legible copies of the documents or produce things requested h, this subpoena, together with the certificate of carpliance, to the party making thi~ 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 t~enty (20) days after its serv~ce, the party serving thi!l subpoena may seek a court orde.- carpel ling you to carply with it. TELEPI-KlNE : SUPREr-E o:xJRT 10# ATTORNEY FOR: I SSLiEO AT lHE REQUEST OF THE FOLLOH I NG PERSON: JEFFREY B RETTIG, ESQ ATTN: CAROL LANDIS lIARRHJI3URC" I'll. 1 71 0 8 215-335-3212 lH I S SUBPOENA WAS NA/'E : ADDRESS : 19616 DEFENDANT BY M277141-05 DATE: :Jr./..-It ;)'~I c2mL' Sea I of he Court (EfIF. 1/97) ~,~ '~ ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMASON CUSTODIAN OF RECORDS FOR: KEYSTONE SPINE CTR ANY AND ALL MEDICAL RECORDS, MEDICAL REPORTS, DIAGNOSTIC STUDIES, NOTES, CORRESPONDENCE, MRI FILMS, CAT SCANS AND/OR X-RAY FILMS. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 ORIGINAL X-RAYS REQUESTED CERTIFffiD PHOTOCOPffiS WILL BE ACCEPTED IN LffiU OF YOUR PERSONAL APPEARANCE. - - - - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN - COMPLETE AND RETURN [ RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced!. [ NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ( RECORDS ( ) PATIENT BILLING ( ) RECORDS / XRAYS have been destroyed X-RAYS Date Author~zed signature for KEYSTONE SPINE CTR M277141- 05 *** SIGN AND RETURN THIS PAGE *** "', . 0' " ,~~ m: CO!M)NWEI\LTH OF PrnNSYLVANIA COUNI'Y OF CUMBERIAND TINGLE VS. Fi Ie No. 20003069 LAMASON ORIGINAL X-RAYS REQUES~~ED SUBPOENA TO PRoou:::E lXlCI.M:NTS OR TH I NGS FOR D I $CX)VERY PURSUANT TO RULE 4009.22 HETRICK CTR, 500 N UNION ST, MIDDLETOWN PA 17057 TO: (Ncrne of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunent!'l ~.J.ttinl!OfTACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS'(lj~~s2r40 DISSTON ST., PHILA., PA You may deliver or mai I lesib Ie copies of the docunents or produce things requested ~" this subpoena, together with the certificate of caTllliance, to the party making thi, request at the address listed above. You have the right to seek in advance the r.ea sonab 1 E cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within t~enty (20) days after its servke, the party serving thi:; ~;ubpoena may seek a CQ<Jrt orde'. o::xrpelling you to carply with it. TH I S SUBPOENA, WAS NA/'E : ADDRESS : I SSUED AT THE REOOEST OF THE FOLL(N/ I NG PERSON: JEFFREY B RETTIG, ESQ A'T"I'N: CAROl, LANDIS TELEPI-KlNE : SUPREJoE COURT I D ,~ ATTORNEY FOR: I~RIaDURa,' rA 17108 215-335-3212 19616 DEFENDANT DATE: 3{~~ c:h, ~ Sea I 0 the CoUrt p~Y/C , o !tYl)~~ fA) D BY M277141-06 (Eff. 1/97) L~_.~ ~, . '", ~, ", -~'- '.c-.--~'."TI~t ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMASON CUSTODIAN OF RECORDS FOR: HETRICK CTR ANY AND ALL MEDICAL RECORDS, MEDICAL REPORTS, DIAGNOSTIC STUDIES, NOTES, CORRESPONDENCE, MRI FILMS, CAT SCANS AND/OR X-RAY FILMS. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. --- --- -- -- - ---- -------------------- - - --- RECORD CUSTODIAN - COMPLETE AND RETURN RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ) RECORDS ) X-RAYS ( ) PATIENT BILLING ( ) RECORDS / XRAYS have been destroyed Date Authorized s1gnature for HETRICK CTR M277141-06 *** SIGN AND RETURN THIS PAGE *** -, . ~~ ' ~- , .~ '~" CQMMJNWEl\LTH OF PENNSYLVANIA <XlUNl'Y OF aJMBERL/\,ND TINGLE VS. File No. 20003069 LAMASON ORIGINAL X-RAYS REQUES~rED SUBPOENA TO PROO..lCE lXlCU1ENTS OR TH I NGS FOR 0 I so::lVERY PURSUANT TO RULE 4009.22 ALTERNATIVE PT, 6510 UNION DEPOSIT RD, HARRISBURG PA 17111 TO: (Na:ne of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunent!'l orsMtn1{TTACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS~ INC, 4940 DISSTON ST., PHILA., PA ,Aadress) You may deliver or mail legible copies of the docunents or produce things reqUlested bl this subpoena, together with the certificate of carpliance, to the party making thi, request at the address 1 isted above. You have the right to seek in advance the re,asonab Ie cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within t~enty (20) days after its serv~ce, the party serving thi5 !;ubpoena may seek a coUlrt orde'- c:arpellil19 you to carply with it. TH I S SUBPOENA YfAS N>>1E : ADDRESS : I SSUED AT THE REOOEST OF THE FOLLON I NG PERSON: JEFFREY B RETTIG, ESQ ATTN: CAROL LANDIS llARRIODUR:G, N. 17108 215-335-3212 TELF.PH:lNE: SUPRB-E OOJRT lOti ATTORNEY FOR: 19616 DEFENDANT BY M277141-07 DATE: ~I~ J~ d{bL Sea 1 0, he Cou t (Eff. 1/97) ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMAS ON CUSTODIAN OF RECORDS FOR: ALTERNATIVE PT ANY AND ALL MEDICAL RECORDS, MEDICAL REPORTS, DIAGNOSTIC STUDIES, NOTES, CORRESPONDENCE, MRI FILMS, CAT SCANS AND/OR X-RAY FILMS. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARA.NCE. ------- - --- ---- -....-- -- ------ ------- - - -....-- RECORD CUSTODIAN - COMPLETE AND RETURN [ RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of record,s that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] NO DOCUMENTS A VAlLABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS ( ( PATIENT BILLING RECORDS / XRAYS have been destroyed X-RAYS Date Authorlzed signature for ALTERNATIVE PT M277141-07 *** SIGN AND RETURN THIS PAGE *** <XJMM)N'WEl\LTH OF PENNSYLVANIA <XlUNI'Y OF aJMBffiIAND TINGLE VS. File No. 20003069 LAMAS ON ORIGINAL X-RAYS REQUES~rED SUBPOENA TO PR()()l.I8E DOClJ1ENTS OR TH I NGS FOR 0 I SCOVERY PURSUANT TO RULE 4009.22 TIAN SHI ACUPUNCTURE, 2315 PATTON RD, HARRISBURG PA 17112 TO: (Na-ne of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunento; OSEitinA~TACHED ADDENDUM ___ at - MEDICAL LEGAL REPRODUCTIONS'(AmFesH40 DISSTON ST., PHILA., PA ------ You may deliver or mail legible copies of the doct.rnents or produce things requested hI this subpOena, together with the certificate of carpliance, to the party mElking thi~ request at the address 1 isted above. You have the right to seek in advance the r'easonab IE cost of pre9aring the copies or producing the things sought. I f you fai 1 to produce the docunents or things required by this subpoena within t\o!enty (20) days after its serv1ce, the party serving thi<; ~;ubpoena may seek a cclUrt orde.- o::rrpe 11 i fl9 you to carp 1 y with it. TH I S SU6!'CENA WAS NAI'E : ADDRESS: ISSUED AT THE REQUEST OF THE FOLLCWING PERSON: JEFFREY B RETTIG, ESQ TELF.PH:lNE: SUPREI'E CXlURT 10 # ATTORNEY FOR: ATTN: CAROL LANDIS I~IOBURa, rA 17108 215-335-3212 19616 DEFENDANT DATE: 3/~' rJ~ c000{ Sea 1 the Court ~rothonotarY - 411~d w, _ er ,2.ivi Div~ion U )l~J~^~P M277141-08 (Eff. 7/97) , .' hJ: ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMASON CUSTODIAN OF RECORDS FOR: TIAN SHI ACUPUNCTURE ANY AND ALL MEDICAL RECORDS, MEDICAL REPORTS, DIAGNOSTIC STUDIES, NOTES, CORRESPONDENCE, MRI FILMS, CAT SCANS AND/OR X-RAY FILMS. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - .. - - - RECORD CUSTODIAN - COMPLETE AND RETURN ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ( RECORDS X-RAYS ( ( PATIENT BILLING RECORDS / XRAYS have been destroyed Date Authorized s~gnature for TIAN SHI ACUPUNCTURE M277141-08 *** SIGN AND RETURN THIS PAGE *** "' '., ',-~, '.' , " ~i CQMMJNWEl\LTH OF PmNSYLVANIA COUNl'Y OF aJMBERL1\ND TINGLE VS. File No. 20003069 LAMAS ON ORIGINAL X-RAYS REQUES~1ED SUBPOENA TO PROCll.K::E ocx::LM:NTS OR TH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 CODER CHIRO, 16248 B LINCOLN HWY, LANCASTER PA 17602 TO: (N<me of Person or Entity) within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunent'l orsE'lin]{TTACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS,( INC, 4940 DISSTON ST., PHILA., PA Address) You may deliver or mail legible copies of the docunents or produce things requested h, this subpoena, together with the certificate of C01llliance, to the party making thi, request at the address listed above. You have the right to seek in advance the reasonabl~ cost of pre9aring 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 serv~ce, the party serving thin subpoena may seek a court orde;- c;arpelling you to carply with it. TELEPHONE: SUPREI'E OOJRT I Dt! ATTORNEY FOR: ISSUED AT THE REQUEST OF 1HE FOLLOHING PERSON: JEFFREY B RETTIG, ESQ ATTN: CAROL LANDIS lJARRIIJBURG, I'll. 171 0 8 215-335-3212 THIS-stJ!3POENA WAS NAI'E : ADDRESS : 19616 DEFENDANT , BY M277141-09 DATE: :S-ul~ ~ r--?OOL Seal l' the rt (Eft'. 1/97) '\ '~ ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMAS ON CUSTODIAN OF RECORDS FOR: CODER CHmO ANY AND ALL MEDICAL RECORDS, MEDICAL REPORTS, DIAGNOSTIC STUDIES, NOTES, CORRESPONDENCE, MRI FILMS, CAT SCANS AND/OR X-RAY FILMS. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ( RECORDS X-RAYS PATIENT BILLING RECORDS / XRAYS have been destroyed Date Authorized signature for CODER CHIRO M277141-09 *** SIGN AND RETURN THIS PAGE *** , ".~ ," ~ , ,c, " , ~ '"'Ii!, ~ mMM)NWEl\LTH OF PWNSYLVANIA muNl'Y OF aJMBERIAND TINGLE VS. Fi 1e No. 20003069 LANASON ORIGINAL X-RAYS REQUES1~ED SUBPOENA TO PROOUCE ocx::L.t1ENTS OR TH I NGS FOR DISOOVERYPURSUANT TO RULE 4009.22 TRISTAN ASSOCS, 4518 UNION DEPOSIT RD, HARRISBURG PA 17111 TO: (Ncrne of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunent~ ~:EJ1inlllifTACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS'(}~es!f40 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested h, this subpoena, together with the certificate of carpliance, to the party making thi, request at the address 1 isted above. You have the right to seek in advance the reasonab IE cost of preoaring the copies or producing the things sought. I f you fai I to produce the docunents or things required by this subpoena within t"!enty (20) days after its serv~ce, the party serving thin subpoena may seek a court orde.' o::rr-pelling you to carp1y with it. TH I S SUBPOENA WAS NA/'E : ADDRESS : I SSUED AT THE REQUEST OF THE FOLLCW I NG PERSON: JEFFREY B RETTIG, ESQ ll.TTN: CAROl, LANDIS TELEPI-KlNE : SUPREI'E roJRT 10 # A Tl'ORNEY FOR: IUlliRIGDURG,'rA 17108 215-335-3212 19616 DEFENDANT DATE: ~~ Q3, dCXJ, Sea 1 the eoUrt M277141-10 (Eff. 1/97) iM: ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMMON CUSTODIAN OF RECORDS FOR: TRISTAN ASSOCS ANY AND ALL MEDICAL RECORDS, MEDICAL REPORTS, DIAGNOSTIC STUDIES, NOTES, CORRESPONDENCE, MRI FILMS, CAT SCANS AND/OR X-RAY FILMS. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPffiS WILL BE ACCEPTED IN LffiU OF YOUR PERSONAL APPEARANCE. - - - ... - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -, - - - RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE AITACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ) RECORDS ( ) X-RAYS ( ) PATIENT BILLING ( ) RECORDS / XRAYS have been destroyed Date Authorized s1gnature for TRISTAN ASSOCS M277141-10 *** SIGN AND RETURN THIS PAGE *** - ~ ~~ I I , ' :.....,' "lit; aJMM)NWEALTH OF PENNSYLVANIA CXlUNl'Y OF aJMBERLAND TINGLE Vs. Fi Ie No. 20003069 LAMASON ORIGINAL X-RAYS REQUESTED SUBPOENA TO PROCllX::E DCO..NENTS OR TH I NGS FOR DISCOVERY PURSUANT TO RUlE 4009.22 PENNA NEURO ASSOCS, 108 LOWTHER ST, LEMOYNE PA 17043 TO: (Ncrne of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunent1l og_thin9%T "CHWFI. ~EE AT ft ll..I'JU ADDENDUM at MEDICAL LEGAL REPRODUCTIONS'(;~~~ss~940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the docunents or produce things requested b, this subpoena, together with the certificate of carpliance, to the party making thi~ request at the address listed above. You have the right to seek in advance the reasonablE cost of pre9aring the copies or producing the things sought. I f you fai 1 to produce the docunents or things required by this subpoena within twenty (20) days after its serv~ce, the party serving thi!l ~;ubpoena may seek a court orde." c:arpelling you to carply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOlLOr'/ING PERSON: ~: JEFFREY B RETTIG, ESQ ADDRESS : A'T''T'N' ("AROT, T,ANDIS TELEPHONE: SUPREI'E exulT I D# ATTORNEY FOR: ~RIgBURG, FA 17108 215-335-3212 19616 DEFENDANT BY M277141-11 DATE: :-1i1li d~ ~, Seal f the rt (Eff. 7/97) '" ' ',',,->, ,,",""' , "'~d ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMASON CUSTODIAN OF RECORDS FOR: PENNA NEURO ASSOCS ANY AND ALL MEDICAL RECORDS, MEDICAL REPORTS, DIAGNOSTIC STUDIES, NOTES, CORRESPONDENCE, MRI FILMS, CAT SCANS AND/OR X-RAY FILMS. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS A V AILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ) RECORDS ( ) X-RAYS PATIENT BILLING RECORDS / XRAYS have been destroyed Author1zed signature for PENNA NEURO ASSOCS Date M277141-11 *** SIGN AND RETURN THIS PAGE *** .'.~ , " I," ~' '0., '" v' '''In~, ~TH OF PENNSYLVANIA COUNl'Y OF aJMBERU\ND TINGLE VS. Fi Ie No. 20003069 LAMAS ON ORIGINAL X-RAYS REQUESTED SUBPOENA TO PROOUCE DOCl..t1ENTS OR lH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 DR JOHN SULLIVAN, 3710 MARKET ST, CAMP HILL PA 17011 TO: (Nane of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunent>; ~~inl~TACHED ADDENDUM at - MEDICAL LEGAL REPRODUCTIONS'(1~~stj40 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested h, this subpoena, together with the cert ificate of carp I iance, to the party mak ing th io 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. I f you fai 1 to produce the docunents or things required by this subpoena within t"ienty (20) days after its serv~ce, the party serving thin subpoena may seek a court orde;" c:arpelling you to carply with it. lH I S SUBPOENA WAS NAt'E : ADDRESS : I SSUEO AT lHE REQUEST OF 1HE FOLLON I NG PERSON: JEFFREY B RETTIG, ESQ TELEPH:lNE: SUPR8'E COJ{T I D ,~ ATTORNEY FOR: ATTN: CAROL LANDIS IUffiRIGDURG, rA 17108 215-335-3212 19616 DEFENDANT DATE: 72~2~rfOe>{ ~IA '- . ~~. Deput " M277141-12 (Eff. 7/97) " ~ ,,~ ">",' .."'~ ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMAS ON CUSTODIAN OF RECORDS FOR: DR JOHN SULLIVAN ANY AND ALL MEDICAL RECORDS, MEDICAL REPORTS, DIAGNOSTIC STUDIES, NOTES, CORRESPONDENCE, MRI FILMS, CAT SCANS AND/OR X-RAY FILMS. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 ORIGINAL X-RAYS REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - RECORD CUSTODIAN . COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS ( ( PATIENT BILLING RECORDS / XRAYS have been destroyed X-RAYS Date Author1zed s1gnature for DR JOHN SULLIVAN M277141-12 *** SIGN AND RETURN THIS PAGE *** , .- ..' ~- , " , .. '""Jiltl CQMM)NWE2\LTH OF PENNSYLVANIA CXJUNTY OF aJMBERU\ND TINGLE VS. Fi Ie No. 20003069 LAMASON SUBPOENA TO PRODUCE OOCU1ENTS OR TH I NGS FOR D I SCX>VERY PURSUANT TO RULE 4009.22 HUNTER KEYSTONE PETERBILT, 1463 MANHEIM PK, LANCASTER PA 17604 TO: ATTN: PERSONNEL DEPARTMENT (Na-ne of Person or Entity) within twenty (20) days after service of this subpoena. you are ordered by the court to produce the following doa.rnentl'l os~n~TTACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS\A~~ess~940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the docunents or produce things requested b\ t.his subpoena, together with the certificate of carpliance, to the party making thi, request at the address 1 isted above. You have the right to seek in advance the reasonab IE cost of preparing the copies or producing the things sought. I f you fai 1 to produce the docurents or things required by this subpoena within t\o!enty (20) days after its serv~ce, the party serving thir; subpoena may seek a COUI"t orde;' carpelliilg you to carply with it. THIS SUBPOENA WAS N.AM: : ADDRESS: I SSUED AT THE REQUEST OF THE FOl.LCW I NG PERSON: JEFFREY B RETTIG, ESQ ATTN: CAROL LANDIS lIARRIODURG,' IV. 171 0 8 215-335-3212 19616 DEFENDANT TELEPH:lNE: SUPREI1: roJRT I D ,~ ATTORNEY FOR: DATE: J/~e ~~t ~i M277141-13 (Eff. 1/97) ~..." , "~; ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMASON CUSTODIAN OF RECORDS FOR: HUNTER KEYSTONE PETERBILT ALL EMPLOYMENT RECORDS AND/OR PERSONNEL RECORDS INCLUDING BUT NOT LIMITED TO APPLICATION FOR EMPLOYMENT, HOURLY WAGES, JOB DESCRIPTION, ATTENDANCE RECORDS, DISCIPLINARY FORMS, MEDICAL RECORDS, ETC. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ( RECORDS ( ( PATIENT BILLING RECORDS / XRAYS have been destroyed X-RAYS Date Authorized s~gnature for HUNTER KEYSTONE PETERBILT M277141-13 *** SIGN AND RETURN THIS PAGE *** , - . " ,I'" "'J'" , ,,<,,--, ", -.'= ;'''' ,",. "~i COMM)NWWILTH OF PrnNSYLVANIA axJNl'Y OF aJMBERIANI) TINGLE Vs. File No. 20003069 LAMAS ON SUBPOENA TO PROOUCE DOClJ1ENTS OR Tl-II NGS FOR D I SO:>VERY PURSUANT TO RULE 4009. 22 MOTOR TRUCK EQUIPMENT CO, PO BOX 1922, CARLISLE PA 17013 TO: ATTN: PERSONNEL DEPARTMENT (Nane of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunent'l osEtinA.1:'YACHED ADDENDUM at - MEDICAL LEGAL REPRODUCTIONS'(1~F~s~940 DISSTON ST., PHILA., PA You may deliver or mail legible copies of the documents or produce things requested bl this subpoena, together with the certificate of carpliance, to the party making thi, request at the address listed above. You have the right to seek in advance the reasonablE cost of pre9aring the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within tw.enty (20) days after its serv~ce, the party serving thi!l !;ubpoena may seek a court orde" o::rrpelling you to carply with it. Tl-II S SUBPOENA WAS NJ>JoE : ADDRESS : I SSUED AT Tl-IE REQUEST OF THE FOLLCIH I NG PERSON: JEFFREY B RETTIG, ESQ ATTN: CAROL LANDIS lIARRIDDURG" I'A 171 0 8 215-335-3212 TELEPHONE: SUPREI'E CXlURT I D# ATTORNEY FOR: 19616 DEFENDANT BY M277141-14 DATE: 'Jf~he~:~ c1001 (Eft. 1/97) -' ,.. .... '-~ ~ ----, ,.', ._J, ~...' , , 'c'lii~i . . ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMAS ON CUSTODIAN OF RECORDS FOR: MOTOR TRUCK EQUIPMENT CO ALL EMPLOYMENT RECORDS AND/OR PERSONNEL RECORDS INCLUDING BUT NOT LIMITED TO APPLICATION FOR EMPLOYMENT, HOURLY WAGES, JOB DESCRIPTION, ATTENDANCE RECORDS, DISCIPLINARY FORMS, MEDICAL RECORDS, ETC. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS X-RAYS ( ( PATIENT BILLING RECORDS / XRAYS have been destroyed Date Authorized signature for MOTOR TRUCK EQUIPMENT CO M277141-14 *** SIGN AND RETURN THIS PAGE *** -- '_,'J "" .' ~, - !&i . CQIoM)NWEl\LT!i OF PENNSYLVANIA CXlUNl'Y OF aJMElERU\ND TINGLE VS. File No. 20003069 LAMASON SUBPOENA TO PRODUCE lXXU1ENTS OR TH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 KEEN LEASING C/O PENSKE, RTE 10 GREENHILL PO BOX 563, READING FA 19603 TO: ATTN: PERSONNEL DEPARTMENT (Nane of Person or Entity) within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunentl'l os~nAs.r'IACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS,( INC, 4940 DISSTON ST., PHILA., PA Address) You may deliver or mail legible copies of the documents or produce things requested b) this subpoena, together with the certificate of ca\'l)liance, to the party making thi~ request at the address listed above. You have the right to seek in advance the reasonablE cost of preparing the copies or ~-oducing the things sought. I f you fai 1 to produce the docunents or things required by this subpoena within t\o!enty (20) days after its servke, the party serving thi!l subpoena may seek a court orde,- c.:arpelling you to ca\'l)ly with it. THIS SUBPOENA WAS NAI'E : ADDRESS: ISSUED AT THE REOOEST OF THE FOLLCWING PERSON: JEFFREY B RETTIG, ESQ ATTN' CAROL LANDIS IrnRRIDDURO, rA 17108 215-335-3212 TELEPHONE: SUPREI'E exulT I D# ATTORNEY FOR: 19616 DEFENDANT BY DATE: -)f ~ ;2~ I ~Cb.t- Sea l' the Court u:.i:fJ ~ M277141-15 (Eff. 1/97) "';1 . ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMASON CUSTODIAN OF RECORDS FOR: KEEN LEASING C/O PENSKE ALL EMPLOYMENT RECORDS AND/OR PERSONNEL RECORDS INCLUDING BUT NOT LIMITED TO APPLICATION FOR EMPLOYMENT, HOURLY WAGES, JOB DESCRIPTION, ATTENDANCE RECORDS, DISCIPLINARY FORMS, MEDICAL RECORDS, ETC. *ENPLOYED BY KEEN LEASING INC* PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEAR1\NCE. --- --- - -- ----------------- --- - -- - - -- - --- RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : RECORDS X-RAYS ( ) PATIENT BILLING ( ) RECORDS / XRAYS have been destroyed Date Authorized signature for KEEN LEASING C/O PENSKE M277141-15 *** SIGN AND RETURN THIS PAGE *** -' '';'- ~ m . c:xJMM)NWEALTH OF PENNSYLVANIA COUNl'Y OF aJMBEmAND TINGLE Vs. File No. 20003069 LAMASON MEDICAL BILLING REQUES'1'ED SUBPOENA TO PROOlX::E lXlCU1ENTS OR TH I NGS FOR D I SO::>VERY PURSUANT TO RULE 4009.22 PA BLUE CROSS BLUE SHIELD, 2500 ELMERTON AVE, HARRISBURG PA 17117 TO: ATTN: LEGAL DEPT (N<me of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doa.rnent!l orSE!Jtn1t.l'TACHED ADDENDUM at MEDICAL LEGAL REPRODUCTIONS~ INC, 4940 DISSTON ST., PHILA., PA ,Address) You may deliver or mail legible copies of the documents or produce things requested b) this subpoena, together with the certificate of carp liance , to the party making thiz request at the address I isted above. You have the right to seek in advance the reasonab IE 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 serv~ce. the party serving thin f,ubpoena may seek a court orde,' o::rrpe 11 ing you to carp ly with it. TH I S SUBPOENA WAS NPJoE : ADDRESS: ISSUED AT THE REQJEST OF THE FOLLOiIING PERSON: JEFFREY B RETTIG, ESQ ATTN: CAROL LANDIS 1I1\RRICBURD, I'1\ 17108 TELEPH::lNE: SUPREM:: CXlURT I D# ATTORNEY FOR: 215-330-3212 19616 DEFENDANT DATE: ~tlIV :J3f;1()(J [ Sea I off the COUrt M277141-16 (Efi'. 1/97) . '. , '''< ~ ADDENDUM TO SUBPOENA TINGLE Vs. No. 20003069 LAMAS ON CUSTODIAN OF RECORDS FOR: PA BLUE CROSS BLUE SHIELD ALL HEALTH BENEFIT FILES, INCLUDING BUT NOT LIMITED TO MEDICAL RECORDS, MEDICAL REPORTS, MEDICAL BILLS, DIAGNOSTIC STUDIES, NOTES, CORRESPONDENCE, APPLICATIONS FOR BENEFITS, DENIAL OF PAYMENTS, DAMAGE ESTIMATES, ETC. PERTAINING TO: NAME: TERRY TINGLE ADDRESS: DATE OF BIRTH: 08/22/46 SSAN: 168366511 MEDICAL BILLING REQUESTED CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE. -- - - - - - -- ------ --------------- -- -- -- - --- RECORD CUSTODIAN - COMPLETE AND RETURN [ ] RECORDS ARE ATTACHED HERETO: I hereby certify as custodian of records that, to the best of my knowledge, information and belief all documents or things above mentioned have been produced. [ ] NO DOCUMENTS AVAILABLE: I hereby certify that a thorough search has been made and that no record of the following documents have been located (CHECK THE APPROPRIATE BOX) : ( ) RECORDS ( ) X-RAYS ( ( PATIENT BILLING RECORDS / XRAYS have been destroyed Author1zed s1gnature for PA BLUE CROSS BLUE SHIELD Date M27714l-16 *** SIGN AND RETURN THIS PAGE *** '!ililili!li8It'''' '~l_iill~.-"6tl!lilllllMiHtlilliBilitl.;fiilil\li\1itIlllll'ilaM-MrJiil'ts<I;M!;i!~.ii~"" ' .,-- ~1iIIllIiIi , (') ii~ 0 1 c: .'l'j ~:;: ::~ u < I \"J ,,:; iT; " '::i ) n ;~ 'J-j -'J " (J..- ~ C0 :~--::: ~?~ ~-,~ ~~! ;.:::: '-j :,:>;0 ~~~ ~'S >'0 _...-," Z,,) J;i... CO m C ~S Z .......) --; :::J -< I V -< Ill. ." - , " ~. .^""" , ~ < ' , ..., 'iIillOi,~', IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERRY W. TINGLE, Plaintiff No. 2000-3069 v. CIVIL FREDERICK LLOYD LAMAS ON, Defendant JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Please mark this matter settled, discontinued, and ended. Date: () By: Jo athan . Cris , Esq. A or l.D. No.: 29936 La a Davis & Yohe, P.e. P.O. Box 825 Harrisburg, P A 17108-0825 (717) 761-1880 Attorneys for Plaintiff, Terry W. Tingle 75019 .r&U~..J;.;.' \d.wi',1L1I1J .. ""'~ ,"" ;".'~li!Id~.;l; ~ ~" 0. "" _ ~~,M~ ~ '~'" d ,,,,,,"*,'" ~,! ~ , "~ ' C ~," 1_' ,,, ","",__~ , .V" >>".'" iIIlMi ..... 0 CI ~ C N s: ..". ::,iCC: ~ --, n1nJ ~~11 Z:c -< , 6jS, N --r,m co <':;0 -, Jr.l, r-.". :"~-\...' ...:;J:"?i ~~~ ?~) :JJ :--'7(; 9 (~3nl Z -I ,-, )> -j co :J.:J -, -( 11