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HomeMy WebLinkAbout00-03099 A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEREMIAH K. STONGE and JENNIFER L. STONGE his wife n q j = OkPlaintiffs c?r t?SE???j dal UU V. 9 JOSEPH M. MCKA ON and SUSAN M. MCKASSON, 6341 E??"j F'd- (h^e RA, i0A 17 11 Defendants CIVIL ACTION - LAW No. v Civil Term 2000 JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Issue a writ of summons in the above matter. Date: May 18, 2000 Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. UV David W. Knauer,, s ire Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 + r? C C. :: m p. -? .- -- `? Fr C`am ' r L. s. A I Commonwealth of Pennsylvania County of Cumberland JR.REMIAH K. STONGE and JENNIFER L. STONGE his wife 303 AL-PAT Drive Dillsburg, PA 17019 V8. JOSEPH M. MCKASON and SUSAN M. MCKASSON 634 Erford Rd. Canp Hill, PA 17011 Court of Common Pleas No 2000-3099-Civil-Term W -------------------___ Civil -Act-ion -- Law To _Joseph M__Mckason and Susan M,_ gjkmson You are hereby notified that Jeremiah K. Stonge and Jeniffer L. Stonge his wife ------------------------------------------------------------------------------------------------ Summons- Civil Action - Law the Plaintiffs hare commenced an action in ________._______________________________________________._ against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date -- May 18-------------------- 4g- 2000 Curtis R. Long ------------------------------------------------ Prothonotary By - - - - kAJ_ e I 1 , t J ? " Jy R? i , tom Ul N• i ? m { v m ?' I p Ln to i t t t ) rn c C p w L, Ng 2 'IOU F- cn Z I R O x LQ H x co H C) CD a ci x 0 .t -CASE NO: 2000-03099 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STONGE JEREMAIH K ET AL VS MCKASSON JOSEPH M ET AL HAROLD WEARY Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS JOSEPH M was served upon the DEFENDANT at 0018:20 HOURS, on the 24th day of May 2000 at 634 ERFORD ROAD CAMP HILL, PA 17011 by handing to SUSAN M. MCKASON a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.30 Affidavit .00 Surcharge 10.00 .00 37.30 Sworn and Subscribed to before me this mot day of (a4,? o2.lnn7 A. D. h notary y So Answers: ? A R. Thomas Kline 05/25/2000 KNAUER & ASSOCIATES By: _ Deputy Sheriff SHERIFF'S RETURN - REGULAR 'CASE NO: 2000-03099 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND STONGE JEREMAIH K ET AL VS MCKASSON JOSEPH M ET HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon MCKASSON SUSAN M the DEFENDANT , at 0018:20 HOURS, on the 24th day of May , 2000 at 634 ERFORD ROAD CAMP HILL, PA 17011 by handing to SUSAN M. MCKASON a true and attested copy of WRIT OF SUMMONS together with and at the same time directing Her attention to the contents thereof„ Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this d-?uA, day of 20-fo A. D. rR (I 00 fPtothonotary So Answers: R. Thomas Kline 05/25/2000 KNAUER & ASOCIATES By: : " neputy Sheriff JEREMIAH K. STONGE and JENNIFER L. STONGE, his wife, Plaintiffs V. JOSEPH M. McKASSON and, SUSAN M. McKASSON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-3099 CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, Joseph M. and Susan McKasson with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. Michael S. Ferguson, Esquire Attorney I.D. No. 83882 2411 North Front St. S d Harrisburg, PA 17110 Date: (717) 232-9900 r M V CERTIFICATE OF SERVICE vl? AND NOW, this a0' day of May, 2003, 1 hereby certify that I have served the foregoing Praecipe to Enter Appearance on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: David W. Knauer, Esquire Knauer & Associates, LSC 411A East Main St. Mechanicsburg, PA 17055 Iga-dAi-- Michael S. Fergus , Esquire s C_ Cam: -n 'TJ C<= ni C (TJ -G JEREMIAH K. STONGE and JENNIFER L. STONGE, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-3099 V. JOSEPH M. McKASSON and, SUSAN M. McKASSON, Defendants CIVIL ACTION - LAW PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please issue a Rule upon the Plaintiff to file a Complaint within twenty (20) days or suffer a judgment of non pros. Respectfully submitted, NEALON & GOVER, P.C. Date: S '? 0 3 By: x' Michael S. Ferguson, Esquire Attorney I.D. No. 83882 ' 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 RULE TO THE PLAINTIFF: A Rule is hereby issued upon you to file a Complaint within twenty (20) days of service of this Rule or suffer a judgment of non pros. DATED: ] &U 2- Prothonotary CERTIFICATE OF SERVICE AND NOW, this day of May, 2003, 1 hereby certify that I have served the foregoing Praecipe for Rule to File Complain on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: David W. Knauer, Esquire Knauer & Associates, LSC 411A East Main St. Mechanicsburg, PA 17055 Ao-- . Michael S. Ferguson, Esquire MIN- ` : . °77 ? j ? C YS v IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY PENNSYLVANIA Jeremiah K. Stonge and his wife COURT OF COMMON PLEAS Jennifer L. Stonge -PAUR" COUNTY Plaintiffs Vs. No. 00-3099 Joseph M. McKasson Defendant JURY TRIAL DEMANDED NOTICE TO DEFEND AND CLAIM RIGHTS 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, Pennsylvania 17101 (717) 232-7536 NOTICIA Le han demaandado a usted en la corte. Si usted quieie defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persoa o por abogado y archivar en la corte enforma escrita sus defensas o sus objections a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importanted para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, Pennsylvania 17101 (717) 232-7536 Respectfully submitted, DAVID W. KNAUER, L.S.C. c 06 avid . Kn r, Esquire Attorney for the Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Date: June 17, 2003 (717) 795-7790 IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife COURT OF COMMON PLEAS Jennifer L. Stonge DAUPHIN COUNTY Plaintiffs Vs. No. 00-3099 Joseph M. McKasson Defendant JURY TRIAL DEMANDED COMPLAINT 1. The Plaintiff Jeremiah K. Stonge is an adult individual with an address of 1 Brookside Circle Dillsburg, PA 17019. 2. The Plaintiff Jennifer L. Stonge is an adult individual and spouse of the Plaintiff Jeremiah K. Stonge and resides with him at the aforesaid address. 3. The Defendant Joseph M. McKasson is an adult individual with an address of 634 Erford Road, Camp Hill, PA 17011. 4. At all times relevant, the Defendant was the operator of a certain Datsun (Nissan) Centra owned by Susan M. McKasson. 5. On May 23, 1998 at or about 10:40 p.m., the Plaintiffs were traveling in a northerly direction on Interstate 183 North and were on or approaching the ramp to merge into SR581 West Bound. 6. At the aforesaid time, date and place, the Defendant so operated the aforesaid vehicle that he rammed into the rear of the vehicle containing the Plaintiffs. 7. In the alternative, the aforesaid collision was caused solely by the carelessness, recklessness and negligence of the Defendant in that he: a.) failed to keep a vigilant outlook for traffic traveling in front of him; b.) failed to see the Plaintiffs' vehicle; c.) saw the Plaintiffs' vehicle but failed to avoid striking it; d.) failed to keep an assured clear distance between him and the Plaintiffs' vehicle; e.) struck the Plaintiff's vehicle; f.) appeared to be in an impaired state so that he should not have been operating a motor vehicle. 8. The Plaintiffs suffered injuries solely as result of the carelessness, recklessness and negligence of the Defendant. COUNTI JEREMIAH K. STONGE V. JOSEPH M. MCKASSON 9. The Plaintiff incorporates herein by reference thereto paragraphs 1 through 8 herein as if more fully set forth herein by reference thereto. 10. Solely as a result of the carelessness, recklessness and negligence of the Defendant the Plaintiff has suffered temporomandibular joint dysfunction (TMJ) and soft tissue injuries. 2 11. Solely as a result of the carelessness, recklessness and negligence of the Defendant, the Plaintiff is entitled to the award of past and future damages for: a.) pain and suffering; b.) loss of enjoyment of life; c.) emotional distress; d.) medical expenses. WHEREFORE, the Plaintiff demands judgment in his favor and against the Defendant in an amount in excess of the amount for mandatory referral to arbitration. COUNT II JEREMIAH K. STONGE V. JOSEPH M. MCKASSON CONSORTIUM 12. The Plaintiff incorporates herein by reference thereto paragraphs 1 through 11 herein as if more fully set forth herein by reference thereto. 13. Solely as a result of the carelessness, recklessness and negligence of the Defendant the Plaintiff has suffered the loss of consortium as a result of the injuries hereinafter set froth to his spouse, the co-Plaintiff Jennifer L. Stonge. WHEREFORE, the Plaintiff demands judgment in his favor and against the Defendant in an amount in excess of the amount for mandatory referral to arbitration. 3 COUNT III JENNIFER L. STONGE V. JOSEPH M. MCKASSON NEGLIGENCE 14. The Plaintiff incorporates herein by reference thereto paragraphs 1 through 13 herein as if more fully set forth herein by reference thereto. 15. Solely as a result of the carelessness, recklessness and negligence of the Defendant the Plaintiff has suffered frequent and severe headaches, cervical and lumbar sprain/strain, temporomandibular joint dysfunction (TMJ)and soft tissue injuries. 16. Solely as a result of the carelessness, recklessness and negligence of the Defendant, the Plaintiff is entitled to the award of past and future damages for: a.) pain and suffering; b.) loss of enjoyment of life; c.) emotional distress; d.) medical expenses. WHEREFORE, the Plaintiff demands judgment in her favor and against the Defendant in an amount in excess of the amount for mandatory referral to arbitration. 4 COUNT IV JENNIFER L. STONGE V. JOSEPH M. MCKASSON 17. The Plaintiff incorporates herein by reference thereto paragraphs 1 through 16 herein as if more fully set forth herein by reference thereto. 18. Solely as a result of the carelessness, recklessness and negligence of the Defendant the Plaintiff has suffered the loss of consortium as a result of the injuries hereinafter set forth to her spouse, the co-Plaintiff Jeremiah K. Stonge. WHEREFORE, the Plaintiff demands judgment in her favor and against the Defendant in an amount in excess of the amount for mandatory referral to arbitration. Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. 91't ?"z a 1i X'n'w David W. Kn uer, E uire Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Date: June 17, 2003 (717) 795-7790 5 VERIFICATION Subject to the penalties of '18 Pa. C.S.A. 40-04 re Iating to unsv.orn fa!slficci ion to authorities, we hereby cerliy'hat the facts in the forecoina Pleading are true and correct to the best of our Informatlon and bellef. -- 6 _/:1_03 D aI . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs COURT OF COMMON PLEAS DAUPHIN COUNTY vs. Joseph M. McKasson Defendant No. 00-3099 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 17th day of June, 2003, serve a true and correct copy of the Complaint by United States mail, first class, prepaid addressed as follows: Michael S. Ferguson, Esquire Nealon and Gover 2411 North Front Street Harrisburg, PA 17110 ujalv? David W. Knauer, sq ire Attorney for Plaintiffs ID No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 d?atdV% . ?.-...uy vm.;a;,eyrY?u.;aec??.u?rssewex?u,?c aw+?.+?a.?sa,a?a??l5 - "?w° D c-_ CJ iJir c n -< JEREMIAH K. STONGE and IN THE COURT OF COMMON PLEAS OF JENNIFER L. STONGE, his CUMBERLAND COUNTY, PENNSYLVANIA wife, Plaintiffs NO. 2000-3099 v. JOSEPH M. McKASSON, Defendant CIVIL ACTION - LAW NOTICE TO PLEAD TO: Jeremiah K. Stonge & Jennifer Stonge c/o David W. Knauer, Esquire 411-A East Main St. Mechanicsburg, PA 17055 YOU ARE HEREBY NOTIFIED to file a written response to the enclosed Answer with New Matter within twenty (20) days from service hereof or a judgment may be entered against you. Respectfully submitted, NEALON & GOVER, P.C. By: - Michael S. Ferguson, Esquire Attorney I.D. No. 83882 2411 North Front St. Harrisburg, PA 17110 Date: (t 3o a3 (717) 232-9900 JEREMIAH K. STONGE and JENNIFER L. STONGE, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-3099 V. JOSEPH M. MCKASSON, Defendant CIVIL ACTION - LAW DEFENDANT'S ANSWER AND NEW MATTER TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Joseph M. McKasson, by and through his attorneys Nealon & Gover, P.C., and in response to Plaintiff's Complaint avers the following: 1.-2. The averments contained in these paragraphs are neither admitted or denied. The Defendant does not know where the Plaintiffs in this matter reside. 1-5. Admitted. By way of further answer, the location of this accident was in Cumberland County Pennsylvania. 6. Admitted in part, denied in part. It is admitted that the Defendant operated the previously mentioned vehicle. It is denied that he rammed into the rear of the vehicle containing the plaintiffs. It is admitted however that the Defendant's vehicle did have contact with the Plaintiff's vehicle. 7.-8. Denied pursuant to Pa.R.C.P. 1029(e). COUNTI JEREMIAH,K. STONGE v. JOSEPH M. McKASSON NEGLIGENCE 9. No responsive pleading is required. However, the Defendant incorporates his responses to paragraphs 1 through 8 by reference. 10.-11. Denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, the Defendant Joseph M. McKasson requests that Count I of the Complaint filed on behalf of Jeremiah K. Stonge be dismissed and costs be placed upon the Plaintiff. COUNT II JEREMIAH K. STONGE v. JOSEPH M. McKASSON CONSORTIUM 12. No responsive pleading is required. However, the Defendant incorporates his responses to paragraphs 1 through 11 by reference. 13. Denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, the Defendant Joseph M. McKasson requests that Count II of the Complaint filed on behalf of Jeremiah K. Stonge be dismissed and costs be placed upon the Plaintiff. COUNT III JENNIFER L. STONGE v. JOSEPH M. McKASSON NEGLIGENCE 14. No responsive pleading is required. However, the Defendant incorporates his responses to paragraphs 1 through 13 by reference. 15.-16. Denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, the Defendant Joseph M. McKasson requests that Count III of the Complaint filed on behalf of Jennifer L. Stonge be dismissed and costs be placed upon the Plaintiff. COUNT IV JENNIFER L. STONGE v. JOSEPH M. McKASSON CONSORTIUM 17. No responsive pleading is required. However, the Defendant incorporates his responses to paragraphs 1 through 16 by reference. 18. Denied pursuant to Pa.R.C.P. 1029(e). WHEREFORE, the Defendant Joseph M. McKesson requests that Count IV of the Complaint filed on behalf of Jennifer L. Stonge be dismissed and costs be placed upon the Plaintiff. NEW MATTER 19. Paragraphs 1 through 18 of Defendant's answers are incorporated herein by referenced. 20. Plaintiff's Complaint is barred in whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act 75 Pa.C.S.A. § 1701 et. seq. WHEREFORE, the Defendant Joseph M. McKasson respectfully requests that the Complaint against him be dismissed with the costs of this action. Respectfully submitted, NEALON & GOVER, P.C. By: 4 Michael S. Ferguson, Esquire Attorney I.D. No. 83882 2411 North Front St. Harrisburg, PA 17110 Date: ?¢ w0 03 (717) 232-9900 VERIFICATION I, Joseph M. McKesson, verify that the statements made in the foregoing Answer and 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 unsworn falsification to authorities. Date: ?,/zi&3 q1, Jo eph M. McKasson CERTIFICATE OF SERVICE AND NOW, this 31' day of June, 2003, 1 hereby certify that I have served the foregoing Answer and New Matter on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: David W. Knauer, Esquire Knauer & Associates, LSC 411A East Main St. Mechanicsburg, PA 17055 IMichael S. Fergu n, Esquire r? Tr?Wa` ,? ,?; r ` ? 14 tJ ? ???? ?> ?y ? l? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs vs. Joseph M. McKasson Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 00-3099 JURY TRIAL DEMANDED REPLY TO NEW MATTER 20. Denied as alleged. The Plaintiffs aver to the contrary that paragraph 20 of the Defendant's New Matter is a conclusion of law to which no reply is required pursuant to the Pennsylvania Rules of Civil Procedure and strict proof thereof is demanded at time of trial. WHEREFORE, the Plaintiffs demand judgment in their favor and against the Defendant on the Defendant's New Matter. Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. avi W. nauer, squire Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Date: July 8, 2003 (717) 795-7790 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs Vs. Joseph M. McKasson Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 00-3099 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 8th day of July, 2003, serve a true and correct copy of the Answer to New Matter by United States mail, first class, prepaid addressed as follows: Michael S. Ferguson, Esquire Nealon and Gover 2411 North Front Street Harrisburg, PA 17110 W? vi W. Knauer, squire Attorney for Plaintiffs ID No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 C) ° -? t f71 f 1 3??1 ?I ? C? m r; :J1 ?n N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs Vs. Joseph M. McKasson Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 00-3099 JURY TRIAL DEMANDED TO THE DEFENDANTS-THIS IS A REPLY ON BEHALF OF BOTH PLAINTIFFS 1. See attached. 2. Please find enclosed a copy of Notice of Continuation from the District Justice Criminal proceedings that the Pennsylvania State Police charged against the Defendant as a result of the collision wherein the Defendant's negligence injured the Plaintiffs. 3. See, attached photographs of the Defendants chalk drawing of the scene of the accident at the District Justice hearing. 4. The Plaintiff has not yet determined who they will call as expert witnesses and therefore as to expert witnesses, the Plaintiffs object to this request. After the Plaintiffs determine whom they will call as expert witnesses, they will so notify the Defendant and provide copies of the expert's reports. 5. See, 4. 6. See, records attached. The Plaintiffs reserve the right to supplement this reply as and when appropriate. 7. The Plaintiffs object to this request because at this time they are not making any claim for lost wages in excess of the loss wage protection of their automobile insurance policy and therefore they are precluded from pleading or proving loss of income claims unless and until their losses would exceed that coverage. Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. David W. Knauer, Esquire Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Date: September 18, 2003 (717) 795-7790 VERIFICATION Subject 10 in2 penalties Ci Ala Pc. ^ C rt C.S.A. <„ Q4 relating to uns;:crn falsification to aL'iilorltieS, we hereby cent-y t •hat ti;e ;acts in tne'crecoina ,^!ea Cing are true aiid Correct to the best of oLr i -fc)"mation and bejlef. Date: 7101 c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs Vs. Joseph M. McKasson Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 00-3099 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 18th day of September, 2003, sere a true and correct copy of the within document by United States mail, first class, prepaid addressed as follows: Michael S. Ferguson, Esquire Nealon and Gover 2411 North Front Street Harrisburg, PA 17110 avid W. Knauer, Esquire Attorney for Plaintiffs ID No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 r r, -fi 5; c, T. -{ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs Vs. Joseph M. McKasson Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 00-3099 JURY TRIAL DEMANDED ANSWERS TO DEFENDANTS INTERROGATORIES - FIRST SET 1. Jennifer Leigh (Petrone) Stonge, Jeremiah Kristin Stonge 2. NA -Jennifer leigh Petrone; 11/14/73 to 1/4/97; marriage 3. 1 Brookside Circle, Dillsburg, PA 17019 (6/01 - Present) 303 AI-Pat Drive, Dillsburg, PA 17019 (1/97 - 6/01) 310 AI-Pat Drive, Dillsburg, PA 17019 ( -1/97) 4. 11/14/73 Pennsylvania Cumberland Camp Hill 5. 207-64-9395 Jennifer 183-56-7247 Jeremiah 6. Jeremiah Kristin Stonge and Jennifer Leigh Stonge 114/97 Grantham, Pennsylvania 7. No 8. Yes 9. No 10. Jennifer-Currently stay at home mom a) Christian Publications Inc., 3825 Hartzdale Dr., Camp Hill, PA 17011 b) Cashier, stock shelves, help customers, head of children's dept., phone, display creation, etc. c) 2/98 - 4/99 d) Approximately $6.00 per hour e) 24 hrslwk f) Larry Hair, Manager g) Pregnancy a) Messiah College, Word Processing Dept., 1 College Ave., Grantham, PA 17027 b) Word processing operator / dictation, computer skills, memos etc. c) 1/97-1/98 d) Approxiately $8.00+ per hour e) 40 f) Mark Ironside g) Want to go part-time a) Messiah College, Athletic Office, 1 College Ave., Grantham, PA 17027 b) Interim Athletic Secretary / phone, mail, typing, dictating, scheduling etc. c) 5/96 -12/96 d) Work/study approximately minimum wage e) 40 f) Lori Braa, Interim Athletic Director g) A permanent secretary was found a) Messiah College, Athletic Dept., 1 College Ave., Grantham, PA 17027 b) Work Study Student / scheduling, phone, typing, mail, errands, etc. c) 9/92 - 5/96 d) Work/study approximately minimum wage e) part-time f) Jerry Stonge, Assistant Athletic Director / Equipment Manager g) Graduation Jeremiah Stonge a) Stine consulting, 54 Old York Rd., Dillsburg, PA 17019 b) Draftsman/CAD, 3d modeling, communications engineering c) 11/97 - present d) range from $11.00 hour to 20.99 hour e) 40 hours a week f) Duane Stine, Owner g) NA a) Messiah College, Athletic Dept., 1 College Ave., Grantham, PA 17027 b) Work Study Student / equip. maintenance, scheduling. Student host etc. c) 9/93-5/97 d) e) 0 g) Work/study approximately $6.00+ part-time Edwin "Sandy" Bush, Graduation 11. No Head of Sports Medicine 12. Jeremiah- no Jennifer- have been in a few "fender benders" over the years - none resulting in a doctor visit. 13. Jennifer: Neck, back, jaw and headaches, bruised sternum and chin from hitting chest. Jeremiah: Neck, back, headaches, and jaw pain. 14. Jennifer: Shepherdstown Family Practice (Dr. David Wenner) Dr. Gary Schwartz Dr. Robert J. Beaudry, Jr. Dr. Albert Heck Central Pennsylvania Rehabilitation Jen saw the Neurologist in February of '99 (Pennsylvania Neurological Associates, LTD. Jeremiah: same except for Dr. Heck Weber and Associates - saw all doctors - 1999 - 1 st Pregnancy & birth Center for Women's Health - saw all doctors - 2001-2002 - 2nd Pregnancy & birth (plus other medical treatment due to complications) Mid Penn Urology - Dr. Scott Owens - 2002 - kidney stones Susquehanna Surgeons - Dr. Ken Graf - 2002 - gallbladder 15. Jennifer: a) Gallbladder removed by Dr. Graf at Holy Spirit Hospital b) kidney stones c) Two pregnancies with complications: (1) Dr. Ndulv Harrisburg Hospital (2) Holy Spirit Hospital Jeremiah: Family physician - normal colds and flu's 16. Jennifer: Work loss did not exceed threshold Dentist : Charles Fields Jeremiah: Same 17. Jennifer: No Jeremiah: No 18. a) Progressive and Health Assurance Dental - Private through employer b) Rejection from Progressive Did not get extension 19. Jennifer: None except use of splint, Gallbladder, Kidney stones, Family physician & obstetrician Jeremiah: splint p.r.n. & necks 20. See answer 15 21. Dr. Gary Schwartz, Shepherdstown Family Practice, 2140 Fisher Road, Mechanicsburg, PA 17055 22. Jeremiah: None Jennifer: a) Approximately 2000 b) PA, Cumberland, Camp Hill, Lower Allen twp. c) Does not remember the names of the other parties d) I was preparing to back out of a space at the Bon Ton parking lot. A car drove past me and I began to exit. The other car then backed up upon seeing me leaving and I bumped into the right side of her car. e) None f) NA g) NA a) 6/28/01 b) PA, Cumberland County, c) See 22, Camp Hill, Lower Allen Twp. d) I was pulling out of the Burger King parking lot - turning right. A van was approaching from the left with it's right turn signal on. As she slowed I pulled out to turn right and she hit the front to mid left side of my car. e) None f) NA g) NA 23. Jennifer: volleyball 2 times a year, reading, walking with the children Jeremiah: Running and soccer 24. See police report 25. We were traveling home from a friends house and stopped at the end of the onramp for approx. 30 seconds until both lanes of 1-83 were clear of traffic. I pulled out into the right lane and accelerated to approx. 30 mph and signaled to move to the left lane. I noticed oncoming traffic headlights in the left lane in my rearview mirror. They were back quite a distance - I was not concerned about transitioning safely into the left lane. I then transitioned to the left lane while still accelerating and then began to decelerate with the total peak speed at approx. 50 mph. While my foot was still on the brake - now traveling approx. 25 mph - I heard a screeching sound and saw headlights approach quickly and dive under my car. From the brief amount of time that I saw the vehicle in my rear-view mirror, I would estimate that it was traveling on the order of twice my speed. The impact happened just prior to the over-pass bridge and both cars pulled over to the right shoulder, just past the overpass. I then recall traveling up the shoulder (the other car followed) to ensure we were clear of the bridge and any oncoming traffic. 26. a) 321-B 4th street, New Cumberland, PA 17070 b) Traveling home c) No d) NA 27. See police report 28. See police report 29. See police report 30. See police report 31. Jennifer: wears glasses but was not driving, Jeremiah: does not wear glasses 32. N/A Jennifer was the passenger and Jeremiah- none 33. Has not decided but will supplement this answer Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. />Jl '-e?i - - --- David W. nauer, Esquire Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Date: September 18, 2003 (717) 795-7790 VERIFICATION SubjaCt to the penalties of la p2. C.S.A. 4904 relating to Lns\ Crn tai S iliCa lion to 2L'1horitl9S, we hereby certify that the `acts in the ;ereooina p!ecdir ig aTe true and correct to the best c-1 oL'r In;ormatlon and belief Date: - fg -U`3 -T?'G'"J??l? K .???r'9Z IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs vs. Joseph M. McKasson Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 00-3099 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 18th day of September, 2003, serve a true and correct copy of the within document by United States mail, first class, prepaid addressed as follows: Michael S. Ferguson, Esquire Nealon and Gover 2411 North Front Street Harrisburg, PA 17110 David W. Knauer, Esquire Attorney for Plaintiffs ID No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 c? - , <<; K -?,', - - ? _ G ?,_ ,,.? ? , ,._7 ``_f _.. i1 _ 1> ?.,i -? _iq [ ?} -0 A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs Vs. Joseph M. McKasson Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 00-3099 JURY TRIAL PLAINTIFF'S INTERROGATORIES DIRECTED TO THE DEFENDANT To: Joseph M. McKasson PLEASE TAKE NOTICE that you are hereby required, pursuant to Pennsylvania Rules of Civil Procedure No. 4005, to serve upon the undersigned, within thirty (30) days after service of this Notice, your answers in writing under oath to the following Interrogatories. David W. Knauer Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 Date: September 30, 2003 I DEFINITIONS AND INSTRUCTIONS (A) Whenever the term "document" is used herein, it includes (whether or not specifically called for) all printed, typewritten, handwritten, graphic or recorded matter, however produced or reproduced and however formal or informal. (B) Whenever you are asked to "identify" a document, the following information should be given as to each document of which you are aware, whether or not you have possession, custody or control thereof: (1) The nature of the document (e.g., letter, memorandum, computer print-out, minutes, resolution, tape recordings, etc.); (2) Its date (or if it bears no date, the date when it was prepared); (3) The name, address, employer and position of the signer(s) (or if there is no signer, of the person who prepared it); (4) The name, address, employer and position of the person, if any, to whom the document was sent; (5) If you have possession, custody or control of the document, the location and designation of the place or file in which it is contained; (6) If you do not have possession, custody or control of the document, the present location thereof and the name and address of the organization having possession, custody or control thereof; and (7) A brief statement of the subject matter of such document. (C) Whenever you are asked to "identify" an oral communication the following information should be given as to each oral communication of which you are aware, whether or not you or others were present or participated therein: (1) The means of communication (e.g., telephone, personal conversation, etc.); (2) Where it took place; (3) Its date; (4) The names, addresses, employers and positions (a) of all persons who participated in the communication; and (b) of all other persons who were present during or who overheard that communication; (5) The substance of who said what to whom and the order in which it was said; and (6) Whether that communication or any part thereof is recorded, described or referred to in any document (however informal) and, if so, an identification of such document in the manner indicated above. (D) If you claim that the subject mater 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 the 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. (E) Whenever you are asked to "identify" a person, the following information should be given: (1) The name, present address, present employer, and position of the person; and (2) Whether the person has given testimony by way of deposition or otherwise in any proceeding related to the present proceeding and/or whether that person has given a statement whether oral, written or otherwise, and if so, the title and nature of any such proceeding, the date of the testimony, whether you have a copy of the transcript thereof, the name of the person to whom the statement was given, where the statement is presently located if written or otherwise transcribed, and the present location of such transcript or statement if not in your possession. (F) The term "you" shall be deemed to mean and refer to the party to whom these Interrogatories have been propounded for answer and shall also be deemed to refer to, but shall not be limited to, your attorneys, consultants, sureties, indemnitors, insurers, investigators and any other agents insofar as the material requested herein is not privileged. (G) The word "incident" shall be deemed to mean and refer to the incident as alleged to have occurred and as set forth in the Complaint. These Interrogatories shall be deemed to be continuing Interrogatories. Between the time of your answers to said Interrogatories and the time of trial, if you or anyone acting in your behalf learns the identity or whereabouts of other witnesses not disclosed in your answers, or if you obtain or learn of additional information requested herein, but not supplied in your answers, then you shall promptly furnish a supplemental answer under oath containing the same. INTERROGATORIES 1. State the name, age, home and business address, and telephone number of all persons you expect to call as expert witnesses either on liability or on damages at the trial of the above-captioned matter. 2. For all persons identified in the preceding Interrogatory, please enclose a current resume. 3. For all persons identified in answer to Interrogatory No. 2 above, set forth their qualifications, including, but not limited to, the following: (a) The schools or training programs that each has attended, including the years in attendance, and degrees or certificates, etc. received. (b) The name and address of the persons or firms for whom the individual worked for the last ten (10) years and a detailed description of all duties at each place of employment. (c) The facts to which the expert is expected to testify. (d) The opinion to which the expert is expected to testify. (e) A detailed summary of the factual grounds for each opinion. NOTE: If the person or persons listed in answer to Interrogatory No. 2 has provided you with a report which included the above information, you may attach a copy of same in lieu of answering this Interrogatory. 4. State the names, home and business addresses, and telephone numbers of all other persons whom you expect to call as witnesses at the trial of the above-captioned matter, stating whether each of the persons identified is expected to testify as to the issues of liability, or damage or both. 5. State the names, home and business addresses, and telephone numbers of any persons whom you do not expect to call as witnesses at the trial of the above-captioned matter, but who are eyewitnesses to the issue of liability or damages, specifying which as to each such person. 6. State the name, home and business address, and telephone number of any persons whom you do not expect to call as witnesses at the trial of the above-captioned matter and who have knowledge pertaining to the issue of liability. 7. State the name, home and business address, and telephone number of any persons whom you do not expect to call as witnesses at the trial of the above-captioned matter and who have knowledge pertaining to the issue of damages. 8. State the name, home and business address, and telephone number of all persons known by you, your agents or attorneys, who have knowledge relating to the incident, but who have not been listed in answer to any of the preceding Interrogatories. 9. Please attach to your Answers to these Interrogatories any statements which are in the possession of you or your attorney taken of any witness or party regarding the facts and circumstances surrounding the happening of the incident referred to herein. 10. With respect to each of the past five (5) years, state: (a) Your yearly gross income. (b) Your yearly net income. (c) The name and address of the person, firm or corporation having custody of any papers pertaining to your income. (d) Attach copies of your income tax records for the preceding five (5) years. 11. List by name of company, type of policy and dollar amount of coverage any insurance contracts you own. 12. Attach copies of the policies listed in the preceding interrogatory. 13. If you consumed any alcoholic beverages, sedatives, tranquilizers, marijuana, cocaine, hashish, or any oiher drug, medicine or pill during the ten hours prior to the accident, list for each: a. The nature, amount, and typ I e of item(s) consumed b. The amount of time over which the item(s) was consumed c. the identity of all person who have knowledge as to the consumption of the item(s) d. The identity of the physician or medical practiotioner who prescribed such item(s), if any i e. The identity of the person who gave or purchased said item(s) for you. 14. If required by law or regulation to be licensed for the activity in which you were engaged at the time of the accident, please list: a. The type of license required b. The date you first obtained such license c. The identity of the authority that issued your license d. The number of your license e. The nature and duration of any revocation or suspension of any license you have held f. the special restrictions, if any, imposed upon your license Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. David W. Knauer, Esquire Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Date: September 30, 2003 (717) 795-7790 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs Vs. Joseph M. McKasson Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 00-3099 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 30th day of September, 2003, serve a true and correct copy of the Plaintiffs Interrogatories Directed to The Defendant, First Set, by United States mail, first class, prepaid addressed as follows: Michael S. Ferguson, Esquire Nealon and Gover 2411 North Front Street Harrisburg, PA 17110 avid W. Knauer, Esquire Attorney for Plaintiffs ID No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 G , cr? 1 ?CD 1 M CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JENNIFER STONGE -VS- MCKASSON COURT OF COMMON PLEAS TERM, CASE NO: 2000-3099 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/29/2003 ns?n bha1 FERGUS Q. Attorney for DEFEN ANT DE11-447174 2 4 8 3-3 -L O ]- COMMONWEALTH OF PEWWSYI N72kw=A COUNTY OF CUMBER LAN D IN THE MATTER OF: JENNIFER STONGE -VS- MCKASSON COURT OF COMMON PLEAS TERM, CASE NO: 2000-3099 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 BEAUDRY ORAL SURGERY MEDICAL RECORDS SHEPHERDSTOWN FAMILY PRACTICE MEDICAL RECORDS QUANTUM IMAGING & THERAPEUTIC- MEDICAL RECORDS CENTRAL PA. REHAB SERVICES MEDICAL RECORDS JOHN O'DONELL MEDICAL RECORDS TO: DAVID KNAUER, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 MCS on behalf of MICHAEL FERGUSON, ESQ. _ Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUK - Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-240689 2 4 8 1 3- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER STONGE VS. . MCKASSON File No. 2000-3099 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BEAUDRY ORAL SURGERY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESQ. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEYFOR: Defendant SE 2 9 2003 Date: A2.r? -3 Seal of the Court BY THE COURT: Pro ono et Civ' vision Deputy 24813-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BEAUDRY ORAL SURGERY 3600 OLD GETTYSBURG ROAD CAMP HILL, PA 17011 RE: 24813 JENNIFER STONGE Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : JENNIFER STONGR 303 ALPAT DR., DILLSBURG, PA 17019 Social Security #: 207-64-9395 Date of Birth: 11-14-1973 SU10-462876 2 4 8 1 3- L 0 :1. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JENNIFER STONGE MCKASSON COURT OF COMMON PLEAS TERM, -VS - CASE NO: 2000-3099 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/29/2003 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-447175 2 4 8 1 3- L 0 2 COMMONWEALTH OF, P E NN S Y T VAN 2 A COUNTY OF CUMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER STONGE -VS- MCKASSON TERM, CASE NO: 2000-3099 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 BEAUDRY ORAL SURGERY MEDICAL RECORDS SHEPHERDSTOWN FAMILY PRACTICE MEDICAL RECORDS QUANTUM IMAGING & THERAPEUTIC- MEDICAL RECORDS CENTRAL PA. REHAB SERVICES MEDICAL RECORDS JOHN O'DONELL MEDICAL RECORDS TO: DAVID KNAUER, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20). days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUR - Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-240689 2 4 8 1 3- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER STONGE VS. MCKASSON File No. 2000-3099 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SHEPHERDSTOWN FAMILY PRACTICE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Ctto=_ Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESQ. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant SEP 2 2003 Date: 3 Seal of the Court BY THE COURT: ?. Pro honotaryf0 a Civil ivision Deputy 24813-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SHEPHERDSTOWN FAMILY PRACTICE 2140 FISHER ROAD MECHANICSBURG, PA 17055 RE: 24813 JENNIFER STONGE Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : JENNIFER STONGE 303 ALPAT DR., DI LLSBURG, PA 17019 Social Security #: 207-64-9395 Date of Birth: 11-14-1973 SU10-462878 2 4 8 1- 3- 1, 0 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER STONGE TERM, -vs- CASE NO: 2000-3099 MCKASSON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/29/200`3 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-447176 2 4 8 1 3- L 0 3 COMMONWEALTH OF P E XW S Y L VAN 2 A COUNTY OF CUMBER LAND IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER STONGE -VS- MCKASSON TERM, CASE NO: 2000-3099 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCONKUTS AMID THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 BEAUDRY ORAL SURGERY MEDICAL RECORDS SHEPHERDSTOWN FAMILY PRACTICE MEDICAL RECORDS QUANTUM IMAGING E THERAPEUTIC- MEDICAL RECORDS CENTRAL PA. REHAB SERVICES MEDICAL RECORDS JOHN O'DONELL MEDICAL RECORDS TO: DAVID KNAUER, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20). days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUK - MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-240689 2 4 8 1 3- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER STONGE VS. MCKASSON File No. 2000-3099 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for QUANTUM IMAGING & THERAPEUTIC- (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun Inc 1601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESO. ADDRESS: 2411 N. FRONT ST. HARK 7Sj G PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY Tlj? COURT: Pr thonotary/ er , Civil Di ion ?3S 2 9-2003 Deputy Date: Seal of the Court 24813-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: QUANTUM IMAGING & THERAPEUTIC- ASSOCIATES, INC. 3508 TRINDLE ROAD CAMP HILL, PA 17011 RE: 24813 JENNIFER STONGE Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records correspondence to and from the consulting and treating physicians, files, memoranda; handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : JENNIFER STONGE 303 ALPAT DR., DILLSBURG, PA 17019 Social Security #: 207-64-9395 Date of Birth: I1-14-1973 SU10-462880 2 4 8 1 3- L O 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JENNIFER STONGE MCRASSON COURT OF COMMON PLEAS TERM, -VS - CASE NO: 2000-3099 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/29/2003 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-447177 2483-3-L 04 COMMONWEALTH OF P E NN S Y L VAN 2 A COUNTY OF CUM S E R LAN D IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER STONGE -VS- MCKASSON TERM, CASE NO: 2000-3099 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 HEAUDRY ORAL SURGERY MEDICAL RECORDS SHEPHERDSTOWN FAMILY PRACTICE MEDICAL RECORDS QUANTUM IMAGING & THERAPEUTIC- MEDICAL RECORDS CENTRAL PA. REHAB SERVICES MEDICAL RECORDS JOHN O'DONELL MEDICAL RECORDS TO: DAVID KNAUER, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20). days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUK - MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-240689 2 4 8 3.3- C O 2 COMMQNWIrALTH, OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER STONGE vs. MCKASSON File No. 2000-3099 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CENTRAL PA. REHAB SERVICES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed _above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESQ. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: _ 6 3 Seal of the Court BY THE COURT: at4r;4-a? 'z Prothonotary/Clerk(r, Civ/Di eeputy ?T 24813-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CENTRAL PA. REHAB SERVICES 75 EVELYN DRIVE MILLESBURG, PA 17061 RE: 24813 JENNIFER STONGE Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : JENNIFER STONGE 303 ALPAT DR., DILLSBURG, PA 17019 Social Security #: 207-64-9395 Date of Birth: 11-14-1973 SU10-462882 2 4 8 13 -L O 4 PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JENNIFER STONGE TERM, -vs- CASE NO: 2000-3099 MCKASSON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/29/2003 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-447178 2 4 8 1 3- L O S COMMONWEALTH OF COUNTY OF IN THE MATTER OF: JENNIFER STONGE -VS- MCKASSON COURT OF COMMON PLEAS TERM, CASE NO: 2000-3099 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 BEAUDRY ORAL SURGERY MEDICAL RECORDS SHEPHERDSTOWN FAMILY PRACTICE MEDICAL RECORDS QUANTUM IMAGING & THERAPEUTIC- MEDICAL RECORDS CENTRAL PA. REHAB SERVICES MEDICAL RECORDS JOHN O'DONELL MEDICAL RECORDS TO: DAVID KNAUER, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUK - MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 P E NN S Y L VAN 2 A CUMBER LAN D DE02-240689 2 4 8 1 3- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JENNIFER STONGE V3. MCKASSON File No. 2000-3099 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JOHN O'DONELL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG, PA 17110 TELEPHONE: (215)_246-0900 SUPREME COURT ID #: ATTORNEYFOR: Defendant SEP 2 9 2003 Date: 3 ?3 Seal of the Court BY THE COURT: rothOno erk, Ci Division Deputy 24813-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JOHN O'DONELL 2745 N. FRONT ST. HARRISBURG, PA 17110 RE: 24813 JENNIFER STONGE Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : JENNIFER STONGE 303 ALPAT DR., DILLSBURG, PA 17019 Social Security #: 207-64-9395 Date of Birth: 11-14-1973 SU10-462884 2483-3-L 05 c-> ?, - ?,.u -? ?T -? -?-: ??, ;.? n =? ?? CERTIFICATE IN THE MATTER OF: JEREMIAH STONGE MCKASSON PREREQUISITE TO SERVICE OF A SUBPOENA r' PURSUANT TO RULE 4009.22 mrri -? C C. _ COURT OF COMM&C-LEA& C_ TERM, cry -vs- CASE NO: 2000-3099 _- c rr, As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 09/29/2003 MCS n b half of I HA RG ONy AS Attorney for DEFENDA DE11-447171 2 4 8 1 2- 1, 0 1 I COMMONWEALTH OF P E NN S Y L VAN 2 A COUNT Y OF CUMBER LAN D IN THE MATTER OF: JEREMIAH STONGE -VS- MCKASSON A SUBPOENA TO PR( l 1111?401A ? BEAUDRY ORAL SURGERY MEDICAL RECORDS SHEPHERDSTOWN FAMILY PRACTICE MEDICAL RECORDS QUANTUM IMAGING E THERAPEUTIC- MEDICAL RECORDS TO: DAVID KNAUER, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUR - Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT COURT OF COMMON PLEAS TERM, CASE NO: 2000-3099 CE DOCUMENTS AND 4009.21 THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-240688 2 4 8 1 2- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEREMIA14 STONGE VS. MCKASSON File No. 2000-3099 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BEAUDRY ORAL SURGERY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACI4ED RIDER **** at The MCS GE= Inc 1601 Market Street Suite 800, Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON. ESQ. ADDRESS: 2411 N. FRONT ST. ARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant SEP 2 9 2003 Date: Seal of the Court BY THE COURT: Pro onotaryl2ler , Civil ivision Deputy 24812-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BEAUDRY ORAL SURGERY 3600 OLD GETTYSBURG ROAD CAMP HILL, PA 17011 RE: 24812 JEREMIAH STONGE Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : JEREMIAH STONGE 303 ALPAT DRIVE, DILLSBURG, PA 17019 Social Security #: 183-56-7247 Date of Birth: 02-16-1975 SU10-462870 2 4 8 1 2- LO 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JEREMIAH STONGE MCKASSON COURT OF COMMON PLEAS TERM, -VS - CASE NO: 2000-3099 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/29/2003 MICHAEL FERGUSON, ESQ. . Attorney for DEFENDANT DE11-447172 2 4 8 1 2- 1, 0 2 C O M M O NW E AL 7H O Y P E NN S Y L VAN 2 A COUNTY O y CUMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS JEREMIAH STONGE -VS- MCKASSON TERM, CASE NO: 2000-3099 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 BEAUDRY ORAL SURGERY MEDICAL RECORDS SHEPHERDSTOWN FAMILY PRACTICE MEDICAL RECORDS QUANTUM IMAGING & THERAPEUTIC- MEDICAL RECORDS TO: DAVID KNAUER, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUK - MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-240688 2 4 8 1 2- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND VS. JEREMIAH STONGE MCKASSON File No. 2000-3099 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SHEPHERDSTOWN FAMILY PRACTICE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant SE 2 9003 Date: Seal of the Court BY P Civil ivision Deputy 24812-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SHEPHERDSTOWN FAMILY PRACTICE 2140 FISHER ROAD MECHANICSBURG, PA 17055 RE: 24812 JEREMIAH STONGE Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : JEREMIAH STONGE 303 ALPAT DRIVE, DILLSBURG, PA 17019 Social Security #: 183-56-7247 Date of Birth: 02-16-1975 SU10-462872 2 4 8 1 2-Z,0 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JEREMIAH STONGE -VS- MCKASSON COURT OF COMMON PLEAS TERM, CASE NO: 2000-3099 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 09/29/2003 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-447173 2483-2-L 03 COMMON W E A L T H Or P E NN S Y L VAN TA COUNTY Or C UMBER LAN D IN THE MATTER OF: JEREMIAH STONGE -VS- MCKASSON OF I14TEM TO SERVE A COURT OF COMMON PLEAS TERM, CASE NO: 2000-3099 DOCUMENTS AND 4 HEAUDRY ORAL SURGERY MEDICAL RECORDS SHEPHERDSTOWN FAMILY PRACTICE MEDICAL RECORDS QUANTUM IMAGING & THERAPEUTIC- MEDICAL RECORDS T0: DAVID KNAUER, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 09/08/2003 CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUK - MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-240688 2 4 8 1 2- C O 2 COMMONWEALTH. OF PENNSYLVANIA COUNTY OF CUMBERLAND JEREMIAH STONGE VS. MCKASSON File No. 2000-3099 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for QUANTUM IMAGING & THERAPEUTIC- (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: ****SEE ATTACHED RIDER**** at The MCS Groin Inc 1601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or. mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESO. ADDRESS: 2411 N. FRONT T. HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: "03 Seal of the Court BY THE COURT: Pr thono k, vil Division Deputy 24812-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: QUANTUM IMAGING & THERAPEUTIC- ASSOCIATES, INC. 3508 TRINDLE ROAD CAMP HILL, PA 17011 RE: 24812 JEREMIAH STONGE Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical file, including but not limited to any and all records correspondence to and from the consulting and treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis or treatment pertaining to: Dates Requested: up to and including the present. Subject : JEREMIAH STONGE 303 ALPAT DRIVE, DILLSBURG, PA 17019 Social Security #: 183-56-7247 Date of Birth: 02-16-1975 SU10-462874 2 4 8 1 2- L 0 3 T ik IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs vs. Joseph M. McKasson Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 00-3099 JURY TRIAL DEMANDED PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS UNDER PA. R.C.P. NO. 4009 FIRST SET TO: Joseph M. McKasson Pursuant to Pa. R.C.P. 4009, you are hereby requested to produce the below-listed documents and/or items for purposes of discovery. This material will be examined and/or photocopied, photograph negatives will be processed and photographs reproduced. Said documents or tangible things are to be produced at the offices of David W. Knauer, Esquire, 411-A E. Main Street, Mechanicsburg, PA 17055 within forty-five (45) days of the date of service hereof and supplemented thereafter in accordance with Pa. R.C.P. 4007.4: 1. The entire contents of any investigation file or files and any other documentary material in your possession which relate in any manner (excluding references to mental impressions, conclusions or opinions regarding the value or merit of the claim or defense or respecting strategy or tactics and privileged communication from and to counsel) to the within action. . 2. Any and all statements concerning the action, as defined by Rule 4003.4 from all witnesses including any statements from the parties herein, or their respective agents, servants or employees. 3. All photographs taken or diagrams prepared of the scene of the accident/incident or any instrumentality involved therein. 4. Any and all documents containing the names and home and business addresses of all individuals contacted as potential witnesses. 5. Reports of any and all experts who will testify at Trial. 6. Reports of any and all agents or employees of Defendant prepared as a result of the incident. 7. A copy of the Defendant(s) insurance policy. 8. If the Defendant's insurance company is considering or planning to withdraw its provision of a defense of the above action, please attach a copy of any and all documents involved with the decision of issuing a reservation of rights letter or document and of the provision of notice to the Defendant of its decision to reserve rights or withdraw a defense. Respectfully submitted, KNAUER & ASSOCIATES, L.S.C. David W. Knauer, Esquire Attorney for Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 Date: September 30, 2003 (717) 795-7790 t A6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs Vs. Joseph M. McKasson Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 00-3099 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 30th day of September, 2003, serve a true and correct copy of the Plaintiffs Request For Production of Documents Under PA. R. C. P. No. 4009, First Set, by United States mail, first class, prepaid addressed as follows: Michael S. Ferguson, Esquire Nealon and Gover 2411 North Front Street Harrisburg, PA 17110 avid W. Knauer, Esquire Attorney for Plaintiffs ID No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 N51@tll?fi °'°"., ••• G.,:a:.v1iS4ueva`mkv+dt3YiMA(IkEtwWFFkK?YYa's':uraF54iesaLnS?.nh&:c?tiMld M •.•. 41 ti C) L J MCI, ) - _ Z =CS b E-` C_ LO m % Z wF -{ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife COURT OF COMMON PLEAS Jennifer L. Stonge CUMBERLAND COUNTY Plaintiffs vs. No. 00-3099 Joseph M. McKasson Defendant JURY TRIAL DEMANDED NOTICE OF DEPOSITION Please be advised that on January 21, 2004, at 11:00 a.m., the Plaintiff will take the deposition of the Defendant, Joseph M. McKasson, at the law offices of Michael S. Ferguson, Esquire, Nealon and Gover, 2411 North Front Street, Harrisburg, PA 17110, Pennsylvania, before a person authorized by law to administer oaths. The oral examination will continue from day to day until completed. You are invited to attend and participate in this examination. Respectfully submitted, KNAUER & ASSOCIATES, LSC Date: December 17, 2003 David W. Knauer, Esquire Attorney for the Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 J , Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs Vs. Joseph M. McKasson Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 00-3099 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 17th day of December, 2003, serve a true and correct copy of the Deposition Notice by United States mail, first class, prepaid addressed as follows: Michael S. Ferguson, Esquire Nealon and Gover 2411 North Front Street Harrisburg, PA 17110 David W. Knauer, Esquire Attorney for Plaintiffs ID No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 &InNiI?iK6l4NKbt?fir::9 b'..LL ?•::Jma-, N C w 'Ti ' `, 'per co (? J `j 4J y cD 4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JEREMIAH & JENNIFER STONGE TERM, -VS- CASE NO: 2000-3099 MCKASSON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 02/16/2004 i mcs on beh f ICHr Q Attorney for DE ENDA T DE11-478101 2 4 8 12 - 1, 0 4 COMMONWEALTH OP P E MM S Y LVAN 2 A COUNTY OF, CUMBER LAND IN THE MATTER OF: COURT OF COMMON PLEAS JEREMIAH & JENNIFER STONGE -VS- MCRASSON TERM, CASE NO: 2000-3099 SUBPOENA TO PRODUCE 1D0CU14E2TS AND QUANTUM IMAGING & THERAPEUTIC- MRI FILM ONLY PROGRESSIVE INSURANCE COMPANY INSURANCE TO: DAVID KNAUER, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/26/2004 MCS on behalf of CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUK - MICHAEL FERGUSON, ESQ. _ Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-254006 2 4 8 1 2- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEREMIAH & JENNIFER STONGE -VS- MCKASSON File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 2000-3099 TO: LnsTnnTAN op RFC'nRn4 FOR• QUANTUM IMAGING & THERAPEUTIC-ASSOC INC (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at _ MCS GROUP INC, 1601 MARKET STREET, STE 800 , PHILA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESQ. ADDRESS: 2411 N FRONT 4TRFF HARRISBURG 'PA 17110 TELEPHONE: (215)246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEER'l, DANT FEB 16 2004 DATE: J? ? :29 .2c?2?r Seal of the Court (Eff. 7{97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: QUANTUM IMAGING & THERAPEUTIC- ASSOCIATES, INC. 3508 TRINDLE ROAD CAMP HILL, PA 17011 RE: 24812 JEREMIAH STONGE Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all MRI films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis, consultation, care and/or treatment pertaining to: Dates Requested: up to and including the present. Subject : JERENHAH STONGE 303 ALPAT DRIVE, DILLSBURG, PA 17019 Social Security #: 183-56-7247 Date of Birth: 02-16-1975 SU10-485144 24812-L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JEREMIAH & JENNIFER STONGE TERM, -VS- CASE NO: 2000-3099 MCKASSON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 02/16/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-478102 24812-1,05 A COMMONWEALTH OH P E NN S Y LVAN 2 A COUNTY OP CUMBER LAND IN THE MATTER OF: COURT OF COMMON PLEAS JEREMIAH & JENNIFER STONGE -VS- MCKASSON TERM, CASE NO: 2000-3099 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 QUANTUM IMAGING & THERAPEUTIC- MRI FILM ONLY_ PROGRESSIVE INSURANCE COMPANY INSURANCE TO: DAVID KNAUER, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/26/2004 MCS on behalf of CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUR - MICHAEL FERGUSON, ESQ. _ Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-254006 2 4 8 1 2- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEREMIAH & JENNIFER STONGE -VS- File No. 2000-3099 MCKASSON TO TO: CUSTOLI.IADLOF RECORDS FOR: PROGRESSIVE INSURANCE COMPANY (Name of Person or Entitv) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP -INC, 1601 MARKET STREET, STE 800 PHILA PA 19103 _ (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SU13POENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON ADDRESS: 2411 N- FRONT sTREF.T HARRISBURG PA 17110 TELEPHONE: (215)246-0900 SUPREME COURT ID ATTORNEY FOR: DEFENDANT FEB f 6 2004 DATE: 0?9 ?vay Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PROGRESSIVE INSURANCE COMPANY PO BOX 94625 CLEVELAND, OH 44101 RE: 24812 JEREMIAH STONGE POLICY NO.: 55475402-0. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject: JEREMIAH STONGE 303 ALPAT DRIVE, DILLSBURG, PA 17019 Social Security #: 183-56-7247 Date of Birth: 02-16-1975 Date of Loss: 05/23/1998 24812-LOS SUID-485146 t7 o O s 9 ua r rn m w or - _ "'a ?Fi Crl 4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JEREMIAH & JENNIFER STONGE -VS- MCRASSON TERM, CASE NO: 2000-3099 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 02/16/2004 COURT OF COMMON PLEAS MCS on eh 1?/?? ;,/USON, ESQ. I ICL Attorney for DEF dDANT DE11-478103 2 4 8 1 3- L 06 COMMONWEALTH OP P E XW S Y LVAN 2 A COUNTY OP CUMBER LAND IN THE MATTER OF: COURT OF COMMON PLEAS JEREMIAH & JENNIFER STONGE -VS- MCKASSON TERM, CASE NO: 2000-3099 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCU4ENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 QUANTUM IMAGING & THERAPEUTIC- MRI FILM ONLY PROGRESSIVE INSURANCE COMPANY INSURANCE TO: DAVID KNAUER, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/26/2004 MCS on behalf of CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUK - Any questions regarding this matter, contact MICHAEL FERGUSON, ESQ. _ Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-254007 2 4 8 1 3- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEREMIAH & JENNIFER STONGE -VS- MCKASSON File No. 2000-3099 OR TO: CUSTODIAN OF RECORDS FOR• QUANTUM IMAGING & THERAPEUTIC-ASSOC INC (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC, 1601 MARKET STREET, STE 800 , PHILA PA 19103 _ (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the patty making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON ADDRESS: 2411 N. FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT FEB 1 61004 DATE: ,z) c?Q -02^? Seal of the Court (Eff. 7/97) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: QUANTUM IMAGING & THERAPEUTIC- ASSOCIATES, INC. 3508 TRINDLE ROAD CAMP HILL, PA 17011 RE: 24813 JENNIFER STONGE Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all MRI films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis, consultation, care and/or treatment pertaining to: Dates Requested: up to and including the present. Subject : JENNIFER STONGE 303 ALPAT DR., DILLSBURG, PA 17019 Social Security #: 207-64-9395 Date of Birth: I1-14-1973 SU10-485148 2 4 8 1 3- L® 6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JEREMIAH & JENNIFER STONGE -VS- COURT OF COMMON PLEAS TERM, CASE NO: 2000-3099 MCKASSON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 02/16/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DE11-478104 2 4 8 1 3- L 0 7 COMMONWEALTH O y P E MM S Y LVAN 2A COUNTY OF, CUMBER LAND IN THE MATTER OF: COURT OF COMMON PLEAS JEREMIAH & JENNIFER STONGE -VS- MCKASSON TERM, CASE NO: 2000-3099 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 QUANTUM IMAGING 6 THERAPEUTIC- MRI FILM ONLY PROGRESSIVE INSURANCE COMPANY INSURANCE TO: DAVID KNAUER, ESQ. MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 01/26/2004 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUK - Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-254007 2 4 8 1 3- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEREMIAH & JENNIFER STONGE -VS- File No. goon-3090 MCKASSON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: CUSTODIAN OF RECORDS FOR: PROGRESSIVE INSURANCE COMPANY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: SEE ATTACHED at MCS GROUP INC, 1601 MARKET STREET, STE 800 , PHILA PA 19103 (Address) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena, within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESQ. ADDRESS: 2411 N FRONT ST TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: DEFENDANT FEB `16 2004 DATE: Q 9 r aOC2 y peal of the Court (Eff. 7/9;7) EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PROGRESSIVE INSURANCE COMPANY PO BOX 94625 CLEVELAND, OH 44101 RE: 24813 JENNIFER STONGE POLICY NO.: 55475402-0. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all insurance records and PIP files, including but not limited to medical reports and/or records, claims, any and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : JENNIFER STONGE 303 ALPAT DR., DII.LSBURG, PA 17019 Social Security #: 207-649395 Date of Birth: 11-141973 Date of Loss: 05/23/1998 SUIO-485150 2 4 8 1 3- 1, 0 7 c,9 p y `- t CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JEREMIAH & JENNIFER STONGE TERM, -VS- CASE NO: 2000-3099 MCKASSON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/06/2004 M on eh f EUSON, ESQ. Attorney for DEFENDANT DE11-484207 2481-2-T,06 I C O MM O NW EAL,T H OP P E WX S Y L VAN 2 rL COUNTY or CUMBER LAND IN THE MATTER OF: COURT OF COMMON PLEAS JEREMIAH & JENNIFER STONGE -VS- MCRASSON A SUBPOENA CENTRAL PA MRI MRI FILM ONLY TERM, CASE NO: 2000-3099 TO: DAVID KNAUER, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 03/17/2004 CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUR - 1553110428 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-259523 2 4 8 1 2- C O 2 IF COMMONWEALTH OF'PENNSYLVANIA COUNTY OF CUMBERLAND JFREMIAH & JENNIFER STONGE vs. MCKASSON File No. 2000-3099 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CENTRAL PA MRI (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street Suite 800 Philadelphia PA 19103 _ You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESQ. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: ..3-1'1 -D Seal of the Court BY THE COURT: L.f a tie le, za->? Prothonotary/Clerk, Civil DivisiA D y ?4RO I EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CENTRAL PA MRI 6290 LOWTHARD RD. LOUISBERRY, PA 17339 RE: 24812 JEREMIAH STONGE MRI C-SPINE FROM 5/30/2000 Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all MRI films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis, consultation, care and/or treatment pertaining to: Dates Requested: up to and including the present. Subject : JEREMIAH STONGE 303 ALPAT DRIVE, DILLSBURG, PA 17019 Social Security #: 183-56-7247 Date of Birth: 02-16-1975 SU10-493740 2 4 8 1- 2- 1, 0 6 t ff1.- Y '?r l^i ? ?Z7 t CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: JEREMIAH & JENNIFER STONGE -VS- MCKASSON COURT OF COMMON PLEAS TERM, CASE NO: 2000-3099 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 04/22/2004 S on b ha o ICHAES N, S4. Attorney for DEFENDANT DE11-487759 2 4 8 1 3- 1,O 8 s COMMONWEALTH OF P E NN S Y L VANS-AL COUNT y OF CUMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS JEREMIAH & JENNIFER STONGE -VS- MCKASSON NOTICE OF INTENT THINGS FC HOLY SPIRIT HOSPITAL TO SERVE A MRI FILM ONLY TERM, CASE NO: 2000-3099 TO: DAVID KNAUER, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 04/02/2004 MCS on behalf of MICHAEL FERGUSON, ESQ. _ Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUK - 1553110428 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-261107 2 4 8 1 3- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEREMIAH & JENNIFER STONGE VS. MCKASSON File No. 2000-3099 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 400912 TO: Custodian of Records for HOLY SPIRIT HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc 1601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON_ ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: PZj.2.Ckj 6 W tl y Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil rvisio Deputy 24813-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: HOLY SPIRIT HOSPITAL 503 NORTH 21ST STREET CAMP HILL, PA 17011 RE: 24813 JENNIFER STONGE Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all MRI films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, diagnosis, consultation, care and/or treatment pertaining to: Dates Requested: up to and including the present. Subject: JENNIFER STONGE 303 ALPAT DRIVE, DILLSBURG, PA 17019 Social Security t(: 207-64-9395 Date of Birth: 11-14-1973 SU10-496650 2 4 8 1 3- L 0 8 a CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS JEREMIAH & JENNIFER STONGE TERM, -vs- CASE NO: 2000-3099 MCKASSON As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE:-07/ 14/2004 I AEL FERGU. SQ. Attorney for DEFE ANT -J V DE11-503594 2 4 8 12 -L 0 7 C O M M O NW E A L T H OF P E NN S Y L VAN 2 A COUNTY OF CUMBER LAN D IN THE MATTER OF: JEREMIAH & JENNIFER STONGE -VS- MCKASSON NOTICE OF INTENT TO J THINGS FOR D: MAGNETIC IMAGING CENTER COURT OF COMMON PLEAS TERM, CASE NO: 2000-3099 TO 2 MEDICAL RECORDS & XRAYS TO: DAVID KNAUER, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 06/24/2004 CC: MICHAEL FERGUSON, ESQ. - 03-294 MICHAEL SMOLUR - 1553110428 Any questions regarding this matter, contact MCS on behalf of MICHAEL FERGUSON, ESQ. _ Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-269956 2 4 8 1 2- C O 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEREMIAH & JENNIFER STONGE File No. 2000-3099 VS. MCKASSON SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MAGNETIC IMAGING CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS GmllD Inc 1601 Market Street Suite 800 Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: MICHAEL FERGUSON, ESO. ADDRESS: 2411 N. FRONT ST. HARRISBURG. PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant JUL 1:4 2004 Date: at ,- 17 . 00y Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Divis' /J D ?/Lr4.1 Deputy l 24812-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CENTER 4665 TRINDLE ROAD MECHANICSBURG, PA 17055 RE: 24812 JEREMIAH STONGE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING MRI FILMS Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to an y an d all records, correspondence to an d from the consulting and/or treating physician s, files, memoran da, han dwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including an y an d all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to. Dates Requested: up to and including the present. Subject : JERENHAH STONGE 1 BROOKSIDE CIRCLE, DILLSBURG, PA 17019 Social Security #: 183-56-7247 Date of Birth: 02-16-1975 SU10-509918 2 4 8 1 2- L O 7 { } (? (?? -*7 ? O i i i`' ' C f ?i^ : - 9 1 72 1 . ti. 1 . - {_? r r .may ? C7 n 'C GJ =,: z; ° ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs Vs. Joseph M. McKasson Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 00-3099 JURY TRIAL DEMANDED NOTICE OF DEPOSITION Please be advised that on April 3, 2007, at 5:00 p.m., the Plaintiff will take the deposition of Dr. Robert Beaudry who is located at 3600 Old Gettysburg Road, Camp Hill, Pennsylvania, before a person authorized by law to administer oaths. The oral examination will continue from day to day until completed. You are invited to attend and participate in this examination. Respectfully submitted, Date: March 22, 2007 UER & ASSO IATES, LSC David W. Knauer, Esquire Attorney for the Plaintiff Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. Joseph M. McKasson Defendant No. 00-3099 JURY TRIAL DEMANDED CERTIFICATE OF SERVICE I, David W. Knauer, hereby certify that I did this 22nd day of March, 2007, serve a true and correct copy of the Deposition Notice by United States mail, first class, prepaid addressed as follows: Jenni Henley Allen, Esquire Nealon and Gover 2411 North Front Street Harrisburg, PA 17110 David W. Knauer, Esquire Attorney for Plaintiffs ID No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 -r,, :Imp '. N ?= = to ??'? r 3 AS OF to - a - a.006 CASE# u6o - zagq HAS BEEN SCANNED. ALL EARLIER FILINGS TO THIS CASE HAVE BEEN MICROFILMED. JEREMIAH K. STONGE and JENNIFER L. STONGE, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-3099 V. JOSEPH M. McKASSON and, SUSAN M. McKASSON, Defendants CIVIL ACTION - LAW PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendants, Joseph M. and Susan McKasson with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY Date: O ©('° 6Y: r CV Michael S. Ferguson, Esquire Attorney I.D. No. 83882 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 r Ib CERTIFICATE OF SERVICE AND NOW, this day of October, 2006, 1 hereby certify that I have served the foregoing Praecipe for Withdrawal of Appearance on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: David W. Knauer, Esquire Knauer & Associates, LSC 411A East Main St. Mechanicsburg, PA 17055 ?Michael S. Ferguson, Esquire = Gtt ._- . CAD ? C i i ?= -?- 01 '14 JEREMIAH K. STONGE and JENNIFER L. STONGE, his wife, Plaintiffs V. JOSEPH M. McKASSON and, SUSAN M. McKASSON, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-3099 CIVIL ACTION - LAW PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants, Joseph M. and Susan McKasson with regard to the above-captioned matter. Respectfully submitted, By: Date: Q ( ( (o NEALON GOVER & PERRY A Jrfl ey Allen, Fscc ttorne 1.1-1 No. 84311 2411 N h ront St. Harrisburg, PA 17110 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this ?, 0 day of October, 2006, 1 hereby certify that I have served the foregoing Praecipe for Entry of Appearance on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: David W. Knauer, Esquire Knauer & Associates, LSC 411A East Main St. Mechanicsburg, PA 17055 ;, PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the following case: (Check One) O for JURY trial at the next term of civil court. ( ) for trial without a jury. (CAPTION OF CASE, entire caption must be state in full) (check one) ( X 1 Civil Action - Law ( ) Appeal from Arbitration (other) JEREMIAH K. STONGE JENNIFER L. STONGE, his wife, Vs. JOSEPH M. McKASSON and, SUSAN M. McKASSON, The trial list will be called on March 20, 2007 and Trials commence on Anril 16, 2007 Plaintiff(s) Pretrials will be held on March 28, 2007 (Briefs are due 5 days pretrial.) (The party listing this case for trial shall provide forthwith a copy of the Praecipe to all counsel, pursuant to Local Rule 214.1.) Defendant(s) No.2000-3099 Indicate the attorney who will try case for the party wllo files this Praecipe: Jenni Henley Allen, Esquire Indicate trial counsel for other parties if known: David W. Knatier, >~scluire This case is ready for trial. Date: _ By: -- & PERRY iV AIlen,-Esquif;d A orney I.D. No. 84311 At rney for: Joseph & Susan McKasson 1 North Front Street Harrisburg, PA 17110 (717) 232-9900 C? ? p -ri ?? !?'+''?y?J ...?{?,5 ??'? t, . ?_ ;_a ?.. F? ? ,? ...* JEREMIAH K. STONGE, JENNIFER L. STONGE, HIS WIFE PLAINTIFFS V. JOSEPH M. MCKASSON AND SUSAN M. MCKASSON, DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00-3099 CIVIL LAW JURY TRIAL DEMANDED IN RE: PRE-TRIAL CONFERENCE ORDER OF COURT AND NOW, this 28th day of March, 2007, after pre-trial conference in the above referenced case, IT IS HEREBY ORDERED AND DIRECTED: 1. Trial counsel in this case shall be David W. Knauer for the Plaintiffs and James Nealon for the Defendants. 2. Counsel have indicated that trial will take approximately less than 2 days. 3. Each party will be granted four peremptory challenges. 4. Given the brief nature of the case, the Court has determined that the jurors will not be allowed to take notes. 5. Both parties have been directed to prepare an exhibit list pursuant to the example attached. Two copies of this exhibit list shall be provided to the Court prior to the commencement of trial. All visual aids used in the case shall be disclosed to the opposing party. 6. Counsel for each party is directed to file with the Court on or before 9:00 a.m., April 16, 2007, a list of the numbered standard jury instructions the party is requesting. If a party is proposing a unique jury instruction or requesting significant modification of a standard instruction it shall provide the full text of the proposed instruction to the Court. 7. On or before 9:00 a.m., on April 16, 2007, the parties will provide a proposed verdict slip to the Court for review. 8. It is anticipated that the jury in this case will be picked on April 16, 2007. Accordingly, counsel are attached for trial in this matter. avid W. Knauer, Esquire Attorney for Plaintiffs _mes Nealon, Esquire Attorney for Defendants Court Administrator IX" &AS- bas By the Court, --? ?-4 `s\ M. L. Ebert, Jr. J. c V0 - J ,. n ? o o?? LIN 63 : i Wd 8Z Ow LOU rttii?lC. d 3Hi ?O COMMONWEALTH OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 96-1183 CRIMINAL CHARGE: (1) CRIMINAL HOMICIDE - MURDER OF THE FIRST DEGREE V. (2) CRIMINAL ATTEMPT TO MURDER (3) AGGRAVATED ASSAULT (4) CRIMES COMMITTED WITH FIREARMS (6) FIREARMS NOT TO BE CARRIED WITHOUT A LICENSE ANTYANE ROBINSON AFFIANT: DETECTIVE RONALD EGOLF COMMONWEALTH'S EXHIBIT LIST EXHIBIT NUMBER DESCRIPTION 1 Photograph of injury to Tara Hodge's head 2 Used envelope bearing handwriting of Tara Hodge 3 Photograph of the front of building at 117-119 West Louther Street 4 Exterior side view of Tara Hodge's apartment 5 Photograph of body of Rashawn Bass in shower 6 Closeup photograph of Rashawn Bass with bullet casing on shoulder 7 Diagram of Tara Hodge's apartment 8 Plastic shower enclosure from Tara Hodge's apartment 9 Address book of Tara Hodge 10 Date book of Tara Hodge David W. Knauer, Esquire Attorney I.D. No. 21582 Knauer & Associates, L.S.C. 411-A E. Main Street Mechanicsburg, PA 17055 Knauer@early.com 717-795-7790 717-795-7793 Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeremiah K. Stonge and his wife Jennifer L. Stonge Plaintiffs COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. Joseph M. McKasson Defendant No. 00-3099 JURY TRIAL DEMANDED PRAECIPE TO MARK DOCKET SETTLED, ENDED AND DISCONTINUED TO THE PROTHONOTARY: Please mark the docket in the above named matter settled, ended and discontinued. ally submitted, & ASSOCIATES, L.S.C. Date: April 23, 2007 David W. Knauer, Esquire Attorney for Defendant Attorney I.D. No. 21582 411-A East Main Street Mechanicsburg, PA 17055 (717) 795-7790 Q fl ?j ELY i