HomeMy WebLinkAbout01-5710IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SHAWN SWINTOSKY,
Plaintiff
WEIS MARKETS, INC.,
Defendant
: CIVIL ACTION - LAW
: JURY TRIAL DEMANDED
YOU HAVE BEEN SUED IN COURT· If you wish to defend against the claims set
forth against you 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 default 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 THIS OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
Lawyer Referral Service
Two Liberty Street
Carlisle, Pennsylvania 17013
(717) 249- 3166
1-800-990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SHAWN SWINTOSKY,
Plaintiff
WEIS MARKETS, INC.,
Defendant
..
: CIVIL ACTION - LAW
..
: JURY TRIAL DEMANDED
USTED HA SlDO DEMANDADO EN LA CORTE. Si usted desea defenderse de
las quejas expuestas en las p~ginas siguientes, debe tomar acci6n dentro de veinte (20)
dias a partir de la fecha en que recibi6 la demanda y el aviso. Usted debe presentar
comparecencia escrita en persona o por abogado y presentar en la Corte por escrito sus
defensas o sus objeciones a las demandas en su contra.
Se le avisa que si no se defiende, el caso puede proceder sin usted y la Corte
puede decidir en su contra sin mas aviso o notificaci~)n por cualquier dinero reclamado en
la demanda o por cualquier otra queja o compensacibn reclamados por el Demandante.
USTED PUEDE PERDER DINERO, O PROPRIEDADES U OTROS DERECHOS
IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE.
SI USTED NO TIENE O NO CONOCE UN ABOGADO, VAYA O LLAME A LA
OFICINA EN LA DIRECCION ESCRITA ABA JO PARA AVERIGUAR DONDE
PUEDE OBTENER ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
Lawyer Referral Service
Two Liberty Street
Carlisle, Pennsylvania 17013
(717) 249 - 3166
1-800-990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
SHAWN SWINTOSKY,
Plaintiff
Me
WEIS MARKETS, INC.,
Defendant
CIVIL ACTION - LAW
,JURY TRIAl D£MANDFD
1. The Plaintiff, Shawn Swintosky, is an adult individual residing at 216 Hastings
Street, Johnstown, Pennsylvania 15904.
2. Defendant, Weis Markets, Inc., is a Pennsylvania Corporation with an
address for service of 1000 South Second Street, Sunbury, Pennsylvania 17801.
3. At all times relevant hereto, the Defendant owned and/or operated a retail
business located on King Street in Shippensburg, Pennsylvania, and believed to be store
#38.
4. On September 19, 2000, the Plaintiff was a business invitee at the
aforementioned Weis Market Store.
5. The Plaintiff was present at the Defendant's store to perform repair work
while in the course and scope of his employment with Sylvania Lighting Services.
6. On September 19, 2000, at approximately 11:00 a.m., the Plaintiff was
traversing the floor near the produce section carrying an eight foot ladder, when he
slipped in liquid which had accumulated on the floor.
7. Plaintiff caught himself in a twisting motion without failing to the ground but in
;o doing experienced immediate back and neck pain.
8. At all times relevant hereto, the Defendant acted through its employees,
agents, and/or servants and is vicariously liable for the negligence of those individuals.
9. The aforementioned accident occurred as a result of the negligence of the
employees, agents, and/or servants of the Defendant, and was due in no manner to any
act or failure to act on the part of the Plaintiff.
10. This matter is alleged to exceed the applicable limits of arbitration and a jury
trial is hereby demanded.
11. The negligence of the employees, agents, and/or servants of the Defendant
consisted of the following:
a) Failing to recognize the special element of harm and
danger of a wet floor;
b)
Permitting or allowing water or other liquid
substance to accumulate on the floor of the store
when the Defendant knew that persons such as the
Plaintiff would have to traverse the area;
c)
Failing to utilize that degree of care required for
business invitees such as the Plaintiff by not
maintaining the premises in a safe and usable
condition;
d)
Failing to inspect the premises to discover the
unsafe and hazardous condition of water or other
liquids on the floor in its store;
e)
Failing to exercise reasonable care in attempting to
clean up the water or other liquid;
Failing to warn or protect the Plaintiff from the
unsafe and hazardous condition of water or other
liquid substance on the floor when the Defendant
knew or should have known that the Plaintiff would
be unable to protect himself;
g)
Failing to correct the hazardous and dangerous
condition that the Defendant knew or should have
known existed on its premises;
h)
Creating or allowing a hazardous condition to exist
which the Defendant knew or should have known
involved an unreasonable risk of danger to persons
such as the Plaintiff who would not know or have
reason to know of the unreasonable risk of harm;
i)
Failing to warn the Plaintiff of the unsafe and
hazardous condition of water or other liquid
substance on the floor;
J)
Failing to carry on the Defendant's activities with
reasonable care for the safety of the public;
k)
Failing to remove the water and/or liquid substance
from the floor of its store; and
i)
Failing to post any warning signs of a wet and/or
slippery floor in the area of Plaintiff's accident when
the Defendant knew, or should have known, that the
Plaintiff would be exposed to an unreasonable risk
of harm.
13. At all times relevant hereto, the Defendant's employees, agents and/or
representatives were acting within the course and scope of their employment with the
3
Defendant, under the Defendant's control, and in furtherance of the Defendant's business
interest.
14. The Defendant is vicariously liable for the negligence of its employees,
agents, and or representatives.
15. As a result of the aforesaid negligence, the Plaintiff suffered serious and
permanent injuries including, but not limited to, cervical, thoracic, and lumbar
strain/sprain, herniated disc at C5-6, muscle spasms, and a severe shock to his nerves
and nervous system.
16. As a result of the negligence of the Defendant, the Plaintiff was fomed to
incur medical bills and expenses for the injuries he has suffered and he will continue to
incur medical expenses in the future.
17. As a result of the negligence of the Defendant, the Plaintiff has suffered, or
may suffer, a severe loss of his earnings and impairment of his earning capacity. This
loss of income and impairment of earning capacity, and the loss of income and
impairment of earning capacity will, or may, continue in the future.
18. As a result of the negligence of the Defendant, the Plaintiff has undergone,
and in the future may undergo, great mental and physical pain and suffering, mental
anguish and humiliation, loss of life's pleasures, and a severe limitation in his pursuit of
daily activities, all to his great loss and detriment.
WHEREFORE, Plaintiff respectfully requests This Honorable Court to enter
judgment against the Defendant in an amount in excess of the mandatory arbitration
limits.
RESPECTFULLY SUBMITTED:
LAW OFFICES OF DALE E. ANSTINE, P.C.
Leai'f'B. ~raff, Esq~i'r~'"''''-L-----~
Attorney I.D. #29176
Two West Market Street
P.O Box 952
York, Pennsylvania 17405
I HEREBY VERIFY that the information set forth in the foregoing Complaint is true
and correct to the best of my knowledge, information and belief. I understand that any
false statements contained herein are subject to the penalties of 18 Pa.C.S. §4904,
relating to unsworn falsification to authorities.
Date:
SHAWN SWINTOSKY
V.
WEIS MARKETS, INC.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND CO., PENNA.
CIVIL ACTION - LAW
NO. 01-5710 CIVIL TERM
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that Plaintiff's Interrogatories, Set #1 and Set #2, along with
PlalntiWs Request for Production of Documents were sent to counsel for Defendant by First Class
United States Mall on the below date to the following address:
Kevin C. McNamara, Esquire
Thomas, Thomas & Haler, LLP
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108
Date:
II-lq~O I
Leah lB. Graft, Esquire/
Attorney I.D. No. 29176
Attorney for Plaintiff
THOMAS, THOMAS & HAFER, LLP
Kevin C. McNamara, Esquire
Identification Number: 72668
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108-0999
717/237-7132
Attorneys for Defendant
SHAWN SWINTOSKY,
Plaintiff
V,
VVEIS MARKETS, INC.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.~I'8- O I --~"~(3
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
NOTICE TO PLEAD
TO: Plaintiff and Counsel:
You am hereby notified to plead to the enclosed New Matter within twenty (20) days fi.om
service hereof or a default judgment may be entered against you.
Respectfully submitted,
THOMAS, THOMAS & HAFER, LLP
By: ~'~' '/~/7 ~;~~t_
Kevin C. McNamara, Esquire
I. D.#72668
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108-0999
(717) 237-7132
Attorneys for Defendant
THOMAS, THOMAS & HAFER, LLP
Kevin C. McNamara, Esquire
Identification Number: 72668
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108-0999
717/237-7132
Attorneys for Defendant
SHAWN SWINTOSKY,
Plaintiff
V.
WEIS MARKETS, INC.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-570
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
DEFENDANT'S ANSWER WITH NEW
MATTER TO PLAINTIFF'S COMPLAINT
2.
3.
4.
required.
5.
It is admitted that the Plaintiff is who he says he is.
Admitted.
Admitted.
Denied. This allegation represents a conclusion of law to which no response is
Denied. After reasonable investigation, Defendant is without knowledge or
information sufficient to form a belief as to the truth of the averments contained in this paragraph
and proof thereof is demanded.
6. Denied. After reasonable investigation, Defendant is without knowledge or
information sufficient to form a belief as to the truth of the averments contained in this paragraph
and proof thereof is demanded.
7. Denied. After reasonable investigation, Defendant is without knowledge or
information sufficient to form a belief as to the truth of the averments contained in this paragraph
and proof thereof is demanded.
8. Admitted in part and denied in part. It is admitted that from time to time, Weis
Markets acts through its employees, agents and/or servants. The allegation of vicarious liability
for the negligence of employees, agents and/or servants represents a conclusion of law to
which no response is required.
9. Denied.
10. Denied. After reasonable investigation, Defendant is without knowledge or
information sufficient to form a belief as to the truth of the averments contained in this paragraph
and proof thereof is demanded.
Denied. It is denied that the Defendant was negligent in any of the ways
11 (a)-(I).
alleged.
12.
13.
The Complaint does not contain a Paragraph 12.
Admitted in part with qualification and denied in part. It is admitted that from time
to time, Weis Markets employees, agents and representatives acting in the course and scope of
their employment do things under the supervision and control of Weis Markets and in
furtherance of Weis Markets' business interests. It is denied that any employee, agent and/or
representative of Weis Markets did or did not do something which caused or contributed to the
incident set forth in Plaintiff's Complaint.
14. Denied. These allegations represent conclusions of law to which no response is
required.
15-18. Denied. It is denied that the Defendant was negligent or that any negligence on
the Defendant's part was a substantial factor in bringing about any of the injuries or damages
2
alleged. As to the specifics of injuries and damages set forth in these paragraphs, After
reasonable investigation, Defendant is without knowledge or information sufficient to form a
belief as to the truth of the averments contained in this paragraph and proof thereof is
demanded.
WHEREFORE, Defendant respectfully requests that Plaintiffs Complaint be dismissed
without cost to it.
NEW MATTER
19. Weis Markets was not negligent in regard to the incident set forth in Plaintiff's
Complaint, nor was any conduct on the part of Weis Markets or its agents, servants or
employees a substantial factor in bringing about the alleged incident or damages claimed in
Plaintiff's Complaint.
20. Plaintiff's claim is or may be barred by the lack of notice of the allegedly
dangerous condition set forth in Plaintiff's Complaint.
21. The conditions set forth in Plaintiffs Complaint was or may have been brought
about by parties other than Answering Defendant and over whom Answering Defendant had no
control or right of control.
22. No conduct on the part of Defendant or any of its employees was a substantial
factor in bringing about the alleged incident or damages.
3
WHEREFORE, Defendant respectfully requests that Plaintiff's Complaint be dismissed
without cost to it.
Respectfully submitted,
THOMAS, THOMAS & HAFER, LLP
I.D.#72668
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108-0999
(717) 237-7132
Attorneys for Defendant
4
VERIFICATION
I, ~_ ,",e.-~ ~ ~/~W'~A'~--~ state that I am an authorized representative of WEIS MARKETS,
INC., that I make this Verification on behalf of Defendant WEIS MARKETS, INC., and that I am
familiar with the facts set forth in the foregoing document. I have read the foregoing document and
hereby affirm that it is true and correct to the best of my personal knowledge, information and
belief. This Verification is made pursuant to 18 Pa.C.S. § 4904 relating to unswom falsification to
authorities.
WEIS MARKETS, INC.
DATE:
:1571.1
CERTIFICATE OF SERVICE
I, Kevin C. McNamara, Esquire, hereby certify that I have served a true and correct copy of
the foregoing document on the following person by placing same in the United States mail, postage
prepaid, onthe 2~X/d~y of ~)c ~ ~ ,2001:
Leah B. Graft, Esquire
LAW OFFICES OF DALE E. ANSTINE, P.C.
Two West Market Street
P.O. Box 952
York, PA 17405
:146393.1
THO~MA.,~HOMAS & HAFER, LLP
Kevin C. McNamara, Esquire
5
THOMAS, THOMAS & HAFER, LLP
Kevin C. McNamara, Esquire
Identification Number: 72668
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108-0999
717/237-7132
Attorneys for Defendant
SHAWN SWINTOSKY,
Plaintiff
V.
WEIS MARKETS, INC.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6-7-~
CIVIL ACTION - LAW
JURY TRIAL DEMANDED
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of the undersigned as attorneys for Defendant Weis Markets,
Inc. in the above matter.
Respectfully submitted,
THOMAS, THOMAS & HAFER, LLP
Kevin C. McNamara, Esquire
I.D.#72668
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108-0999
(717) 237-7132
Attorneys for Defendant Weis Markets, Inc.
DATE:
CERTIFICATE OF SERVICE
I, Kevin C. McNamara, Esquire, hereby certify that I have served a true and correct copy of
the foregoing document on the following person by placing same in the United States mail, postage
prepaid, on the ~.~/a~Y of~'~'~c ~'~ ~/~ , 2001:
Leah B. Graft, Esquire
LAW OFFICES OF DALE E. ANSTINE, P.C.
Two West Market Street
P.O. Box 952
York, PA 17405
THOMAS, THOMAS & HAFER, LLP
Kevin C. McNamara, Esquire
:146389.1
SHAWN SWINTOSKY
V.
WEIS MARKETS, INC.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND CO., PENNA.
CIVIL ACTION - LAW
NO. 01-5710 CIVIL TERM
JURY TRIAL DEMANDED
PLAINTIFF'S REPLY TO DEFENDANT'S
NEW MATTER
AND NOW, comes Plaintiff, by and through his counsel, who replies to Defendant's New
Matter as follows:
19-22. Denied. The allegations contained in Paragraphs 19 through 22 are conclusions of law to
which the Pennsylvania Rules of Civil Procedure require no responsive pleading, are therefore denied, and
strict proof thereof is demanded at trial, if relevant.
Respectfully submitted,
Leah B. Graft, Esqu'~re
Attorney I.D. No. 29176
Two West Market Street
P.O. Box 952
York, Pennsylvania 17405
(717) 846-0606
Attorney for Plaintiff
VERIFICATION
Leah B. Graft, Esquire, hereby states that she is the attorney for the Plalmiff in this action
verifies that the statements made in the foregoing Reply to Defendant's New Matter are true
and correct to the best of her knowledge, information, and belief. The undersigned understands that
the statements therein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom
falsification to authorities.
Date: /0 -.~1.o!
Leah B. Graft, Es~tuiro/
Attorney I.D. No. 29176
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a tree and correct copy of the foregoing Reply to Defendant's
New Matter was sent by First Class United States Mail to counsel for Defendant on the below date
at the following address:
Kevin C. McNamara, Esquire
Thomas, Thomas & Hafer, LLP
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108
Date: /~) ?, /- vt
Leah B. Graft, Esquire
Attorney ID No. 29176
Attorney for the Plaintiff
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2001-05710 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
SWINTOSKY SHAWN
VS
WEIS MARKETS INC
R. Thomas Kline
duly sworn according to law,
and inquiry for the within named DEFENDANT ,
WEIS MARKETS INC
but was unable to locate Them in his bailiwick.
deputized the sheriff of NORTHUMBERLAND County,
serve the within COMPLAINT & NOTICE
says, that he made a diligent
to wit:
, Sheriff or Deputy Sheriff who being
search and
He therefore
Pennsylvania,
to
On November 13th , 2001 , this office was
attached return from NORTHUMBERLAND
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep Northumberland
18.00
9.00
10.00
28.62
.00
65.62
11/13/2001
DALE ANSTINE
in receipt of the
Sheriff of Cumberland County
Sworn and subscribed to before me
this ~ day of~
~o! A.D.
/- ; Pr~'honotary ~ ~ '
In The Court of Common Pleas of Cumberlan~ County, Pennsylvania
Shawn Swintosky
VS.
Weis Markets, Inc
SERVE: same No. 01 5710 civil
Now, October 3, 2001 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriffof Northumberland County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriffof Curnberland County, PA
Affidavit of Service
Now~
within
,20 , at o'clock __ M. served the
upon
at
by handing to
a
and made known to
copy of the original
the contents thereof.
So answers,
Sheriffof , , County, PA
Sworn and subscribed before
me this __ day of
,20
COSTS
SERVICE
MILEAGE
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
SWINTOSKY
VS.
WEIS MARKETS INC
NO.
CERTIFICATE
015710
PREREQUISITE TO SERVICE OF A SUBPOENA
PURSUANT TO RULE 4009.22
As a prerequisite to service of a subpoena(s) for documents and things
pursuant to Rule 4009.22 KEVIN MCNAMARA, ESQUIRE certifies that:
1. A Notice of Intent to Serve the Subpoena(s) with a copy of
the subpoena(s) attached thereto was mailed or delivered to
each party at least twenty days prior to the date on which
the subpoena(s) is sought to be served,
2. A copy of the Notice of Intent, including the proposed
subpoena(s) is attached to this certificate,
3.No objection to the subpoena(s) has been received, and
4. The subpoena(s) which will be served is identical to
the subpoena(s) which is attached to the Notice of Intent
to Serve the Subpoena(s).
Date: 03/27/02
File #: M284575
KEVIN MCNAMARA, ESQUIRE
305 N FRONT ST 6TH FLOOR
PO BOX 999
HARRISBURG, PA 17108
717-237-7100
ATTORNEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO:
MEDICAL LEGAL REPRODUCTIONS, INC.
4940 DISSTON STREET
PHILADELPHIA PA 19135
(215)
By: Christine janiszewski
IN TI-IK COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
SWINTOSKY
Vs.
WEIS MARKETS
INC
No. 015710
TO: LEAH GRAFF
NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE
DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21
DEFENDAHT intends to serve a subpoena(s) identical to
the one(s) attached to this notice. You have twenty (20) days
from the date listed below in which to file of record and serve upon
the undersigned an objection to the subpoena. If no objection is
made the subpoena may be served.
Date: 03/06/02
KEVIN MCNAMARA, ESQUIRE
305 N FRONT ST 6TH FLOOR
PO BOX 999
HARRISBURG, PA 17108
ATTOR/qEY FOR DEFENDANT
INQUIRIES SHOULD BE ADDRESSED TO=
MEDICAL LEGAL REPRODUCTIONS,
4940 DISSTON STREET
PHILADELPHIA, PA 19135
(215) 335-3336
INC.
By: Christine Janiszewski
Enc (s):
File #:
Copy of subpoena(s)
Counsel return card
M284575
CCkMMDNWEALTH OF p~qSYLVANIA
C~3NTY OF Cm4BERUU~
SWINTOSKY :
:
Vs. : File No.
:
WEIS MARKETS INC :
01570
TO:
vALLEY ORTHO,
SUBPOENA TO PROOUCE D(X3.1'IENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
1111 FRANKLIN ST STE 140, JOHNSTOWN PA 15905-4382
(Nm~e 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 ADDENDUM
~DICAL LEGAL REPRODUCTIONS%AdT~ss~940 DISSTON ST., PHILA., PA
You may deliver or mail legible co~ies of the doctrnents or produce things requested
this subpoena, together with the certificate of cu,uliance, to the party making thi~
request at the address listed above. You have the right to seek in advance the rea~onabl~
cost of preparing the copies or producing the things sought.
If you fail to produce the doctn~ents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena m~y seek a court orde.'
~,~elling yo~ to cu,~ly with it.
THIS SUBPOENA WAS ISSUED AT THE RE(;i, UEST OF THE FOJ._LOWIt.,~i PER,CK~N:
I~Ut, J..'E[: R"'I~'~/'TI~I' MC~A, ESQ
ADOR ESS:
305 i~ FROi,~T~.~'~ 6TH FLOOR
TELEPHONE:
SUPRE~ COU~T ID ~
ATTORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-01
03/~F/02
DALE:
DEFENDANT
$.eal of the Oourt
BY THE C~URT:
Protl~m~otary/Ct~erl~, Civil Division
C 't
(Elf. 7~97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 01570
CUSTODIAN OF RECORDS FOR: VALLEY ORTHO
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ]
[ ]
RECORDS AREATTACHED HERETO:I hereby certify as custodian of
records that, to the best ~f my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AV/JLABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS
( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-01
Authorized signature for
VALLEY ORTHO
*** SIGN AND RETURN THIS PAGE ***
(I~TH OF p]~VAN-,-A
SWINTOSKY
Vs.
WEIS MARKETS INC
File No.
01570
TO:
SUBPOENA TO PROOUCE DOCtJMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4-009.22
THRESE BAYWOOD, CRNP, 1027 BRO~a/) ST, JOHNSTOWN PA 15906
(Name of Parson o~ Entity)
within twenty (20) days afte~ service of this subpoena, you a~eo~de~ed by the ~rt to
price the foll~i~ ~t~ ~ things:
SEE ATFAC~D ~DENDUM
MEDICAL LEOAL REPRODUCTIONS(,AjL~s)4940 DISSTON ST., PHILA., PA
Yo~ may delive~ cc mail legible copies of the doc~nts o~ produce things requested
this sub~ena, together with the certificate of co,'~liance, to the party making thi~
request at the address listed above. You have the right to seek in advance the rea~onabl~
cost of preparing the copies or producing the things sought.
If you fail to produce the doctrnents cc things required by this subpoena within twenty
(20) days altec its service, the party serving thi~ subpoena may seek a court orde.'
o.,,~ellmg you to cc~ly with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWIN~ PERSON:
NAME: KEVIN MCNAMAP. A, ESQ
ADORESS: 3~ 6TH FLOOR
TELEPHONE:
SUPREFE COJRT ID ~
ATTORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-02
03 ~o ~/o2
DATE:
Seal of the Ccitt
DEFENDANT
BY THE COURT:
Proth~notary/~l~k. Civil Division
-- / z Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 0157D
CUSTODIAN OF RECORDS FOR: THRESEBAYWOOD, CRNP
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/2~/75
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ]
[ ]
RECORDSAREATTACHED HERETO:I hereby certify as custodian of
records that, to the best of my knowledge, information and ~ .
belief all documents or things above mentioned have been proaucea.
NO DOCUMENTS AVA~LABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-02
Authorized signature for
THRESE BAYWOOD, CRNP
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
VS.
WEIS MARKETS INC
CO~~ OF p~YLVANIA
o0um OF
File No. 01570
SUBPOENA TO PROOUCE DOCt~ENTS OR THINGS
FOR DISCOVERY PURSUANT TO ~ULE 4009.22
DR RODNEY HOUGH AND, DR ROBERT SINGUENZA, 49 BROOKWOOD AVE
TO: CARLISLE PA 17013-9126
(Name of Perso~ o~ Entity)
within twenty (20) days after service of this subpoena, you a~e ordered by the court to
produce the followir~3 o~t.~ or~t~ngs~:~~z~r~-~-
at
MEDICAL LEGAL REPRODUCTIONS(,A~N~ss~940 DISSTON ST., PEILA., PA
You may deliver or mail legible cooies of the documents or produce things requested bt
this subpoena, together with the certificate of cu,~liance, to the party making this
request at the address listed '~bove. You have the right to seek in advance the rea~onabI~
cost of preparing' the copies or 0roducing 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 orde.'
c~m~ellir~3 you to cu~ly with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLCWI4NG PERSON:
NAME: KEVIN MCNAMARA, ESQ
ADORESS:-- 30.5 ~: ...... ~ ..~.. ~ ~.~. 6TH FLOOR
TELEPHONE:
~UPRE~ COU~T ID #
A~-FORNEY FOR:
HARRISBURG, PA 17108
215-335-E212
DEFENDANT
M284575-03
03/~/02
DATE:
Seal of the Court
BY THE COURT:
ProthO~Ota~y/Cl~e~l(, Ci¥il Oivisi~
-- , t ~ty
(Eff. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 015~0
CUSTODIAN OF RECORDS FOR: DR RODNEY HOUGH AND
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: SHAWN J SWINTOSKY
ADDRESS: 216 HASTINGS ST JOHNSTOWN PA
DATE OF BIRTH: 03/26/75
SSAN: 196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN
COMPLETE AND RETURN
[ ]
[ ]
RECORDS AREATTACHED HERETO:I hereby certify as custodian of
records that, to the best of my knowledge~ information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-03
Authorized signature for
DR RODNEY HOUGH AND
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
VS.
WEIS MARKETS INC
c~NWEALTH OF p~YLVANIA
COUNTY
File No.
0157/0
TO:
SUBPOENA TO PROEXJ(~ DOCUMENTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
GALLAGHER BASSETT SVCS, 540 PELLIS RD STE 3000,
GREENSBURG PA 15601
(Name of Person o~ Entity)
within twenty (20) days afte~ service of this subpoena, you a~e ~d~ed by the c~rt to
price the foll~i~ ~t~ ~ things:
SEE A AC D DENDUM
at
MEDICAL LEGAL REPRODUCTIONS~Ad~ss~940 DISSTON ST., PHILA., PA
y(~ may deliver o~ mail legible cooies of the doc~znents o~ produce things requested ¥:'~
this subpoena, togethe~ with the certificate of o~,~liance, to the party making thi~
request at the address listed 'above. You have the right to seek in advance the rea~onabl~
cost of preparing the copies or producing the things sought.
if you fail to produce the documents o~ things required by this subpoena within twenty
(20) days afte~ its semv~ce, the party serving thin subpc~.na may seek a court ocde.'
oJ,~ellin~ you to c~,~ly with it.
THIS SUBPOENA WAS ISSUED AT THE RE(;~JEST O~ THE FOLLOWING PERSOI~.:
NAME: KEVIN MCNAMJ%RA, ESQ
ADOEESS:__ 305.. .... ~..~..~. ~ 6TH FLOOR
TELEPHONE:
SUPREIIE COURT ID #
ATTORNEY FC~:
H/~ISBURG, PA 17108
215-335-3212
M284575-04
03/d~/02
DATE:
DE FEiN-DANT
Sea] of the Cx~urt
BY THE CCURT:
Prothonot~ry/Cl~, C'ivil Division
-- / ' Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 01590
CUSTODIAN OF RECORDS FOR: GALLAGHER BASSETTSVCS
ANY A/qD A~L RECORDS, MEDICAL AND OR ACCIDENT CORRESPONDENCE, NOTES,
RECEIPTS, BILLS, ETC., AND ANY OTHER INFORMATION PERTAINING TO:
NAME: SHAWN J SWINTOSKY
ADDRESS: 216 HASTINGS ST JOHNSTOWN PA
DATE OF BIRTH: 03/26/75
SSAN: 196544333
ALL RECORDS PERTAINING TO POLICY #011083
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ]
[ ]
RECORDS ARE ATTACHED HERETO:I hereby certify as custodian of
records that, to the best of my knowledge, information and ~ ~
belief all documents or things above mentioned have peen proaucea.
NO DOCUMENTS AVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-04
Authorized signature for
GALLAGHER BASSETT SVCS
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
Vs.
WEIS MARKETS INC
C~TH OF pE~qSYLVANIA
: File No.
01570
SLI~POENA TO PRODUCE DOOJMENTS OR TH I NGS
FOR DISOOVERY PURSUANT TO RULE 4009 2~
TO:
HEA~TH AMERICA PENNA, 5 GATEWAY CTR, PITTSBURGH PA 15222
ATTN: HELEN ANDREKO
(Name of Person or Entity)
within twenty (20) days afte~ service of this subpoena, yo~ are ordered by the court to
produce the followin9 doc~nent.~ or thir
at
MEDICAL LEGAL REPRODUCTIONS(A~Ss~940 DISSTON ST., PEILA., PA
you may deliver or mail legible cooies of the documents or produce things requested b!
this subpoena, together with the certificate of c~,~liance, 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 ~ies or producing the things sought.
If you fail to produce the docunents or things required by this subpoena within twenty
(20) days after its service, the party serving thin subpoena may seek a court orde.'
~,~ellin9 you to ca~ly with it.
THIS SU~POENAWAS ISSUED AT THE REC~JESTOFTHE FOLLO~INGPERSOH:
NAME: KEVIN MCNAMARA, ESQ
ADORESS: 305 ~~..w.~ ~m~ 6TH FLOOR
TELEPHONE:
SUPRE~[ CC~RT ID ~
ATTORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
DEFENDANT
M284575-05
o /or/'o2
DATE:
Seal of the Court
BY THE CO~T:
Prothonotary/Cl%~k,~'~O~w 1 Divisien
! ! Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC~
No. 0t57/0
CUSTODIAN OF RECORDS FOR: HEALTH AMERICA PENNA
ANY ~ /LLL RECORDS, MEDIC3%L AND OR ACCIDENT CORRESPONDENCE, NOTES,
RECEIPTS, BILLS, ETC., 3_ND ANY OTHER INFORMATION PERTAINING TO:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/7s
196544333
ALL RECORDS PERTAINING TO POLICY #196544333
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ]
[ ]
RECORDSAREATTACHED HERETO:I hereby certify as custodian of
records that, to the best 9f my knowledge, information and
belief all documents or things above mentioned have been produced.
NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERId%ND
M284575-05
Authorized signature for
HF2%LTHAMERICA PENNA
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
Vs.
WEIS MARKETS INC
OO~'O~TH OF
: File No.
01570
TO:
SLm_POENA TO PROOUCE DCOJ-IENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
CONCERTAMANAGED CARE, 4718 OLD GETTYSBURG RD #205,
MECHANICSBURG PA 17
(Name of Person o~ Entity)
Within twenty (20) days after service of this subpoena, you are o~dered by the court to
produce the fol lowin<j docunent.~ or thir
SEE 'g TrArI I - )D-ENDI
MEDICAL LEGAL REPRODUCTIONS(A~s~940 DISSTON ST., PHILA., PA
You may deliver or mail le9ible copies of the doctmaents or produce things requested
this subpoena, together with the certificate of cu,wlience, to the party making thi~
request at the address listed 'above. You have the right to seek in advance the rea~onab)~
cost of preparing the copies or producing the things sought.
If you fail to produce the docunents or things required by this subpoena within twenty.
(20) days after its service, the party serving this subpoena may seek a court orde.-
=,,oelling you to c~,ply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: XEVIN MCNAMARA, ESQ
ADORESS: 3C5 N ~RCI;'T CT 6TH FLOOR
TELEPHONE:
SUPREItE COU~T ID ~
A'rrORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
DEFENDANT
M284575-06
DATE:
Seal of the Court
BY THE COUIRT:
Prothonotar~/~3d~erk, Civil Division
Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 0157D
CUSTODIAN OF RECORDS FOR: CONCERTA 5~ANAGED CARE
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
DATE
NAME: SHAWN J SWINTOSKY
ADDRESS: 216 HASTINGS ST JOHNSTOWN PA
OF BIRTH: 03/26/75
SSAN: 196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of
records that, to the best ?f my knowledge, information and
belief all documents or things above mentioned have been produced.
] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-06
Authorized signature for
CONCERTAMA/qAGED CARE
*** SIGN.AND RETURN THIS PAGE ***
CO~TH OF P~Y~
c~tmr~Y OF ~
SWINTOSKY :
:
Vs. : File No.
:
WEIS M.,.J~KETS INC :
0157~0
SUBPOENA TO p _ROO__r~' EO~LI"ENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22.
BUREAU OF WORKER COMP, 1171 S CAMERON ST RM 103, HARRISBURG PA 17104-2
TO: ATTN: I~
(Name of person cc Entity)
within twenty (20) days afte~ service of this subpoena, you are ordered by the court to
produce the fol lo~ir~j documents or things~
SEE ATTACHED ADUENDU
at
MEDICAL LE~IAL REPRODUCTIONS(Ao~s)&940 DISSTON ST., PHILA., PA
you may deliver or mail legible copies of the documents or produce things requested
this subpoena, together with the certificate of ccrr~liance, to the party making thiz
request at the address listed 'above. You have the right to seek in advance the reasonable
cost Of preparing the copies or pcoducing the things sought.
If you fail to produce the doctrnents or things required by this subpoena withim twenty
(20) days after its service, the party serving thi-~ :~ubpoena may seek a court
ua,~elling you to cu,~ly with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: KEVIN MCNAMARA, ESQ
ADO~ESS: 305 N ~RO:TT ST 6TH FLOOR
TELEPHONE:
SUPREt~ CO JRT ID #__
ATTORNEY FOR:
HA~ISDu~ 17108
215-335-3212
DEFENDANT
M284575-07
03/d~/02
DATE:
Seal of the Court
BY TFE COURT:
Prothonotary~Clei~k, Civil Divisio~
(Eff. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. ~15~0
CUSTODIAN OF RECORDS FOR: BUREAU OF WORKER COMP
ANY AND ALL OF PLAINTIFF'S WORKER'S COMPENSATION CLAIMS, BENEFITS,
FILINGS, CORRESPONDENCE, HEARING TRANSCRIPTS, MEDICAL RECORDS,
MEMOS, AND FILE NOTES.
PERTAINING TO:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ]
] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-07
Authorized signature for
BUREAU OF WORKER COMP
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
VS.
WEIS MARKETS INC
CO~94D~TH OF P~~5~fLVANIA
File No.
0157/0
SUBPOENA TO PRODUCE DOCENTS OR 1%11NGS
FOR DISCOVERY PURSUANT TO RULE 4009 2~
TO:
CARLISLE HOSP, 246 PARKER ST, CARLISLE PA 17013
ATTN: MEDICAL RECORDS DEPT
(Name of Pe~so~ oc Entity)
within twenty (20) days afte~ service of this subpoena, you are ordered by the court to
produce the following doc~eot.~ or things:~
SEE ADDENDUM
at
~EDICAL LEGAL REPRODUCTIONS(,Ad~N~ss~940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or pr~x~uce things requested
this subpoena, together with the certificate of c~,~liance, to the party making thi~
request at the address listed above. You have the right to seek in advance the rea~onabl~
cost of preparing the copies or producing the things sought.
If you fail to produce the doct~ents or things required by this subpoena within twenty
(20) days after its service, the party serving 'thin subpoena may seek a court
o.,,~elling you to cu,~ly with it.
TH I S SUBPOENA WAS ISSUED AT THE RE~IJEST OF THE FGCLOWING PERSON:
NAME: KEVIN MCNi~, ESQ
ADORESS: 305 N P~O~T CT 6TH FLOOR
TELEPHONE:
SUPREME COURT ID #
ATTORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-08
o3/~ ~/o2
DATE:
DEFENDANT
Seal of the Court
BY ~ COURT:
Prothonotary/~l~k, Civil Oivisio~
~ty
(Elf. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 01570
CUSTODIAN OF RECORDS FOR: CARLISLE HOSP
Any and all hospital records, including microfilm, microfiche
emergency room reports, x-ray r~ports, out-patient records physical
therapy records, and any other information pertaining to:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of
records that, to the best of my knowledge~ information and ~ ~
belief all documents or things above mentioned have peen proaucea.
[ ]
NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X~RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBEPJ.~kND
M284575-08
Authorized signature for
CARLISLE HOSP
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
Vs.
WEIS MARKETS INC
File No.
0157/0
TO:
SUBPOENA TO PROOI.,CE DOO,.%'ENTS OR TH I NGS
FCR DISCOVERY PURSUANT TO RULE 40.__Q09.22
PENN WOOD PHYS THERAPY, 425 STONEHEDGE DR, CARLISLE PA 17013
(Nmme of Person o~ Entity)
within twenty (20) days after service of this subpoena, yc~J m~e ~d~ed by the c~rt to
p~ce the foll~i~ ~t~ ~ things:
SEE A AC D DENDUM
at
MEDICAL LEGAL REPRODUCTION~d~)4940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the documents or produce things requested bt
this subpoeoa, tOgether with the certificate of cu,~liance, to the party making thi:
request at the address listed above. You have the right to seek in advance the rea~onab ~
cost of preparing the copies or producing the things sought.
If you fail to produce the doc~nents or things required by this subpoena within twenty
(20) days after its service, the party serving 'thi-q subpoena may seek a court cede.'
o.~,~elling you to oa,~ly with it.
THIS SU~POEhb~ WAS ISS~JED AT THE RE(~JEST OF THE FOLLOWING PERSON:
NAME: KEVIN MCNA~, ESQ
ADC)~ESS:__ 305 13 I~RC~ CT 6TH FLOOR
TELEPHONE:
SUPRES"~ COURT ID :~
ATTORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-09
03/0~/02
DATE:
Seal of the Oourt
DEFENDANT
BY THE COURT:
Prothonotary/C~l~, Civil oivisio~
-- / / ~ty
(Eff. 7/9?)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
No. 01575
WEIS MARKETS INC
CUSTODIAN OF RECORDS FOR: PENN WOOD PHYS THERAPY
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME:
ADDRESS:
DATE OF BIRTH:
S SAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ]
[ ]
RECORDS AREATTACHED HERETO:I hereby certify as custodian of
records that, to the best 9f my knowledge, information and
belief all documents or things above mentioned have been produced.
NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS
( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAiqD
M284575-09
Authorized signature for
PENN WOOD PHYS THERAPY
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
Vs.
WEIS MARKETS INC
CO~43NWEALTH OF p~-'YLVANIA
File No.
o15W0
TO:
SUBPOENA TO PROOUCE DOCUMENTS OR THINGS
FOR D ISOCNERY PURSUANT TO RULE 4009.22
UPMC LEE REGIONAL, 2110 FRANKLIN ST, JOHNSTOWN PA 15905
i%TTN: DEPT OF RADIOLOGY
(Name of Pemso~ o~ Entity)
Within twenty (20) days afte~ service of this subpoena, you a~e o~-de~ed by the court to
produce the followir~j docunentn o~ things:
SEE ATFACI-I.ED ADDENDUM
M~DZCAL LEGAL REPRODUCTIONS(,A~d~s~940 DISSTON ST., PEILA., PA
You may delive~ o~ mail legible copies of the documents o~ produce things requested
this subpoena, togethe~ with the certificate of c~,~lience, to the party making thiz
request at the address listed '~bove. You haye the right to seek in advance the rea~onabl~
cost of preparing the cc~ies Or producing the things sought.
If you fail to produce the docunents o~ things required by this subpoena within twenty
(20) days afte~ its service, the party serving 'this subpoena may seek a court orde,'
co~l~elling you to co,~ly with it.
THIS SUIBPOENA WAS ISSUED AT THE RE(I~EST OF THE FOLLOWING PERSON:
NAME: KEVIN MCNAMARA, ESQ
ADORESS: 305 I:~"..vA.~ v°m~ 6TH FLOOR
TELEPHONE:
SUPRE~ COURT ID #
AI'~ORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-10
03~DF~02
DATE:
DEFENDANT
Seal of the Coumt
BY II-E COURT:
Prothc,~otary/(~le~, C~vil Oivisio~
o.
/ ; ~ty
(Elf. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS
INC
NO. 0157D
CUSTODIAN OF RECORDS FOR: UPMC LEE REGIONAL
ANY A/qD ALL MEDICAL RECORDS.
PERTAINING TO:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ]
NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X- RAYS
( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-10
Authorized signature for
UPMC LEE REGIONAL
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
Vs.
WEIS MARKETS INC
~TH OF pB~-"fLVANIA
COUNTY OF ~
File No.
0157~0
TO:
SUBPOENA TO PROOUCE ~NTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
ARLINGTON GROUP, 805 SIR THOMAS CT BOX 6507, HARRISBURG PA 17112
(Name of Person o~ Entity)
Within twenty (20) days after service of this subpoena, you are c~dered by the court to
produce the fol lowing docume~t.~ or thir
MEDICAL LEGAL REPRODUCTIONS(,Ad~N~ss~940 DISSTON ST., PHILA., PA
Yo~ may deliver or mail legible copies of the doc~n~nts or produce things requested
this subl~ena, together with the certificate of co,'wliance, to the pa~ty making thi~
request at the address listed above. You have the right to seek in advance the rea~onabl~
cost of preparing the copies or producing the things sought.
If you fail to produce the doc~nents or things required by this subpoena within twenty
(20) days afte~ its service, the party serving 'Chis subpoena may seek a court orde.-
or~,~ellincj you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST Of: THE FOLLCWING PERSON:
NAME: KEVIN MCNAMARA, ESQ
AD0~ESS:
305 ~:.,.~.,~ ~T 6TH FLOOR
TELEPHONE:
SUPRE~ COURT
ATTORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-11
03/~/02
OATE:
DEFENDANT
Seal of the Oourt
BY THE O3URT:
Prothonotary/~l~, Civil Oivisio~
/ / Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
VS.
WEIS MARKETS INC
NO. 01590
CUSTODIAN OF RECORDS FOR: ARLINGTON GROUP
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-R3kY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDSAREATTACHED HERETO:I hereby certify as custodian of
records that, to the best ?f my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ]
NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBE~
M284575-11
Authorized signature for
ARLINGTON GROUP
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
VS.
WEIS MARKETS INC
C~TH OF p]~Y'LVANIA
File No.
0157/0
SUBPOENA TO PROOUCE DOCUHENTS OR TH I NGS
FOR DISODVERY PURSUANT TO RULE 4009.22
TO:
CARLISLE HOSP, 246 PARKER ST BOX 310, CARLISLE PA 17013-0310
AT'UN: M~DICAL RECORDS DEPT
(Name of Perso~ or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the fo1 lowing docurne~t.~ om thir
SEE ATTACHED ADDENDLTM
at
M~DiCAL LEGAL REPRODUCTIONS(A~s9940 DISSTON ST., PHILA., PA
You my deliver or mail legible copies of the docunents or produce things requested
this subpoena, together with the certificate of cu,~liance, to the party making thi[
request at the address listed 'above. You have the right to seek in advance the rea~onabl~
cost of preoa~ng the copies ou producing the things sought.
If you fail to produce the docuaents or things required by this subpoena within twenty
(,20) days after its service, the party serving 'thin subpoena may seek a court orde,'
u:~,~elling you to cc~ly with it.
THIS SU~POENAWAS ISSUED ATT HE RECXJESTOFTHEFOLLOWINGPERSON:
NAME: ~VIN MCNAMARA, ESQ
ADORESS:
305 ~ ~RC:,"P ~T 6TH FLOOR
TELEPHONE:
SUPREPE COURT ID #
A1-FORNEY FOR:
HARRISBURG, PA 17108
~215-335-3212
M284575-12
03/~/02
DAT~:
DEFENDANT
Seal of the Court
BY TiE COL~T:
Prothonotary/Gqe~lk, Civil Oivisio~
(Eff.
ADDENDUM TO SUBPOENA
SWINTOSKY
VS.
WEIS MARKETS INC
No. 015~0
CUSTODIAi~ OF RECORDS FOR: CARJ~ISLE HOSP
Any and all hospital records, including microfilm, microfiche
emergency room reports, x-ray reports, out-patient records physical
therapy records, and any other information pertaining to:
DATE
NAME: SHAWN J. SWINTOSKY
ADDRESS: 216 HASTINGS ST JOHNSTOWN PA
OF BIRTH: 03/26/75
SSAN: 196544333
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ] RECORDS AREAFFACHEDHERETO:I hereby certify as custodian of
records that, to the best of my knowledge{ information and
belief all documents or things above mentioned have been produced.
[ ]
NODOCUMENFSAVA~LABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-12
Authorized signature for
CARLISLE HOSP
*** SIGN AND RETURN THIS PAGE ***
C~TH OF pI~VANIA
SWINTOSKY :
Vs. : Fi le No.
WEIS MARKETS INC :
01570
TO:
SUBPOENA TO PRO(DO(DE DOCLI'IENTS OR lq'liNGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
CARLISLE IMAGING ASSOCS, 101 NOBLE BLVD STE 104,
CARLISLE PA 17013-010
(Name of Person or Entity)
within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the fol lowing docu~ent.~ or thing :
at
MEDICAL LEGAL REPRODUCTIONS(A~s~940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the doccrnents or produce things requested b'..
this subpoena, together with the certificate of cu,~]iance, to the party making thi[
request at the address listed above. You have the right to seek in advance the reasonable
cost of prepar{ng the cop~es or producing the things sought.
If you fail to produce the documents or things required by this subpoena within twent'..
(20) days after its service, the party serving thi-~ subpoena may seek a court orde.-
c~,~elling you to oa,~ly with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
KEVIN MCNAMARA, ESQ
ADORESS:
305 I; ~.~.C:;T ST 6TH FLOOR
TELEPHONE:
SUPREME COURT ID ~
AI-I'ORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
DEFENDANT
M284575-13
03/09/02
DATE:
~eal of the Court
BY ~ (X)URT:
Prothon~tar~/C~/erk, Civil Division
(Elf. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 0157~
CUSTODIAN OF RECORDS FOR: CARLISLE WAGING ASSOCS
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY. OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HA~TINGS ST JOHNSTOWN PA
03/26/?5
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ] RECOPUDSAREATTACHEDHERETO:I hereby certify as custodian of
records that, to the best of my knowledge~ information and
belief all documents or things above mentioned have been produced.
[ ]
NODOCUMENTSAVA]LABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-13
Authorized signature for
CARLISLE IMAGING ASSOCS
*** SIGN AND RETURN THIS PAGE ***
~NWEALTH OF p~NSYLVANIA
SWINTOSKY :
:
Vs. : Fi le No.
WEIS MARKETS INC :
0157f0
TO:
SUBPOENA TO PEO[XJCE ~NTS OR THINGS
FOR D ISOOVERY PURSUANT TO RULE 4009.22
DR WILLIAM BEUTLER, C/O PENNA SPINE INST, 805 SIR THOMAS CT
HARRISBURG PA 17109
(Name of Pepson o~ Entity)
Within twenty (20) days afte~ sepvice of this subpoena, you ape o~deped by the court to
produce the following doctrnents oc thi~
MEDICAL LEOAL REPRODUCTIONS(A~$s~940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the docm~nents or produce things requested
this subpoena, together with the certificate of co,eliance, to the party making thiz
request at the address listed above. You have the right to seek in advance the rea~onabI~
cost of preparing the copies or producing the things sought.
If you fail to prc~uce the docunents or things required by this subpoena within twenty
(20) days after its service, the party serving 'thin subpoena may seek a court orde.'
oa,welling you to co,ely with it.
THIS SLSPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: KEVIN MCNAMAPJ%, ESQ
AD(AqESS: 305 ~'; ..... ~..v..m~ ~°m~ 6TH FLOOR
TELEPHONE:
SUPREME CO JRT ID #
ATTORNEY FOR:
[{ARRISBURG, PA 17108
215-335-3212
M284575-14
03/07/02
DATE:
DEFENDANT
Seal of the Cc~rt
BY THE (XDURT:
Prothonotapy/(~l~r~, Civil Division
-- / / Deputy
(Eff. 1/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 0157D
CUSTODIAN OF RECORDS FOR: DR WILLIAM BEUTLER
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TOANY EXAMINATION OR TREATMENT RENDERED TO:
DATE
NAME: SHAWN J SWINTOSKY
ADDRESS: 216 H3kSTINGS ST JOHlqSTOWN PA
OF BIRTH: 03/26/75
SSAN: 196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
] RECORDS AREATTACHED HERETO:I hereby certify as custodian of
records that, to the best of my knowledge~ information and
belief all documents or things above mentioned have been produced.
£ ]
NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS
( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-14
Authorized signature for
DR WILLIAM BEUTLER
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
Vs.
WEIS MARKETS INC
CO~DNW~L.. TH OF p~SYLVANIA
O0t~iTY OF CU~~
File No.
OlS?O
SUBPOENA TO PROOtlCE DOCtt~ENTS OR TH I
FOR DISODVERY PURSUANT TO RULE 4009.22
TO:
DR DANIEL CHESS, C/O CARLISLE HOSP PAIN CTR, 7 SPRINT DR
O3~RLI~LE PA 17013
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you a~e ordered by the court to
produce the fol lowin~ docu~eot.~ or thir
'on 1 ngs:
SEE
at
MEDICAL LEGAL REPRODUCTIONS(,Ad~s~940 DISSTON ST., PHILA., PA
You tomy deliver or mail legible copies of the ~ts o~ produce things requested
this subpoena, together with the certificate of co','~lience, to the party making thi[
request at the address listed 'above. You have the right to seek in advance the rea~onabl~
cost of preparing the copies or producing the things sought.
If you fail to produce the doc~xnents or things required by this subpoena within twenty.
(20) days afte~ its service, the party serving 'thin subpoena may seek a court orde.'
o.,,~elling yo~ to o~',$~ly with it.
THIS SUBPOENA WAS I SSUEDATTHE RE.JEST OFT HE FOLLOW INGPERSON:
NAME: KEVIN MCNAMARA, ESQ
ADDRESS:
305 ~ ~ROL'T ET 6TH FLOOR
TELEPHONE:
SUPRI~E COURT ID #
A~-FORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-15
03/0 ~/02
DATE:
DEFENDANT
[eal of the Court
BY THE COURT:
Prothonota~y~l~r~k, Civil Division
(Eff. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 015~0
CUSTODIAN OF RECORDS FOR: DR DANIEL CHESS
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME: SHAWN J SWINTOSKY
ADDRESS~ 216 HASTINGS ST JOHNSTOWN PA
DATE OF BIRTH: 03/26/75
SSAN: 196544333
CERTWIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ] RECORDS ARE ATTACHED HERETO:I hereby certify as custodian of
rec?rds that, to the best of my knowledge, information and
belief all dOcuments or things above mentioned have been produced.
[ ]
NODOCUMENTSAVAILABLR:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located(CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS
( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-15
Authorized signature for
DR DANIEL CHESS
*** SIGN AND RETURN THIS PAGE ***
COMMONWEALTH OF p~YLVANIA
COUNTY OF ~
SWINTOSKY :
Vs. : File No,
WEIS MARKETS INC :
0157~
SUBPOENA TO PRODUCE DCCUMENTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
DR ROY WARREN, C/O UPMC LEE PEG-CHRIS LAROSSE, 320 MAIN ST
JOHNSTOWN PA 15901
(N~e of Person o~ Entity)
within twenty (20) days after service of this subpoena, you are o~dered by the court to
produce the following doc~rnent,~ or things:
SEE ATTACIiED ADDENDUM
MEDICAL LEGAL ~EPRODOCTIONS(,A .J~N~$s~t940 DISSTON ST., PHILA., PA
You may deliver or mail legible copies of the doct~nts or produce things requested
this subpoena, together with the certificate of ccmpliance, to the party making thi[
request at the address listed 'above. You have the right to seek in advance the rea~,onabl~
cost of prepa~ing 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 thin :~ubpoena may seek a court orde.'
c~mDellin9 you to c~,oly with it.
THIS SUBPOENA WAS ISSUED AT THE REQIJEST OF THE FOLLONING PERSON:
NAME: KEVIN MCNAMARA, ESQ
ADORESS:__ 305 I,~ ~ROI.'T ST 6TH FLOOR
TELEPHONE:
COURT
ATTORNEY FOR:
I{ARRISBURG, PA 17108
215-335-3212
M284575-16
03/0 ?/02
DATE:
DEFENDANT
Seal of the Oo~rt
BY ~ COURT:
ProthonotaryyC l~m"k,
Civil Divisio~
Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 0157D
CUSTODIAN OF RECORDS FOR: DR ROY WARREN
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ~ EXAMINATION OR TREATMENT RENDERED TO:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAW-N J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ] RECORDS AREATTACHED HERETO:I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ]
NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XP~AYS have been destroyed
Date
CUMBERLAND
M284575-16
Authorized signature for
DR ROY WARREN
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
Vs.
WEIS MARKETS INC
C~TH OF pI~qNSYLVANIA
C0OW~Y OF ~
File No.
015~0
SUBPOENA TO PROOUCE DOCUMENTS OR TH I FIGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
DR JASON LITTON, C/O ORTHO INST, 875 POPLAR CHURCH RD
CAMP HILL PA 17011
(Nmme of Parso~ o~ Entity)
Within twenty (20) days efte~ sarvice of this subpoena, you a~e o~de~ed by the c~rt to
price the fo11~i~ ~t~ ~ ~ings:
SEE
at
MEDICAL LEGAL REPRODUCTIONS~N~s)4940 DISSTON ST., PHILA., PA
Yo~ may deliver c~ mail legible cooies of the documents o~ produce things requested
this subpoena, togethe~ with the certificate of c~,~lience, to the party making thi[
request at the address listed above. You have the right to seek in advance the rea~onabl~
cost of preparing the copies or producing the things sought.
If you fail to produce the documents o~ things required by this subpoena within twenty.
(20) days after its sarvlce, the party serving thi-~ subpoena may seek a court orde.'
~,~l~ellincJ you to co,~ly with it.
THIS SUbPOENA WAS ISSUED ATTHE REQUIESTOFTHE FOLLONINGPERSON:
NAME: KEVIN MCNAMARA, ESQ
AD0~ESS:
305 ~ ~RO~ ST 6TH FLOOR
TELEPHONE:
SUIPREI~ CO JRT ID #
A'rFORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-17
03/09/02
DAT~:
DEFENDANT
Seal of the
(Eff. 7'/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 015~0
CUSTODIAN OF RECORDS FOR: DR JASON Lr[~ON
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
DATE
NAME:
ADDRESS:
OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 F~STINGS ST JOHNSTOWN PA
o~/~/7s
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ]
RECORDSAREAFFACHEDHERETO:I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ]
NO DOCUMENTS AVA~LABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS
( ) RECORDS / XEAYS have been destroyed
Date
CUMBERLAND
M284575-17
Authorized signature for
DR JASON LITTON
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
Vs.
WEIS MARKETS INC
CO~949NWEALTH OF p51~%hqYLVANIA
File No.
015%0
SUBPOENA TO PROOUCE D(X~LI'IENTS OR TH I NGS
FOR D I SCOVERY PURSUANT TO RULE 4009.22
TO:
CUNAMUTUAL INS CO,
~T~I~? WAYR PATZNER.
5910 MINERAL POINT RD, MADISON WI 53705
GEN CO
(Name of Person o~ Entity)
Within twenty (20) days afte~ service of this subpoena, you a~e o~de~ed by the court to
m-oduce the following docunent.~ o~ things:____
SEE ATTACHED ADDENDUN
M~DICAL LEGAL REPRODUCTIONS(,Ad~N~ss~940 DISSTON ST., PHILA., PA
You may delive~ or mail legible copies of the documents pc produce things requested
this subpoena, togethe~ with the certificate of cu,~liance, to the party making thiz
request at the address listed 'above. You have the right to seek in advance the rea~onabl~
cost of preparing the copies or producing the things sought.
If you fail to prc~duce the docuT~nts c~ things required by this subpoena within twenty
(20) days afte~ its se~vlce, the party serving 'thin subpoena may seek a court ocde.'
o~Dellir~3 you to co,~ly with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: ~'I~.VIN MCN~'~RA, ESQ
ADORE,SS:
305 ;; ~-C~ CT 6TH FLOOR
TELEPHONE:
SUPRE)VE COURT ID ~
A-~FORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-18
03/D~/02
DATE:
DEFENDANT
Seal of the Oourt
BY T~ COURT:
protl~Dr~tary};Cl~k, Civil Division
DeDuty
(Eff. 7'/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
VS.
WEIS MARKETS INC
No.
CUSTODI/LN OF RECORDS FOR: C~A ~tr~AL [NS CO
ANY AND ALL OF PLAINTIFF'S RECORDS, APPLICATIONS, DISBURSEMENTS,
CORRESPONDENCE, REGARDING PERSONAL LOAN, CERTIFICATE NO. DD857889.
PERTAINING TO:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ] RECORDSAF~EATTACHEDHERETO:I hereby certify as custodian of
records that, to the best ~f my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ]
NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-18
Authorized signature for
CLINAMUTUAL INS CO
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
Vs.
WEIS MARKETS INC
~NWEALTH OF p~SYLVANIA
COUNTY OF ~
: File No.
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
DR WILLIS WILLARD III, C/O DR HUFF, 49 BROOKWOOD AVE
P. ART,T~Lg PA 17013
(Name of Person or Entity)
within twenty (20) days afte~ service of this subpoena, yo~ a~e o~de~ed by the court to
price the foll~i~ ~t~ ~ ~ings: ~~
SEE DE UM
at
MEDICAL LEGAL REPRODUCTIONS~A~O~ss~940 DISSTON ST., PHILA., PA
Yo~ may deliver or.il legible co~ies of the ok~nts or proo~ce things requested bt
this subpoena, together with the certificate of c~,~liance, to the p~ty ~king this
request at the address listed ~ve. Y~ have the ri~t to s~k in advice the reason~le
cost of prepping the ~ies or D~ucin9 the things s~ght.
If you fail to produce the documents or things required by this subpoena within twenty
(20) days after its service, the party serving Chin subpoena may seek a court orde.-
towelling you to cu,~ly with it.
TH I S SUBPOENA WAS
NAME:
ADORESS:
ISSUED AT ~ RE(iUEST O~ THE FOLLOWING PERSON:
KEVIN MCNA~A, ESQ
~v~ 2~ ....... 6TH FLOOR
TELEPHONE:
SUPREPE COURT ID #
A]-FORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-19
03/D~/02
DATE:
DEFENDANT
seal of the Court
BY ~
Proth~-~>ter4y/~lerk, Civil Division
~ / Oeputy
(Elf. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
VS.
WEIS MARKETS
INC
NO. 01575
CUSTODIAN OF RECORDS FOR: DR V~LLIS V~LLARD ~/
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
ANY AND ALL RECORDS OF DR WILLARD.
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ]
RECORDS AREATTACHEDHERETO:I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
£ ]
NODOCUMENTSAVA1LABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-19
Authorized signature for
DR WILLIS WILLARD III
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
VS.
WEIS MARKETS INC
~TH OF p]]~YLVANIA
O73N~Y OF ~
: File No.
01570
SUBPOENA TO PROOUCE DOCUMENTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
CONEMAUGH MEM HOSP, 1086 FRANKLIN ST, JOHNSTOWN PA 15905-4398
ATTN: MEDICAL RECORDS DEPT
(Name of Person or Entity)
within twenty (20) days after service of this subpoena, you a~e ordered by the court to
produce the followincj doc~nent~ or things.
SEE
at
MEDICAL LEQAL REPRODUCTIONS~AuTu,~Ss~940 DISSTON ST., PHILA., PA
YOU may deliver or mail legible cooies of the doct~nents or produce things requested
this subpoena, together with the certificate of cu,uliance, to the party making thi~
request at the address listed above. You have the right to seek in advance the reasonable
cost of preparing the copies or producing the things sought.
If you fail to produce the doctments or things required by this subpoena within twenty
(20) days after its service, the party serving thin subpoena may seek a court orde.'
o.,,~allin9 you to oa,~ly with it.
THIS ~SUBPOENA WAS ISS%ED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: KEVIN MCNAMARA, ESQ
ADORESS: 305..~ ~m..~.~ -~m. 6TH FLOOR
TELEPHONE:
SLIPREME COdRT ID ~t
ATTORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-20
o3/ /o2
DATE:
DEFENDANT
Keal of the Court
BY THE COURT:
Prothonotar~/dlerk, Civil Division
P / Deputy
(Elf. 1/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS
INC
NO. 015~0
CUSTODIAN OF RECORDS FOR: CONEMAUGH MEM HOSP
Any and all hospital records, including microfilm, microfiche
emergency room reports, x-ray r~ports, ?ut-patient records physical
therapy records, and any other information pertaining to:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOPINSTOWN PA
03/26/75
196544333
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ] RECORDS AREATTACHEDHERETO:I hereby certify as custodian of
records that, to the best'of my knowledge, information and
belief all documents or things above mentioned have been produced.
] NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
· has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-20
Authorized signature for
CONEMAUGH MEM HOSP
*** SIGN AND RETURN THIS PAGE ***
CO--TH OF pfI~VANIA
OOUNTY OF O3~
SWINTOSKY :
Vs. : File No.
:
WEIS MARKETS INC :
0157~
TO:
SUBPOENA TO PROOUCE DOOJMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
DR JAMES RIDELLA, 1111 FRANKLIN ST, JOHNSTOWN PA 15905
(Name of Person or Entity)
Within twenty (20) days after service of this sub0oena, you a~e ordered by the court to
produce the fol 1owin~ docunent.~ or thir
at
MEDICAL LEGAL REPRODUCTIONS(,A~N~s)4940 DISSTON ST., PHILA., PA
Yc~ may deliver or mail legible copies of the c~nts or produce things requested
this subpoena, together with the certificate of cu,~liance, to the party making
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 doctrnents or things required by this subpoena within twenty
(,20) days after its service, the party serving thi-~ subpoena may seek a court orde.-
o.,,~elling you to oa,~ly with it.
THIS SL~POENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: KEVIN MCNAMARA, ESQ
ADO~ESS:
305 :: URONT ST 6TH FLOOR
TELEPHONE:
SUPRE~E CO. JRT I D ~
A'~'ORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-21
03/d ~/02
DATE:
DEFENDANT
Seal of the Court
BY ~ COURT:
Protho~otary/~l~'k, Ci¥il Division
--~~-'~ Deputy
(Elf. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 0157;0
CUSTODIAN OF RECORDS FOR: DR JA_MES R/DELLA
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
DATE
NAME:
ADDRESS:
OF BIRTH:
SSAiq:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of
records that, to the best of my knowledge{ information and
belief all documents or things above mentioned have been produced.
[ ]
NO DOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-21
Authorized signature for
DR JAMES RIDELLA
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
VS.
WEIS MARKETS INC
~TH OF pI~NSYLVANIA
: File No.
01570
TO:
SUBPOENA TO PROOLJCE [XlX3.JHENTS OR TH I NOS
FOR DISCOVERY PURSUANT TO RULE 4009.22
KMART PHARMACY, 1181 WALNUT BOTTOM RD, CARLISLE PA 17013
(Name of Person o~ Entity)
within twenty (20) days afte~ service of this subpoena, you are o~de~ed by the c~rt to
pr~uce the foll~i~ ~t~ ~ things:
SEE
at
MEDICAL LEQAL REPRODUCTIONS(AJu,W~s~940 DZSSTON ST., PEILA., PA
You may deliver or mail legible copies of the doccrnents or produce things requested
this sub~m~ena, togethe~ with the certificate of c~,~liance, to the party making this
request at the address listed 'above. You have the right to seek in advamce the rea~onabl~
cost of preparing the cc%oies or producing the things sought.
If you fail to produce the doctmnents or things required by this subpoena within twenty
(,20) days after its service, the party serving 'thin subpoena may seek a court
cc~Dell~ng you to Cu,~ly with it.
THIS SL~3POENA WAS ISSUED AT THE REQUEST OF THE FOLLCWING PERSON:
NAME: KEVIN MCNAMA~A, ESQ
ADO~ESS:
, 305 ~',~ ~.~.OL~T ET 6TH FLOOR
TELEPHONE:
SUPREPI5 CCURT ID ~__
A~-FORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-22
03/0~/02
OATE:
DEFENDANT
Seal of the Court
BY THE C~T:
Prothonota~y/~lerk, Civil Divisio~
· / Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 015~0
CUSTODIAN OF RECORDS FOR: KMART PHA1ANIACY
ANY AND ALL PHARbL~CEUTICAL RECORDS.
PERTAINING TO:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ] RECORDS AREATTACHED HERETO:I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ]
NO DOCUMENTS AVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-22
Authorized signature for
KMART PHARMACY
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
VS.
WEIS MARKETS INC
C~TH OF p~SYLVANIA
COUNTY OF CU~~/~%~a)
File No.
0157/0
TO:
SI.~POENA TO PROOUCE DOCUHENTS OR TH I N(~
FOR DISOOVERY PURSUANT TO RULE 4009.22
CO~ GEN OSTEO HOSP, 4300 LONI)ONDERRY RD, FJkRRISBURG PA 17109
ATTN: MEDICAL RECORDS DEPT
(Name of Person o~ Entity)
within twenty (20) days afte~ service of this subpoena, you a~e ocde~ed by the court to
pcoduce the followin~ doc~nent~ o~ things:
SEE ATT ITHEII [])
MEDICAL LEGAL I~EPRODUCTIONS~AuTu~N~s~940 DISSTON ST., PHILA., PA
Yo~ may deliver o~ mail legible copies of the documents o~ produce things requested
this sub~ena, together with the certificate of cu,wliance, to the party making thiz
request at the address listed above. You have the ri~nt to seek in advance the rea~onabl~
cost of preoaring the copies or producing the things sought.
If you fail to produce the documents o~ things required by this subpoena within twenty
(20) days altec its se~vlce, the pa~ty serving 'thi~ s~a~y seek a ~rt ~de.-
~,~ell~ y~ ~ ~,~ly with it.
THIS SUt3POENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
NAME: KEVIN MCNANARA, ESQ
ADO~ESS:
~ ~, ~,~,m om 6TH FLOOR
TELEPHONE:
SUPREPE CO JRT tD ~
A'rFORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
M284575-23
o3/ /02
DATE:
DEFENDANT
Seal of the Oo~rt
BY THE OOURT:
Prothonota~y/(~l~, Civil Division
' ' Deputy
(Elf. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
VS.
WEIS MARKETS INC
No. 01590
CUSTODIAIq OF RECORDS FOR: CONtiGEN OSTEO HOSP
Any and all hospital records, including microfilm, microfiche
emergency room reports, x-ray r~ports, out-patient.records physical
therapy records, and any other information pertaining to:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 F~gTINGS ST JOHNSTOWN PA
03/26/75
196544333
ALL FEES MUST BE APPROVED PRIOR TO RECORDS BEING FORWARDED.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ]
RECORDS AREATTACHEDHERETO:I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ]
NO DOCUMENTS AWAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-PAYS
( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-23
Authorized signature for
COMM GEN OSTEO HOSP
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
Vs.
WEIS MARKETS INC
C~TH OF pS~qSYLVANTA
No.
0157~D
SUBPOENA TO PRCOUCE DOOJHE~S OR TH INC~
FOR DISCOVERY PURSUANT TO RULE 4009.2?
PA HIGHER EDUC ASSIS ASSN, 29 N COLGATE, CARLISLE PA 17013
TO: ATT~: PR~qONNEL DEPARTMENT
(Name of Person o~ Entity)
Within twenty (20) days afte~ service of this subpoena, you are o~de~ed by the court to
produce the following document.~ o~ thir
MEDICAL LEGAL REPRODUCTIONS(,A~N~s~940 DISSTON ST., PHILA., PA
YOU may deliver c~ mail legible copies of the docunents c~ produce things requested
this subpoena, togethe~ with the certificate of co,~lience, to the party making thi~
request at the address listed above. You have the right to seek in advance the reasonable
cost of preparing the copies or producing the things sought.
If you fail to produce the doct~nents o~ things required by this subpoena within twenty.
(20) days afte~ its service, the party serving 'thin subpoena may seek a court orde,-
ocm~elling you to oa',~ly with it.
THISSUBPOENAWA$ ISSUED AT THE REQUEST OFTHEFOLLO,','INGPERSON:
NAME: K~VIN MCNAMARA, ESQ
ADDRESS:
305 II UROI~ CT 6TH FLOOR
TELEPHONE:
sOPnE E COURT
ATTORNEY F~:
HARRISBURG, PA 17108
215-335-3212
M284575-24
03/0~/02
DATE:
. DEFENDD/qT
Keal of the Court
BY TH5 COURT:
Prothonotary/~le~k, Civil Division
/ ~ D~puty
(Elf. ~/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS
INC
No. 015~0
CUSTODIAN OF RECORDS FOR: PA HIGHER EDUC ASSIS ASSN
ANY EMPLOYMENT APPLICATIONS, EAR~INGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ~ AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORK)4EN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, DR~-D ANY OTHER INFORMATION PERTAINING TO:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE,
RECORD CUSTODIAN COMPLETE AND RETURN
[ ] RECORDS AREATTACHED HERETO:I hereby certify as custodian of
records that, to the best ?f my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ]
NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-P~AYS
( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-24
Authorized signature for
PA HIGHER EDUC ASSIS ASSN
*** SIGN AND RETURN THIS PAGE ***
SWINTOSKY
Vs.
WEIS MARKETS INC
~TH OF P]~9~fLVANIA
: File No.
0157;0
SUBPOENA TO PROOUCE DOOJMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
CENTIMARK CORP, 1400 HUMMEL AVE, LEMOYI~ PA 17043
TO: ATTN: PERSONNEL DEPARTMENT
(Name of Person or Entity)
within twenty (20) days after service of this subpoena, you a~e ordered by the c~rt to
price the fo11~i~ ~t~ ~ things:
SEE
MEDICAL LEOAL REPRODUCTIONS,.?w~._4940 DISSTON ST., PHILA., PA
You raay deliver or mail legible copies of the doc~nents or produce things requested
this subpoena, togethe~ with the certificate of cu,~liance, to the party nmking thiz
request at the address listed above. You have the right to seek in advance the rea~onab]~
cost of preparing the copies or producing the things sought.
If you fail to produce the doctrnents or things required by this subpoena within twenty
(20) days after its service, the party serving thi.~ subpoena may seek a court orde.'
o.,,~elling you to c~ly with it.
THIS S~JBPOENA WAS ISSUED AT THE REGOEST OF THE FOLLOWING PERSON:
NAMe: KEVIN MCNAF~d~A, ESQ
ADORESS:
305 ~: URO:;T ~T 6TH FLOOR
TELEPHONE:
SUPREPE COURT ID ~
ATTORNEY FOR:
HA~ISBURG, PA 17108
215-335-3212
M284575-25
03/0~/02
DATE:
DEFENDANT
Seal of the
BY THE ODURT:
Prothc~otery/~e~k, Civil Oivisioo
(Eff. 1/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 0157~
CUSTODIAN OF RECORDS FOR: CESrlTMARK CORP
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: SHAWN J SWINTOSKY
ADDRESS: 216 HASTINGS ST JOHNSTOWN PA
DATE OF BIRTH: 03/26/75
SSAN: 196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ]
RECORDSAREATTACHED HERETO:I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
[ ]
NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-HAYS ( ) RECORDS / XRAYS have been destroyed
Date
~uMBERLAND
M284575-25
Authorized signature for
CENTIMARK CORP
*** SIGN AND RETURN THIS PAGE ***
C~NWEALTH OF p~%~SYLVANIA
SWINTOSKY :
Vs. : File No.
WEIS MARKETS INC :
015~0
TO:
SUBPOENA TO PROEX.ICE ~NTS OR TH I NGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
EBI LP, 100 INERPLACE PKWY BOX 346, PARSIPPANY NJ 07054
ATTN: PERSONNEL DEPARTMENT
(N~me of Person o~ Entity)
Within twenty (20) days afte~ service of this subpoena, yo~ are omdered by the c~rt to
price the foll~i~ ~t~ ~ thin~s:
SEE A'Iq~AC~D ~DENDUM
at
MEDICAL LEGAL REPRODUCTIONS(,Ad~s~940 DISSTON ST., PEILA., PA
Yo~ may deliver o~ mail legible co~ies of the doc~oents o~ produce things requested b~
this sub~ena, together With the c~tificate of ~.~li~ce. to the p~ty ~king thiz
request at the addmess listed ~ve. Y~ have the r i~t to s~k in advice the rea~onebl~
cost of prep~in~ [he :ies or producing the things s~ght.
If y~ fail to pr~uce the ~nts ~ thin~s re~ired by ~is sub~a within twenty
(20) days aft~ its s~vlce, the p~ty serving thin s~a ~y seek a ~rt ~de.-
~elli~ y~ to ~ly with it.
~IS ~ WAS I~D AT ~E RE. ST ~ ~E F~L~I~ PER~:
KEVIN MCN~A, ESQ
305 ~ PRO}~ ST 6~ FLOOR
TELEPHONE:
SUPRE]~ COURT ID #
ATTORNEY FOR:
HARRISBURG, FA 17108
215-335-3212
M284575-26
03/~ ~/02
DATE:
DEFENDANT
Seal of the Oc~rt
BY THE CC~3RT:
Prot~notary~/C~k, Civil Division
/ ' Deity
(£ff. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS INC
No. 01590
CUSTODIAN OF RECORDS FOR: EBI LP
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME: SHAWN J SWINTOSKY
ADDRESS: 216 HASTINGS ST JOHNSTOWN PA
DATE OF BIRTH: 03/26/75
SSAN: 196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ]
] RECORDSAREATTACHED HERETO:I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS
( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-26
Authorized signature for
EBI LP
*** SIGN AND RETURN THIS PAGE ***
· OgM~DNWEALTH OF p~%~SYLVANIA
SWINTOSKY
VS.
WEIS MARKETS INC
File No.
0157~
SUBPOENA TO PROOtlC~ DQO. I'IENTS C~ TH I NQS
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
FISHERS ROOFING, RR 2, LOYSVILLE PA 17047-9802
ATTN~ PRR~ONNEL DEPARTMENT
(Name of Person o~ Entity)
Within twenty (20) days afte~ sarvice of this subpoena, you are o~de~ed by the court to
I~oduce the fol lowing do<~znent.~ o~ thi
at
MEDICAL LEGAL REPRODUCTIONS~A~0~$s~940 DISSTON ST., PHILA., PA
You may deliver o~ mail legible copies of the docunents o~ produce things requested bt
this subpoena, togethe~ with the certificate of co','~liance, to the party making this
request at the address listed 'above. You have the right to seek in advance the rea~onabl~
cost of preparing the copies or producing the things sought.
If you fail to produce the doctrnents o~ things required by this subpoena within twenty
(20) days &fte~ its service, the party serving thi-~ s~ubpoena may seek a court orde,'
COToelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE RE(~LIEST OF THE FOLLOWING PERSON:
NAME: KEVIN MCNAMARA, ESQ
305 i: F~.ONT ST 6TH FLOOR
TELEPHONE:
StJPRE~E COURT ID ~.__
ATTORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
DEFENDANT
M284575-27
03/~}~/02
DAT~:
Seal of the Court
BY ~ COURT:
Prothonota~y~O'l~k, Civil Divisien
· ~ Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS
INC
No. 0157~
CUSTODIAN OF RECORDS FOR: ~SHERS ROOFING
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ANY OTHER INFORMATION PERTAINING TO:
NAME:
ADDRESS:
DATE OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ]
[ ]
RECORDSAP~EATTACHED HERETO:I hereby certify as custodian of
records that, to the best of my knowledge, information and
belief all documents or things above mentioned have been produced.
NO DOCUMENTS AVAiLABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
· ( ) X-RAYS
( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-27
Authorized signature for
FISHERS ROOFING
*** SIGN AND RETURN THIS PAGE ***
· C04,~,~D~,~.L'i~{ OF p~SYLVANTA
SWINTOSKY
VS.
WEIS MARKETS INC
C0~r~Y OF ~
: File No.
0157~0
StJ~POENA TO PEOOUCE IiXDC~NTS OR TH I N(3S
FOR DISCOVERY PURSUANT TO RULE 4009.22
TO:
SLI LIGHTING PRODUCTS, 122 E LAUREL ST, MULLINS SC 29574
ATTN~ RMOG~NE BRITT
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to
produce the following doctrnent.~ or things:~
SEE ATTACHED ADDENDUM
MEDICAL LEGAL REPRODUCTIONS(,A~,~Ss~940 DISSTON ST., PHILA., PA
You may deliver or mail legib]e cooies of the doctrnents or produce thinss requested bi
this subpoena, together with the certificate of cu,oliance, to the party making thi~
request at the address listed above. You have the right to seek in advance the reasonable
cost of preparing the co~ies or producing the things sought.
If you fail to produce the docunents or things required by this subpoena within twenty
(20) days after its ser¥1ce, the party serving 'this subpoena may seek a court orde.'
orJ,Oellin9 you to c~ly with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLCWING PERSON:
NAME: T~RVIN MCNiadV[ARA, ESQ
ADORESS:
3C5 i; I~RCI:T CT 6TH FLOOR
TELEPHONE:
SUPRE~ COURT ID"~
ATTORNEY FOR:
F~%RRISBURG, PA 17108
215-335-3212
M284575-28
03/D$/02
DATE:
DEFENDANT
Seat of the 0ourt
BY ~ COURT:
Prothonotary/~le~k, Civil oivisio~
/ / Deputy
(Eff. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
VS.
WEIS MARKETS INC
No. 01570
CUSTODIAN OF RECORDS FOR: SLI LIGHTING PRODUCTS
ANY EMPLOYMENT APPLICATIONS, EARNINGS, LEDGER SHEETS, TIME CARDS
REVIEWS, ATTENDANCE SHEETS, ANY AND ALL MEDICAL RECORDS AND REPORTS
AND PRE-EMPLOYMENT PHYSICALS, WORKMEN'S COMPENSATION CLAIMS MADE, ANY
W-2 WITHHOLDING TAX FORMS, AND ~ OTHER INFORMATION PERTAINING TO:
DATE
NAME:
ADDRESS:
OF BIRTH:
SSAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOHNSTOWN PA
03/26/75
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN COMPLETE AND RETURN
[ ] RECORDSAREATTACHEDHERETO:I hereby certify as custodian of
records that, to the best ~f my knowledge, information and
belief all documents or th~ngs above mentioned have been produced.
[ ]
NODOCUMENTSAVAILABLE:I hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS ( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-28
Authorized signature for
SLI LIGHTING PRODUCTS
*** SIGN AND RETURN THIS PAGE ***
C~NWEALTH OF pI~VANIA
SWINTOSKY
VS.
WEIS MARKETS INC
: File No.
0157/0
SUBPOENA TO PRODUCE D(XiLe~NTS OR TH I NGS
FOR DISOOVERY PURSUANT TO RULE 4009.22
TO:
WINDBER MED CTR,
WINBl~R PA 15963
DEAN ORNISH PROGRAM, 600 SUMMSET AVE
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you ere ordered by the court to
produce the following docunent~ or thir
SEE '9 TT DENDIT!
at
MEDICAL LEGAL REPRODUCTIONS(A~o~ss~940 DISSTON ST., PHILA., PA
You my deliver or mail legible copies of the doctrnents or produce things requested
this subpoena, together with the certificate of c~,'~liance, to the party making thi~
request at the address listed above. You have the right to seek in advance the rea~onabl~
cost of preparing the copies or producing the things sought.
If you fail to produce the docunents or things required by this subpoena within twenty
(20) days after its service, the party serving this subpoena may seek a court orde.'
o.~,~elling you to co~ply with it.
' THIS SUBPOENA WAS ISSLIED AT THE REQUEST OF THE FOLLOfllNG PERSON:
KEVIN MCNAlVL1LRA, ESQ
ADC~ESS:
305 .': ~RC.NT ~T 6TH FLOOR
TELEPHONE:
SUPREP1E COURT ID #
ATTORNEY FOR:
HARRISBURG, PA 17108
215-335-3212
DEFENDANT
M284575-29
03/D~/02
DATE:
Seal of the Oourt
BY THE CO~T:
Prothonotary/O~erl(, Ci¥i 1 Oivisio~
/ ' Deputy
(Elf. 7/97)
ADDENDUM TO SUBPOENA
SWINTOSKY
Vs.
WEIS MARKETS
INC
No. 0157~
CUSTODIAN OF RECORDS FOR: V~INDBERMED CTR
ANY AND ALL OFFICE RECORDS, INCLUDING NOTES, CORRESPONDENCE,
MEMORANDA, X-RAY REPORTS, HISTORY NOTES, INDEX CARDS AND ANY OTHER
INFORMATION RELATING TO ANY EXAMINATION OR TREATMENT RENDERED TO:
NAME:
ADDRESS:
DATE OF BIRTH:
S SAN:
SHAWN J SWINTOSKY
216 HASTINGS ST JOH/~STOWN PA
03/26/75
196544333
CERTIFIED PHOTOCOPIES WILL BE ACCEPTED IN LIEU OF YOUR PERSONAL APPEARANCE.
RECORD CUSTODIAN - COMPLETE AND RETURN
[ ]
[ ]
RECORDS AREATFACHED HERETO:I hereby certify as custodian of
records that, to the best ~f my knowledge{ information and
belief all documents or th~ngs above mentioned have been produced.
NODOCUMENTSAVAILABLE:i hereby certify that a thorough search
has been made and that no record of the following documents have
been located (CHECK THE APPROPRIATE BOX):
( ) RECORDS ( ) PATIENT BILLING
( ) X-RAYS
( ) RECORDS / XRAYS have been destroyed
Date
CUMBERLAND
M284575-29
Authorized signature for
WINDBER MED CTR
*** SIGN AND RETURN THIS PAGE ***
SHAWN SWINTOSKY :
V. :
WEIS MARKETS, INC. :
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND CO., PENNA.
CWIL ACTION - LAW
NO. 01-5710 CIVIL TERM
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that Plaintiffs Request for Production of Documents, Set No. 1I was
sent to counsel for Defendant by First Class United States Mail on the below date to the following
address:
Kevin C. McNamara, Esquire
Thomas, Thomas & Hafer, LLP
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108
Date:
Leal~ B. GraSi~, ]Esquir~ ~ -
Attorney I.D. No. 29176
Attorney for Plaimiff
SHAWN SWINTOSKY
V.
WEIS MARKETS, INC.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND CO., PENNA.
CIVIL ACTION - LAW
NO. 01-5710 CIVIL TERM
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the Notice of Deposition was sent by
First Class United States Mail to counsel for Defendant on the below date at the following address:
Kevin C. McNamara, Esquire
Thomas, Thomas & Haler, LLP
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108
Date:
Leah B. Graft,~Esqmre ~
Attomey I.D. No. 29176
Attorney for Plaintiff
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) (X) for JURY trial at the next term of civil court.
( ) for trial without a jury.
CAPTION OF CASE
(entire caption must be stated in full)
SHAWN SWINTOSKY,
(Plaintiff)
VS.
WEIS MARKETS, INC.,
(Defendants)
No. Civil 04-4q0" ol-ffTt/O
Date:
(check one)
(X) Civil Action - Law
( ) Appeal from Arbitration
( )
(other)
The trial list will be called on February 17, 2004
and
Trials commence on March 15, 2004
Pretrials will be held on February 25, 2004
(Briefs are due 5 days before pretrials.)
(The party listing this case for trial shall provide
forthwith a copy of the praecipe to all counsel,
pursuant to local Rule 214.1 .)
Indicate the attorney who will try case for the party who files this praecipe:
Kevin C. McNamara, Esquire
Indicate trial counsel for other parties if known:
Leah B. Graft, Esquire, for Plaintiff
This case is ready for trial.
Signed:
Ke~in C. McNamara, Esquire
Attorney for: Defendant
WEIS MARKETS, INC.
CERTIFICATE OF SERVICE
I, Rick Stains, Jr., a Paralegal for the law firm, Thomas, Thomas & Hafer, LLP, hereby certify
that a true and correct copy of the foregoing document was served on all counsel of record by depositing
the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, on the date set forth
below:
Leah B. Graff, Esquire
LAW OFFICES OF DALE E. ANSTINE, P.C.
Two West Market Street
P.O. Box 952
York, PA 17405
Attorney for Plaintiff
THOMAS, THOMAS & HAFER, LLP
By:
Rick Stains, Jr., P~l~al
SHAWN SWINTOSKY,
Plaintiff
WEIS MARKETS, INC.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01 -~,0.
CIVIL ACTION -- LAW
JURY TRIAL DEMANDED
To the Prothonotary:
Please Withdraw this case from trial, which was previously scheduled to commence on
March 15, 2004.
Respectfully submitted,
THOMA;~?fI~ OMAS & HAFER, LLP
Kevin C. McNamara, Esquire
I.D.#72668
305 North Front Street
Post Office Box 999
Harrisburg, PA 17108-0999
(717) 237-7132
Attorneys for Defendant
273593.1
I, Rick Stains, Jr., a Paralegal for the law finn Thomas, Thomas & Haler, LLP, hereby
certify that I have served a true and correct copy of the foregoing document on the following person
by placing same in the United States mail, postage prepaid, on date set forth below:
Leah B. Graff, Esquire
LAW OFFICES OF DALE E. ANSTINE, P.C.
Two West Market Street
P.O. Box 952
York, PA 17405
THOMAS, THOMAS & HAFER, LLP
Date:
Rick Stai~
273593.1
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)
(X) for JURY trial at the next term of civil court.
( ) for trial without a jury.
CAPTION OF CASE
(entire caption must be stated in full)
SHAWN SWINTOSKY,
(check one)
(X) Civil Action - Law
( ) Appeal from Arbitration
( )
(other)
(Plaintiff)
VS.
WEIS MARKETS, INC.,
(Defendants)
The trial list will be called on April 6, 2004
and
Trials commence on May 3, 2004
Pretrials will be held on April 14, 2004
(Briefs are due 5 days before pretrials.)
(The party listing this case for trial shall provide
forthwith a copy of the praecipe to all counsel,
pursuant to local Rule 214.1 .)
No. Civil
Indicate the attorney who will try case for the party who files this praecipe:
Kevin C. McNamara, Esquire
Indicate trial counsel for other parties if known:
Leah B. Graft, Esquire, for Plaintiff
Date:
This case is ready for trial.
Signed:
Kevin C. McNamara, Esquire
Attorney for: Defendant
WEIS MARKETS, INC.
CERTIFICATE OF SERVICE
I, Rick Stains, Jr., a Paralegal for the law firm, Thomas, Thomas & Hafer, LLP, hereby certify
that a true and correct copy of the foregoing document was served on all counsel of record by depositing
the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvania, on the date set forth
below:
Leah B. Graff, Esquire
LAW OFFICES OF DALE E. ANSTINE. P.C.
Two West Market Street
P.O. Box 952
York, PA 17405
Attorney for Plaintiff
271958.2
I/I '~
THOMAS, THOMAS & HAFER, LLP
Rick Stains, ~¥Paralega
SHAWN SWINTOSKY,
Plaintiff :
V.
WEIS MARKETS, INC., :
Defendant :
IN RE:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 01-5710 CIVIL TERM
PRETRIAL CONFERENCE
A pretrial conference was held before thai
Honorable Edward E. Guido, Judge, on Wednesday, Apf[~ 14¥?
2004 Present for the Plaintiff was Leah B. Graff, Esquire,
and present for the Defendant was Kevin C. McNamara,
Esquire.
This is a routine slip and fall case in which the
Plaintiff sustained back, neck, and s~oulder injuries~ Both
liability and damages are contested.
Neither party has any scheduling conflicts. They
estimate that the case will take two and one half to three
days to try.
Each party will be presenting video depositions.
The parties are directed to attempt to resolve any
objections on their own, and those objections that cannot be
resolved shall be submitted to the trial judge for
disposition. Prior to trial the parties shall submit a list
of those objections referencing the appropriate page numbers
to the trial judge.
The parties are continuing settlement
negotiations.
possibility.
Settlement is within the realm of
By the
Edward E. Guido, J.
Leah B. Graff, Esquire
For the Plaintiff
Kevin C. McNamara, Esquire
For the Defendant
Court Administrator
:lfh
SHAWN SWINTOSKY :
V. :
WEIS MARKETS, INC. :
1N THE COURT OF COMMON PLEAS
OF CUMBERLAND CO., PENNA.
CW[L ACTION - LAW
NO. 01-5710 CIVIL TERM
JURY TRIAL DEMANDED
PRAECIPE TO DISCONTINUE,
To The Prothonotary:
Please mark the above captioned action settled and satisfied.
Lea~h B. Graft, Esquire
Attorney I.D. No. 29176
Two West Market Street
P.O. Box 952
York, Pennsylvania 17405
(7171) 846-0606
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the within Praecipe was sent by First
21ass United States Mail to counsel for Defendant on the below date at the following address:
Kevin C. McNamara, Esquire
Thomas, Thomas & Hafer, LLP
305 North Front Street
P.O. Box 999
Harrisburg, PA 17108-0999
)ate: August 11, 2004
Lek B. Graft, Esqf~ire
Attorney I.D. No. 29176
Attorney for Plaintiff
2