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HomeMy WebLinkAbout02-5675 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUSAN SHELBURNE v, [Jd -5~75 ~ CRAIG ANDRUS NOTICE TO DEFEND 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 also lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 19751_1 NOTICIA Le han demandado a usted en la corte. Si usted qui ere def endorse de estas demandas expuestas en las paginas siquientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forroa escrita sus defensas 0 sus objeciones alas deroandas 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 pervio aviso 0 notification y por cualquier queja 0 alivio que es pedido en la peticion do demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importanates para usted. LLEVE ESTA DEMANDA A UN ABODAGO 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 ESCRIT A ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 2 1975U COMPLAINT Comes the plaintiff, Susan Shelburne, and sets for the following: 1. Plaintiff is Susan Shelburne of 5546 Moreland Court, Mechanicsburg, P A 17055. 2. Defendant is Craig Andrus of 5169 E. Trindle Road, Lot #3, Mechanicsburg, P A 17055. 3. The facts and occurrence hereinafter related took place on or about November 29, 2000 on Main Street in Mechanicsburg, P A. 4. At that time and place, Plaintiff Shelburne was operating her motor vehicle by proceeding eastward on Main Street. Shelburne was proceeding with due caution. 5. Defendant Andrus was also proceeding eastward on Main Street, driving his 1994 GMC Truck. 6. At that time the Andrus vehicle while proceeding too quickly for conditions approached the Shelburne vehicle from the rear and collided with it violently. 7. The foregoing accident and all the injuries and damages set forth hereinafter sustained by Shelburne are the direct and proximate cause of the negligent careless wanton and reckless manner in which the Defendant Andrus operated his motor vehicle as follows: a. Failure to have his vehicle under such control as to be able to stop within the assured clear distance ahead. b. Failure to keep alert and maintain a proper watch for the presence of other motor vehicles on the highway. c. Failure to apply his brakes in sufficient time to avoid striking the rear of Plaintiffs vehicle. d. Failure to travel at safe speed. 3 19751_1 e. Failure to keep a proper watch for traffic on highway. f. Failure to drive his vehicle with due regard for the highway and traffic condition which are existing and of which he was or should have been aware. g. Failure to keep proper and adequate control over his vehicle. h. Plaintiff Shelburne sustained painful and severe injuries which include but are not limited to serious back and neck injuries requiring a spinal fusion operation in February of 2002. 1. By reason of the aforesaid injuries sustained by the Plaintiff, she was forced to incur liability for medical treatment, medications, hospitalizations and similar miscellaneous expenses in an effort to restore himself to health and claim is made therefor. J. Because of the nature of his expenses, Plaintiff Shelburne has been advised and, therefore, avers that she may be forced to incur similar expenses in the future and claim is made therefor. k. As a result of the aforementioned injuries, Plaintiff has undergone and in the future will undergo great physical and mental suffering, great inconvenience in carrying out his daily activities, loss oflife's pleasures and enjoyment and claim is made therefor. 1. As a result of the aforesaid injuries, Plaintiff Shelburne has been and in the future will be subject to great humiliation and embarrassment and claim is made therefor. m. As the result of the aforesaid injuries, Plaintiff has sustained work loss, loss of opportunity and permanent diminution of his earning power and capacity and claim is made therefor. 19751_1 4 n. As the result of the aforesaid injuries, Plaintiff has sustained uncompensated work loss and claim is made therefor. o. Plaintiff continues to be plagued by persistent pain and limitation and, therefore, avers that his injuries are of a permanent nature causing residual problems for the remainder of her life and claim is made therefore. WHEREFORE, Plaintiff demands judgment against Defendant in an amount in excess of $30,000 exclusive of interest and costs and in excess of jurisdictional amount requiring compulsory arbitration, Respectfully submitted, (( /7_Sl:z Date ( / )bsep . etz lHi. No. 2958 ~____ 305 N. Front Street, Suite 403 Harrisburg,PA 17101 (717) 236-4812 Attorney for Plaintiff Shelburne 1975U 5 \~ o } ~ ~ '0 Cz ~ '^ '" ~\ ,\ (j , &> ~~~ \~\ 1 ~~ ~~ l ~ (") f,; rJ C) "T.J t';'- ~;'"P ,'j ~lr.'. ~,;;' l_ ()5";' ;;: ~--- :::-- '.,co. --'c':- ~; c- .' ~ '0,:0'/1 '-..) (Y', 1--'1 ,") " ~) .;; ,..'.0 (') <._')nl "" "-.I :is -< ),,," _!;: SHERIFF'S RETURN - REGULAR CASE NO: 2002-05675 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SHELBURNE SUSAN VS ANDRUS CRAI G KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ANDRUS CRAIG the DEFENDANT , at 1940:00 HOURS, on the 5th day of December, 2002 at 27 E LOCUST STREET MECHANICSBURG, PA 17055 by handing to CRAIG ANDRUS a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 6.90 .00 10.00 .00 34.90 .?=,::>:{:~. R. Thomas Kline ,~-~ )'~ .'>'~.J .............t' 12/09/2002 JOSEPH METZ me this Iff:- day of Sworn and Subscribed to before By: i-J.e.~L _ LinJ ;C A. D . \ ~Uf" -0 ~A.fi?;~ $f- Prothonotary' SUSAN SHELBURNE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5675 CRAIG ANDRUS, Defendant JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Craig Andrus, with regard to the above-captioned matter, Respectfully submitted, NEALON & GOVER, P .C. Date: /1/2d/1 L- By: B~~J~~ire Attorney I.D, No. 84188 2411 North Front St. Harrisburg, PA '17110 (717) 232-9900 CERTIFICATE OF SERVICE AND NOW, this 20th day of December, 2002, I 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: Joseph Metz, Esquire Dilworth Paxson, LLP 305 N. Front St., Suite 403 Harrisburg, PA 17101 ~o.~. Bria ,Sinne, EsqUire 0 C'" 0 -, C f"-\ '""1"1 ..",. CJ ~l._ ~1 t.~L '1 rT', n ..'") --- ~._-- i~ :',..) /'" ~:} c;. . , ~. " -r' I.-~ ----~ { "'- "T ~:' C ~...,) C,'-- :J,J ",-_. ') :;~ (r. :'l}. ~- SUSAN SHELBURNE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5675 CRAIG ANDRUS, Defendant JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Susan Shelburne c/o Joseph Metz, Esquire Dilworth Paxson, LLP 305 N. Front St., Suite 403 Harrisburg, PA 17101 YOU ARE HEREBY NOTIFIED to file a response to the enclosed New Matter within twenty (20) days of service hereof. Failure by you to do so may constitute an admission. Respectfully submitted, NEALON & GOVER, P.C. Date: / / 2tJ~ '3 By: ~K~~ Brian R. nett, Esquire Attorney I.D, No, 84188 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 SUSAN SHELBURNE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5675 CRAIG ANDRUS, Defendant JURY TRIAL DEMANDED DEFENDANT'S ANSWER WITH NEW MATTER TO PLAINTIFF'S COMPLAINT AND NOW, comes the Defendant, Craig S. Andrus, by and through his attorneys, Nealon & Gover, P,C" and files the following Answer to Plaintiff's Complaint with New Matter: 1, Admitted, based on information and belief. 2, Admitted in part, denied in part, By way of further answer, the Defendant's address is 27 East Locust Street, Mechanicsburg, PA 17055, 3, Admitted, 4, Admitted in part, denied in part, It is admitted that the Plaintiff was operating her vehicle by proceeding eastward on Main Street. After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining matters asserted and strict proof of same is demanded at trial. Any remaining averments are denied pursuant to Pa.R.C,P, 1029(e), 5. Admitted, 6, Denied as stated. By way of further answer, it is admitted that the vehicle being driven by the Defendant came in contact with the vehicle being operated by the Plaintiff, All the remaining averments are denied pursuant to Pa,R.C,P, 1029(e), 7, Denied, After reasonable investigation, the Defendant is without knowledge or information sufficient to form a belief as to the truth of the matters asserted and strict proof of same is demanded at trial. Any remaining averments are denied pursuant to Pa,R.C,P, 1029(e). WHEREFORE, Defendant, Craig S, Andrus, respectfully requests that the Complaint filed against him be dismissed with the cost of this action, NEW MATTER 8, Paragraphs 1 through 7 of Defendant's Answer are incorporated herein by reference thereto. 9, The Plaintiffs' complaints are barred in whole or in part by application of the Pennsylvania Motor Vehicle Financial Responsibility Act. WHEREFORE, Defendant, Craig S, Andrus, respectfully requests that the Complaint filed against him be dismissed with the cost of this action, Respectfully submitted, NEALON & GOVER, P.C. By: ~If~ Brian R. Sinnett, Esquire Attorney 1.0, No, 84188 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 Date: I! ?pIc; 3 VERIFICATION I, Craig S, Andrus, verify that the statements made in the foregoing Answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C,S,A. 94904 relating to unsworn falsification to authorities. Date: ///3/0] d~~~ crai~rus CERTIFICATE OF SERVICE AND NOW, this .tth day of January, 2003, I hereby certify that I have served the foregoing Answer with New Matter on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Joseph Metz, Esquire Dilworth Paxson, LLP 305 N. Front St., Suite 403 Harrisburg, PA 17101 :?,~ Brian R. S n , Esquire (") ~ '"'Om rnp1 ~-""-1 __...A...., ~5; -<~"... ~CJ ~8 ~c: z =< c w Co.- :r:.- Z N N -0 :J:: ~ :.n o -;1 ...{ ~:r t1 !llp ;,~ FiJ ':::jc, "'\-""""ra .,.. ...,., 90 ~m ~ ~ v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5675 SUSAN SHELBURNE, Plaintiff CRAIG ANDRUS, Defendant JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Craig Andrus, with regard to the above-captioned matter. Respectfully submitted, NEALON & GOVER, P.C. Date: Iz...(a (07 By ~~~q";rn Attorney 1.0. No. 83882 2411 North Front 51. Harrisburg, PA 17110 (717) 232-9900 ~ CERTIFICATE OF SERVICE AND NOW, this ~ day of December, 2003, I 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: Joseph Metz, Esquire Dilworth Paxson, LLP 305 N. Front St., Suite 403 Harrisburg, PA 17101 1!~~~U~ESqUire C) ,-- "- .;c., "" C:-:J C.::-J <~ o f' C) -jj -I -f- illi:! ()f"n -;,C-J ?:)r\ ";:1>' 1')/ ,~~, . '., '--: CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS 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: 08/16/2004 MCS on behal~ r ~ ~~USON~\'-"f Attorney for DEFENDANT DEll-510962 60252 - L 01 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO Rill,E 4009,21 [ Note: see enclosed list of locations] TO: JOSEPH U. METZ, 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: 07/26/2004 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. PATRICK FALLER - 02-579 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273685 60252 - CO 2 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED YORK HOSPITAL YORK HOSPITAL CARLISLE HOSPITAL CARLISLE HOSPITAL THE HETRICK CENTER HEALTH SOUTH HOSP/SPEC. SERVICE NEUROLOGY CENTER, INC. BRUCE BAILEY, M.D. PINNACLE HEALTH AT HARRISBURG MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS & XII1AYS DE02-273685 602S2-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN SHELBURNE FileNo. 02-5675 vs. CRAIG ANDRUSI SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for YORK 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 GrOllP Inc 160] Market Street Suite ROO Phi]ade]nhia PA ]9103 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 lihe 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: ADDRESS: MICHAEL FERGUSON. ESO. 24] I N FRONT ST, HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Pro Date: ..... t Ly -< ~ I ::UYSr Deputy Sea] of the Court 60252-01 EXPLANATION OF REQUIRED RI~CORDS TO: CUSTODIAN OF RECORDS FOR: YORK HOSPITAL 100l SOUTH GEORGE STREET YORK, PA 17403 RE: 60252 SUSAN SHELBURNE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and./or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relatin~ to any examination, consultation, diagnosis, care, treatment, admiSSIOn, discharge, or emergency care pertaining to: Dates Requested: up to and including the present, Subject: SUSAN SHELBURNE 5546 MORELAND COURT, MECHANICSBURG, PA 17055 Social Security #: 379-50-0097 Date of Birth: 09-04-1949 SUlO-515576 60252 -LO]" CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS 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: 08/16/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DEll-510963 60252 - L 02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO Rill.E 4009.21 [ Note: see enclosed list of locations] TO: JOSEPH U. METZ, 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 twent.y 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: 07/26/2004 KCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. PATRICK FALLER - 02-579 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273685602S2-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED YORK HOSPITAL YORK HOSPITAL CARLISLE HOSPITAL CARLISLE HOSPITAL THE HETRICK CENTER HEALTHSOUTH HOSP/SPEC. SERVICE NEUROLOGY CENTER, INC. BRUCE BAILEY, M.D. PINNACLE HEALTH AT HARRISBURG MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS " XIlAYS MEDICAL RECORDS " XIlAYS MEDICAL RECORDS " XIlAYS MEDICAL RECORDS " XRAYS MEDICAL RECORDS " XIlAYS DE02-273685 60252 - C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN SHELBURNE FileNo. 02-5675 vs. CRAIG ANDRUSI SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009,22 TO: Custodian of Records for YORK HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by th(: court to produce the following documents or things: **** SEE A TT ACHED RIDER **** at TheMCSGroun Ine ]60] MarketS!reet Suite ROO Philadelphia PA ]9103 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 ]he 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: ADDRESS: MICHAEL FERGUSON. ESO. 241] N FRONT ST HARRISBURG PA ]71]0 TELEPHONE: (2]5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY ~)URT: Pro onotaryl r Date: Ju.L'{ ..<~ :IN\'1 I Deputy Seal of the Court 60252-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: YORK HOSPITAL 1001 SOUTH GEORGE STREET YORK, PA 17403 RE: 60252 SUSAN SHELBURNE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, 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: SUSAN SHELBURNE 5546 MORELAND COURT, MECHANICSBURG, PA 17055 Social Security #: 379-50-0097 Date of Birth: 09-04-1949 SU10-51557860252-L02 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of MICHAEL FERGUSON, ESI~. 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: 08/16/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DEll-510964 60252 -LO 3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RUL.E 4009.21 [ Note: see enclosed list of locations ]1 TO: JOSEPH U. METZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intenrul 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: 07/26/2004 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. PATRICK FALLER - 02-579 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273685 602S2-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED YORK HOSPITAL YORK HOSPITAL CARLISLE HOSPITAL CARLISLE HOSPITAL THE HETRICK CENTER HEALTHSOUTH HOSP/SPEC. SERVICE NEUROLOGY CENTER, INC. BRUCE BAILEY, M.D. PINNACLE HEALTH AT HARRISBURG MEDICAL RECORDS K-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS & XF~YS MEDICAL RECORDS & XF~YS MEDICAL RECORDS & XF~YS MEDICAL RECORDS & XF~YS MEDICAL RECORDS & XF~YS DE02-273685 60252 - C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN SHELBURNE FileNo. 02-5675 vs. CRAIG ANDRUSI SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by tho: court to produce the following documents or things: .... SEE A TT ACHED RIDER .... at The MCS Groun Ine ]601 Market Street Suite 800 Philadelnhia 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: ADDRESS: MICHAEL FERGUSON. ESO. 2411 N FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY f1~URT: Pro onotar Date: ...J{~ iy ..{~, ),{'f~ Deputy Seal of the Court 60252-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL 274 WILSON STREET CARLISLE, PA 17013 RE: 60252 SUSAN SHELBURNE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physician, files, memoranda, handwritten notes, history and physical reports, medication! prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, test, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present, Subject: SUSAN SHELBURNE 5546 MORELAND COURT, MECHANICSBURG, PA 17055 Social Security #: 379-50-0097 Date of Birth: 09-04-1949 SUI0-515580 60252-L03 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS 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: 08/16/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DEll-510965 60252 - L 04 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RU1.B 4009.21 [ Note: see enclosed list of locations :I TO: JOSEPH U. METZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intenrn; to serve a subpoena identical to the one that is attacbed to this notice. You have twenty (20) days from the date listed below in which to file of re'~ord 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 m,ay be served. Complete copies of any reproduced recorda 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: 07/26/2004 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. PATRICK FALLER - 02-579 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DECl2-273685 602S2-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED YORK HOSPITAL YORK HOSPITAL CARLISLE HOSPITAL CARLISLE HOSPITAL THE HETRICK CENTER HEALTHSOUTH HOSP/SPEC. SERVICE NEUROLOGY CENTER, INC. BRUCE BAILEY, M.D. PINNACLE HEALTH AT HARRISBURG MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS 6< XIlAYS MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS 6< XRAYS DECl2-273685602S2-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN SHELBURNE FileNo. 02-5675 vs. CRAIG ANDRUSI SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARJ.ISLE HOSPITAL (Name of Person or Entity) Within twenty (20) days after service ofthis subpoena, you are ordered by the court to produce the following documents or things: **** SEE A TT ACHED RIDER **** at The MCS Group Ine 1601 Market Street Suite 800 Philadelphia PA 19]103 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 FOLLOWJNG PERSON: NAME: ADDRESS: MICHAEL FERGUSON. ESO. 2411 N. FRONT ST. HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Pr Date: .Ju.L oJ.;). ~0^'1 I 1- Seal of the Court Deputy 60252-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL 274 WILSON STREET CARLISLE, PA 17013 RE: 60252 SUSAN SHELBURNE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, 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: SUSAN SHELBURNE 5546 MORELAND COURT, MECHANICSBURG, PA 17055 Social Security #: 379-50-0097 Date of Birth: 09-04-1949 SUIO-51558260252-L04 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS 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 ~ertificate, (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: OS/16/t004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DEll-510966 60252 -LO 5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RUIoB 4009.21 [ Note: see enclosed list of locations] TO: JOSEPH U. METZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intenrn; to serve a subpoena identical to the one that is attached to this notice. You have twenty (201 days from the date listed below in which to file of rel~ord and serve upon the undersigned an objection to the subpoena. If the twenty may notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced recorda 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: 07/26/2004 II<ICS on behalf of II<IICHAEL FERGUSON, ESQ. .lI.ttorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. PATRICK FALLER - 02-579 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273685 602S2-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED YORK HOSPITAL YORK HOSPITAL CARLISLE HOSPITAL CARLISLE HOSPITAL THE HETRICK CENTER HEALTH SOUTH HOSP/SPEC. SERVICE NEUROLOGY CENTER, INC. BRUCE BAILEY, M.D. PINNACLE HEALTH AT HARRISBURG MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS 6< XlRAYS MEDICAL RECORDS 6< XIRAYS MEDICAL RECORDS 6< XIRAYS MEDICAL RECORDS 6< XIRAYS MEDICAL RECORDS 6< HAYS DE02-273685 602S2-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN SHELBURNE FileNo. 02-5675 vs. CRAIG ANDRUSI SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for THE HETRICK 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 A TT ACHED RIDER **** at TheMCSGroup Ine 1601 Market Street Suite 800 Philadelphia PA 19]03 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 FOLLOW1NG PERSON: NAME: ADDRESS: MICHAEL FERGUSON. ESO. 2411 N FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant vii Di . sion Date: .. )(~ ly 2;)... ::J~'1 Seal of the Court Deputy 60252-05 EXPLANATION OF REQUIRED Rl~CORDS TO: CUSTODIAN OF RECORDS FOR: THE HETRICK CENTER 500 NORTH UNION STREET MIDDLETOWN, PA 17057 RE: 60252 SUSAN SHELBURNE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. 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 any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: SUSAN SHELBURNE 5546 MORELAND COURT, MECHANICSBURG, PA 17055 Social Security #: 379-50-0097 Date of Birth: 09-04-1949 SUI0-515584602S2-LOS CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS 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: OS/16/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DEll-510967 60252 -LO 6 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02 -5675 CRAIG ANDRUS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RilloB 4009.21 [ Note: see enclosed list of locations :I TO: JOSEPH U. METZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intenrn; 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 m;ay 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: 07/26/2004 MCS on behalf of MICHAEL FERGUSON, ESQ. ~ttorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. PATRICK FALLER - 02-579 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 8800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273685602S2-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED YORK HOSPITAL YORK HOSPITAL CARLISLE HOSPITAL CARLISLE HOSPITAL THE HETRICK CENTER HEALTH SOUTH HOSP/SPEC. SERVICE NEUROLOGY CENTER, INC. BRUCE BAILEY, M.D. PINNACLE HEALTH AT HARRISBURG MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS 6< XIIAYS MEDICAL RECORDS & XIIAYS DE02-273685 60252 - C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN SHELBURNE FileNo. 02-5675 vs. CRAIG ANDRUSI SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULli: 4009.22 TO: Custodian of Records for HEALTHSOUTH HOSP/SPEC SERVICE (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 A TT ACHED RIDER **** at TheMCSGroun Ine 1601 Market Street Suite 800 Philadelnhia 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 Ihe 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: ADDRESS: MICHAEL FERGUSON. ESO. 2411 N. FRONT ST HARRISBURG PA 17110 TELEPHONE: (2] 5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY T~)URT: Proth not~y! Date: ~/.I .l~ .J~I 'J.(X'>r Deputy Seal of the Court 60252-06 EXPLANATION OF REQUIRED RlCCORDS TO: CUSTODIAN OF RECORDS FOR: HEALTHSOUTH HOSP/SPEC. SERVICE 4950 WILSON LANE MECHANICSBURG, PA 17055 RE: 60252 SUSAN SHELBURNE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. 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 any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: SUSAN SHELBURNE 5546 MORELAND COURT, MECHANICSBURG, PA 17055 Social Security #: 379-50-0097 Date of Birth: 09-04-1949 SUI0-S15586602S2-L06 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -vs- CASE NO: 02-5675 CRAIG ANDRUS AS a prerequisite to service of a subpoena for do~uments 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 atta~hed thereto was mailed or delivered to each party at least twenty days prior to the date on whi~h 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: 08/16/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DEll-510968 60252 -LO 7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -vs- CASE NO: 02-5675 CRAIG ANDRUS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PURSUANT TO RUI.B 4009.21 [ Note: see enclosed list of locations] TO: JOSEPH U. METZ, 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 mate listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twent.y may 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: 07/26/2004 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. PATRICK FALLER - 02-579 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273685 602S2-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED YORK HOSPITAL YORK HOSPITAL CARLISLE HOSPITAL CARLISLE HOSPITAL THE HETRICK CENTER HEALTHSOUTH HOSP/SPEC. SERVICE NEUROLOGY CENTER, INC. BRUCE BAILEY, M.D. PINNACLE HEALTH AT HARRISBURG MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS 6< XllAYS MEDICAL RECORDS 6< XllAYS MEDICAL RECORDS 6< XllAYS MEDICAL RECORDS 6< XllAYS MEDICAL RECORDS 6< XllAYS DECl2-273685 60252 - C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN SHELBURNE FileNo. 02-5675 vs. CRAIG ANDRUSI SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for NET TROT .OGY CENTER. INC. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by thl~ court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Groun Ine ]601 Market Street Suite 800 Philadelnhia 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 FOLLOWlNG PERSON: NAME: ADDRESS: MICHAEL FERGUSON. ESO. 2411 N. FRONT ST HARRISBURG PA 171 lO TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Pr Date: .... )1.1 Ly ~, ;1(Y~ Seal of the Court Deputy 60252-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: NEUROLOGY CENTER, INC. 897 POPLAR CHURCH RD. SUITE 107 CAMP HILL, PA 17011 RE: 60252 SUSAN SHELBURNE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. 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 any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic fOIm, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: SUSAN SHELBURNE 5546 MORELAND COURT, MECHANICSBURG, PA 17055 Social Security #: 379-50-0097 Date of Birth: 09-04-1949 SUIO-51558860252-L07 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS 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, in~luding 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: 08/16/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DEll-510969 60252 - L 08 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -vs- CASE NO: 02-5675 CRAIG ANDRUS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMENTS AND THINGS FOR DISCOVERY PURSUANT TO RU10B 4009.21 [ Note: see enclosed list of locations :I TO: JOSEPH U. METZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intenrn; to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the mate listed below in which to file of rel~ord 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 recorda 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: 07/26/2004 :MCS on behalf of MICHAEL FERGUSON, ESQ. .!\.ttorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. PATRICK FALLER - 02-579 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273685 602S2-C02 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED YORK HOSPITAL YORK HOSPITAL CARLISLE HOSPITAL CARLISLE HOSPITAL THE HETRICK CENTER HEALTH SOUTH HOSP/SPEC. SERVICE NEUROLOGY CENTER, INC. BRUCE BAILEY, M.D. PINNACLE HEALTH AT HARRISBURG MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS 6< XII1AYS MEDICAL RECORDS 6< HAYS DECl2-273685 60252 - C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN SHELBURNE FileNo. 02-5675 vs. CRAIG ANDRUSI SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BRUCE BAILEY. M D (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 A TT ACHED RIDER **** at The MCS Groun Ine 1601 Market Street Suite 800 Philadelnhia P A 19101 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 FOLLOW1NG PERSON: NAME: ADDRESS: MICHAEL FERGUSON. ESO. 2411 N. FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY P:)URT: Pro onotaryl ision Date: \. 1, Lc ~I ~1 Seal of the Court Deputy 60252-08 EXPLANATION OF REQUIRED RI~CORDS TO: CUSTODIAN OF RECORDS FOR: BRUCE BAILEY, M.D. 850 WALNUT BOTTOM ROAD SUITE C-8 CARLISLE, PA 17013 RE: 60252 SUSAN SHELBURNE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. 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 any and all records, correspondence to and from the consulting and/or treating physicians, fIles, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: SUSAN SHELBURNE 5546 MORELAND COURT, MECHANICSBURG, PA 17055 Social Security #: 379-50-0097 Date of Birth: 09-04-1949 SUIO-515590 60252-L08 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS As a prerequisite to service of a subpoena for do~uments 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 re~eived, 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: 08/16/2004 MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT DEll-510970 60252 - LO 9 ~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RU10B 4009.21 [ Note: see enclosed list of locations :I TO: JOSEPH U. METZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intenrn3 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 recorda 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: 07/26/2004 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. PATRICK FALLER - 02 -579 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-273685 602S2-C02 . >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED YORK HOSPITAL YORK HOSPITAL CARLISLE HOSPITAL CARLISLE HOSPITAL THE HETRICK CENTER HEALTHSOUTH HOSP/SPEC. SERVICE NEUROLOGY CENTER, INC. BRUCE BAILEY, M.D. PINNACLE HEALTH AT HARRISBURG MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS X-RAY ONLY MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS & XRAYS MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS 6< XRAYS DE0<2-273685 602S2-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN SHELBURNE FileNo. 02-5675 vs. CRAIG ANDRUSI SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PINNACLE HEALTH AT HARRISBURG (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by thl~ court to produce the following documents or things: **** SEE A TT ACHED RIDER **** at The MCS Group Ine 1601 Market Street Suite 800 Philadelnhia 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 FOLLOW1NG PERSON: NAME: ADDRESS: MICHAEL FERGUSON. ESO. 2411 N FRONT ST HARRISBURG. PA 171 ]0 TELEPHONE: (215) 246.0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Pr , Civil ivision Date: '- t l'( :2:21 ").(x1 Seal of the Court Deputy 60252-09 EXPLANATION OF REQUIRED Rl~CORDS TO: CUSTODIAN OF RECORDS FOR: PINNACLE HEALTH AT HARRISBURG HOSPITAL 111 SOUTH FRONT ST HARRISBURG, PA 17101 RE: 60252 SUSAN SHELBURNE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. 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 any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: SUSAN SHELBURNE 5546 MORELAND COURT, MECHANICSBURG, PA 17055 Social Security #: 379-50-0097 Date of Birth: 09-04-1949 SUlO-51559260252-L09 CERTIFICATE PREREQUISITE TO SERVICE OF A SUB,POENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS 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: OS/24/2004 ~~,o~ je]:'f}Jfof JI~~i1wg~ON Attorney I:or DE DEll-512927 60252 - L J. 0 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02 -5675 CRAIG ANDRUS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 PA SPINE INSTITUTE MAGNETIC IMAGING CENTER MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS 6< XRAYS TO: JOSEPH U. METZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intemls 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 r,ecord 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 Illay be served. Complete copies of any reproduced recorda 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: OS/04/2004 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. PATRICIA FALLER - 02-579 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #SOO PHILADELPHIA, PA 19103 (215) 246-0900 DE02-274672 602S2-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN SHELBURNE FileNo. 02-5675 vs. CRAIG ANDRUS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for PA SPINE INSTITIJTE (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 GrOll" Toe 1601 Market Street Suite ROO Phlladelnhia FA 19101 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 addlress 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: ADDRESS: MICHAEL FERGUSON. ESO. 2411 N FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant B~)URT: Fa. Date: (i AUG 2 4 2004 W U4it ~ a. Wr+ al of the Court 60252-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: PA SPINE INSTITUTE 805 SIR THOMAS COURT PO BOX 6507 HARRISBURG, PA 17109 RE: 60252 SUSAN SHELBURNE Prior approval is required 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 any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: SUSAN SHELBURNE 5546 MORELAND COURT, MECHANICSBURG, PA 17055 Social Security #: 379-50-0097 Date of Birth: 09-04-1949 SUlO-517580 602S2-L~O CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS 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 certifi~ate, (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: 08/24/2004 MICHAEL !'ERGUSON, ESQ. Attorney for DEFENDANT DEll-512928602S2-Lll COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RUJ[d!: 4009.21 PA SPINE INSTITUTE MAGNETIC IMAGING CENTER MEDICAL RECORDS 6< XRAYS MEDICAL RECORDS & XRAYS TO: JOSEPH U. METZ, ESQ., PLAINTIFF COUNSEL MCS on behalf of MICHAEL FERGUSON, ESQ. intend~ 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 recorda 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: OS/04/2004 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. PATRICIA FALLER - 02-579 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-274672 60252 -CO 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN SHELBURNE FileNo. 02-5675 vs. CRAIG ANDRUS 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 A IT ACHED RIDER **** at The MCS Grnun Ine 1601 Market Street Suite 800 Philadelnhia PA ]9103 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 wilhin 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: ADDRESS: MICHAEL FERGUSON. ESO. 2411 N FRONT ST HARRISBURG PA 17110 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant ~ AUG 2 4 2004 Date:u~wL ..z ~O(3f al of the Court BlJHE COURT: ~t ProthonotaIy/Clerk, J~ 60252-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MAGNETIC IMAGING CENTER 4665 TRINDLE ROAD MECHANICSBURG, PA 17055 RE: 60252 SUSAN SHELBURNE Prior approval is required 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 any and all records, correspondence to and from the consulting and/or treating physicians, flies, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray fIlms and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject: SUSAN SHELBURNE 5546 MORELAND COURT, MECHANICSBURG, PA 17055 Social Security #: 379-50-0097 Date of Birth: 09-04-1949 SUI0-517582 60252 -Lll (") ..., 0 = c "" .." J:" ;;::: - ~~ ~m c::: . ( f~ ::z :',~j C"> ~C; N ~~ ~~: -..I 0 '< " ~-ii :l:"C> ::J: '-~ ~~ - 5 - i ~ C> 0 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SUSAN SHELBURNE COURT OF COMMON PLEAS TERM, -VS- CRAIG ANDRUS CASE NO: 02-5675 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 obj ection 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. c:: DATE: OS/23/2004 I ^ DEl1-512643 60796-L~3 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SUSAN SHELBURNE TERM, -VS- CASE NO: 02-5675 CRAIG ANDRUS NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCOMBNTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 STATE FARM INSURANCE INSURANCE TO: JOSEPH U. METZ, 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 recorda may be ordered at YlOur expense by completing the attached counsel card and returning same to MCS lOr by contacting our local MCS office. DATE: OS/03/2004 MCS on behalf of MICHAEL FERGUSON, ESQ. Attorney for DEFENDANT CC: MICHAEL FERGUSON, ESQ. PATRICIA FALLER - 02-579 Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #SOD PHILADELPHIA, PA 19103 (215) 246-0900 DE02-27455260796-C02 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SUSAN SHELBURNE FileNo. 02-5675 vs. CRAIG ANDRUS SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for STATE FARM INSURANCE (Name of Person or Entity) Within twenty (20) days after service ofthis subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Ine 160] Market Street Suite 800 Philadelnhia PA 19101 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: ADDRESS: MICHAEL FERGUSON. ESO. 24]] N FRONT ST HARRISBURG PA 17]] 0 TELEPHONE: (2] 5) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: .- :: -. ='""S4 .JJ'f ;;;)9 , ~ B(J;;:OUR~: Prothonotary/Clerk, Civil Divis' ~~ eputy Seal of the Court 60796-13 EXPLANA TlON OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: STATE FARM INSURANCE ONE STATE FARM DRIVE P.O. BOX 41 CONCORDVILLE, PA 19339 RE: 60796 SUSAN SHELBURNE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. 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. Snbject : SUSAN SHELBURNE 5546 MORELAND COURT, MECHANICSBURG, JM 17055 Social Security #: 379-50-0097 Date of Birth: 09-04-1949 Date of Loss: 11/29/2000 SUlD-517286 60796 -L13 (") ,..., ~ = c "'" ;."" .s:- ri? ~~) ". ..-\ c: ff..Fl ::=...'. ,,-, /' <..) ~,~ ~l'!~~ c::> ~C) ~=B -- -c y'~ B ';?.:~-...< ::JI,: c::::-"- ::S["'n pc~ <t? .-1 ~ ...,. ~ -II PRAECIPE FOR liSTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: :Ea for JURY trial at the next term of civil court. -0 for trial without a jury, CAPTION OF CASE (endre caption must be stated in full) ----------------------------------------------------------------------------------------------------------- SUSAN SHELBURNE, (check one) tiC] Civil Action - Law o Appeal from arbitration o (other) (plaintiff) vs. The trial Ust will be called on 1 /9/07 and CRAIG ANDRUS, Trials commence on 2 /5 /07 vs. (Defendant) Pretrials will be held on 1 /1 7 / n 7 (Briefs are due 5 days before pretrials No. 02:-5675 Tenn Indicate the attorney who will try case for the party who tiles this praecipe: Jenni Henley Allen Indicate trial counsel for other parties if known: This case is ready for trial. Signed: Allen Print Name: Date: 10/16/06 Attorney for: Defendant -- CERTIFICATE OF SERVICE AND NOW, this J 0 ~ day of October, 2006, I hereby certify that I have served the foregoing Praecipe for Listing Case for Trial on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Joseph Metz, Esquire Dilworth Paxson, LLP 112 Market Street, 8th Floor Harrisburg, PA 17101 ~. ?;:. '"'t}OJ mS:i ~t. Cl.?",-; ::':::..., C2'" ~<: .--'u ):>> c: Z ::2 ,...:) g a' o ~ - CD -0 :x. w .. .r:- \D ~ ~:!J -of;; -nC? {~~ :1: -n 00 .7 tT1 9 ~ ,. . . SUSAN SHELBURNE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5675 CRAIG ANDRUS, Defendant JURY TRIAL DEMANDED PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the undersigned's appearance on behalf of the Defendant, Craig Andrus, with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY Date: {b 1'2':; (o~ By: ~~~qUire Attorney 1.0. No. 83882 2411 North Front St. Harrisburg, PA 17110 (717) 232-9900 . , ,. CERTIFICATE OF SERVICE AND NOW, this 'Le( day of October, 2006, I 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: Joseph Metz, Esquire Dilworth Paxson, LLP 112 Market Street, 8th Floor Harrisburg, PA 17101 IUjJhb~qr-- Michael S. Ferguson, Esquire ...., r--..:J C:J C~:::J. 0' o -n C) C) --l ::;:l --.-. "T1 rnp= ~~ ~~jf"'n :.:--., ~D .< r--:) O't -D f''' (..:l - .. SUSAN SHELBURNE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02.5675 CRAIG ANDRUS, Defendant JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendant, Craig Andrus, with regard to the above-captioned matter. Respectfully submitted, NEALON GOVER & PERRY By: Date:~ I .. CERTIFICATE OF SERVICE AND NOW, thisd S~ day of October, 2006, I 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: Joseph Metz, Esquire Dilworth Paxson, LLP 112 Market Street, 8th Floor Harrisburg, PA 17101 nley Allen, Esquire o c:; <=~~- t~: r---:> c,.::,") C'::JI C)....... o c-~ -, o -n .-~ :::C-n f\'F :~:~ t~3 '}-~b r:~: f~ '::-ll -",. ~O :< N 0"' :s! ..-::. r:: .l;:' v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5675 SUSAN SHELBURNE, Plaintiff CRAIG ANDRUS, Defendant JURY TRIAL DEMANDED MOTION TO LIST FOR TRIAL TO THE HONORABLE JUDGE J. WESLEY OLER JR.: AND NOW, comes the Defendant, Craig S. Andrus, by and through his attorneys, Nealon Gover & Perry, and files the following Motion to List for Trial: 1. Nicole M. Werner, Esquire was in attendance for the call of the list this morning, however she was remiss in calling the above-referenced case to be listed for trial. 2. Ms. Werner attempted to notify Your Honor of the mistake, however, the case had already been stricken from the trial list. Accordingly, Your Honor requested that a Motion to List for Trial be filed. 3. Counsel for the Plaintiff, Joseph Metz, Esquire, was not present at the call of the list. 4. All relevant discovery and preliminary matters have been completed and the case is ready for trial. WHEREFORE, Defendant, Craig S. Andrus, respectfully requests that this Honorable Court grant the above Motion and list this case for the next trial term. Respectfully submitted, NEALON GOVER & PERRY By: ,,~ .J(('\ /" l 1: A f / / V . ",0..e..t.JL.1.--1., /.t~.../! Jenni Henley Allen, Esquire .Ix t.. Attorney 1.0. No. 84311 2411 North Front 8t. Harrisburg, PA 17110 (717) 232-9900 Date: 1/J/tJl CERTIFICATE OF SERVICE qth . AND NOW, this day of January, 2007, I hereby certIfy that I have served the foregoing Motion to List for Trial on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Joseph Metz, Esquire Dilworth Paxson, LLP 112 Market Street, 8th Floor Harrisburg, PA 17101 j~ :h ~/ . ; ~A A~~~i~en'l:~/~II~~:I E~~li 0 --_1 ) ":" -n c. :",:: \ ,f) ~," -'. \."/ . SUSAN SHELBURNE, Plaintiff v CRAIG ANDRUS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 02-5675 CIVIL TERM IN RE: CASE STRICKEN FROM LIST ORDER OF COURT AND NOW, this 9th day of January, 2007, upon consideration of the call of the civil trial list, and the above-captioned case having not been called for trial, it is stricken from the trial list. ~sePh Metz, Esquire 112 Market Street 8th Floor Harrisburg, PA 17101-2043 For Plaintiff ~enni Henley Allen, Esquire 2411 N. Front Street Harrisburg, PA 17111 For Defendant Court Administrator :mae By the Court, >. 0:;'; t:::; r"\ u.J ~:: ~?(::: ~+-~: . ~t~ ;;d UJ U-:r.: t- u... o r- o 5 - ~ Z li.~ L: -, ....... c::> = c;-.l ....:..-- ; (j ~ SUSAN SHELBURNE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5675 CRAIG ANDRUS, Defendant JURY TRIAL DEMANDED CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: PLEASE WITHDRAW DEFENDANT'S PRAECIPE TO LIST THE ABOVE- CAPTIONED MATTER FOR TRIAL THE WEEK OF APRIL 16, 2007, Respectfully submitted, NEALON GOVER & PERRY By . Date: Jenn' n y Allen, Esquire Att ney 1.0. NO. 84311 241 h Front Street Harrisburg, PA 17110 (717) 232-9900 ...... CERTIFICATE OF SERVICE AND NOW, this ~~~ay of January, 2007, I hereby certify that I have served the foregoing PRAECIPE TO WITHDRAW REQUEST TO LIST FOR TRIAL on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Joseph Metz, Esquire Dilworth Paxson, LLP 112 Market Street, 8th Floor Harrisburg, PA 17101 o ~~:: r-' g -oJ <- SE w o -n -I :1:"'n rl1r: -or>...; ~~.~.j "'( o'c, ";:; ~r~ -u -',- ~~ ::~~.~~ ::::'\ -f':O- ~~ w . . ('.) \..0 SUSAN SHELBURNE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 02-5675 v. CIVIL ACTION - LAW CRAIG ANDRUS, Defendant PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please discontinue the above-captioned case at Plaintiff's request. Respectfully submitted, DILWORTH PAXSON LLP cJtBZJ . Metz, Esquire o y J.D. No. 32958 112 Market Street, 8th Floor Harrisburg, PA 17101 Tel.: (717) 236-4812 Fax: (717)236-7811 Date: April 9, 2007 24901_1 n ~ "'---- r--.:> = = -..J :> -0 ........, .-"V o " ---l I-n m,_ --1~~ ~!:--~,C( ~C) '-~ -j-, n,,"" '1 ;.'~ ~{; ~ J-> ~ ~ ::i: o w