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HomeMy WebLinkAbout07-1145r John F. Yaninek, Esquire METTE, EVANS & WOODSIDE 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - telephone (717) 236-1816 - facsimile jfyaninek@mette.com Attorneys for Plaintiff JEFFREY HOLLENBACH 3625 Elmerton Avenue Harrisburg, PA 17109 V. MARY STRICKLAND 76 Greenwood Circle Wormleysburg, PA 17043 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff(s). You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 239-3166 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTA. SI NO TIENE ABOGADO O SI NO TIENE EL D1NERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 John F. Yaninek, Esquire METTE, EVANS & WOODSIDE 3401 North Front Street P.O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - telephone (717) 236-1816 - facsimile jfyaninek@mette.com Attorneys for Plaintiff JEFFREY HOLLENBACH 3625 Elmerton Avenue Harrisburg, PA 17109 V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. //Y.S- L Uc-C `7 CIVIL ACTION - LAW MARY STRICKLAND 76 Greenwood Circle Wormleysburg, PA 17043 JURY TRIAL DEMANDED COMPLAINT AND NOW, comes the Plaintiff, JEFFREY HOLLENBACH, by and through his attorneys, Mette, Evans & Woodside, and files this Complaint against the Defendant and in support thereof avers as follows: 1. Plaintiff Jeffrey Hollenbach is an adult individual residing at 3625 Elmerton Avenue, Harrisburg, Dauphin County, PA 17109. 2. Defendant Marry Strickland is an adult individual residing at 76 Greenwood Circle, Wormleysburg, Cumberland County, PA 17043. 3. The accident hereinafter related, took place on or about September 29, 2005 at approximately 5:45 p.m. at or near the intersection of South Third Street and Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania. 4. At the aforesaid mentioned time and place, Plaintiff Jeffrey Hollenbach was operating a 2001 Ford SUV which was heading northbound on South Third Street and stopped at a red light at the intersection of South Third Street and Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania. At the aforesaid mentioned time and place, Defendant Mary Strickland was operating a 1997 Buick sedan traveling northbound on South Third Street, Lemoyne, Cumberland County, Pennsylvania. 6. At the aforesaid mentioned time and place, Defendant Mary Strickland, failed to timely notice Plaintiff s stopped vehicle and violently crashed into the rear of the vehicle operated by Plaintiff. 7. Defendant Mary Strickland advised the West Shore Regional Police Department that a cup of coffee had fallen in her car, she leaned over to pick it up and violently crashed into the rear of the vehicle operated by Plaintiff. 8. The negligent and/or reckless behavior of Defendant Mary Strickland caused the aforementioned accident with Plaintiff Jeffrey Hollenbach. 9. As a result of the accident, Plaintiff Jeffrey Hollenbach sustained serious and permanent injuries hereinafter described. 10. The negligence and/or recklessness of Defendant Mary Strickland consisted of the following: a. failure to notice Plaintiff's stopped vehicle and violently crashing into the rear of the vehicle; b. failing to stop within the assured clear distance; C. failing to keep alert and maintain a proper lookout for changes in road conditions and traffic; d. failing to prepare for and observe traffic control devices; and, e. not having her vehicle under control. 11. As a result of Defendant Mary Strickland's negligence, carelessness and/or recklessness, Plaintiff Jeffrey Hollenbach suffered serious, permanent and painful injuries and damages, including but not limited to: a. decompressive lumbar laminectomy surgery; b. surgery of the right supraclavicular neuroplasty of the brachial plexis; C. right carpal tunnel release surgery; d. chronic neck pain with pain and numbness radiating into bilateral shoulders, arms, wrists and hands; e. bilateral thoracic outlet syndrome; f. low back pain with pain and numbness radiating into bilateral legs and feet; g. chest pains; h. tachycardia; i. headaches; j. permanent scarring; k. past lost wages; 1. loss of future earning capacity; m. past medical bills; n. future medical bills; o. past and future pain and suffering; P. past and future loss of life's enjoyment; and q. embarrassment. 12. As a direct result of these injuries, Plaintiff Jeffrey Hollenbach underwent a variety of medical treatment, including numerous surgeries, trigger point injections, epidural steroid injections, physical therapy, diagnostic studies, and the taking of prescription medications for pain, inflammation, depression and anxiety. WHEREFORE, Plaintiff Jeffrey Hollenbach requests ruling in his favor and against Defendant in an amount in excess of $50,000 along with costs and other relief that the Court deems just. Respectfully submitted, METTE, EVANS & WOODSIDE By: J F. Yanin squire S . Ct. I.D. 5741 3401 North Front Street P. O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - Phone (717) 236-1816 - Fax Attorneys for Plaintiff Jeffrey Hollenbach Date: March 1, 2007 VERIFICATION I, JEFFREY HOLLENBACH, have read the foregoing Complaint and verify that the facts set forth herein are true and correct to the best of my knowledge, information and belief. To the extent that the foregoing document and/or its language is that of counsel, I have relied upon counsel in making this Verification. I understand that any false statements made herein are subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. DATED: Z /Z e C)4-? -- - JEFFREY HOLL NBACH 465308v1 rT" JEFFREY HOLLENBACH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 07-1145 V. MARY STRICKLAND, Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED ENTRY OF APPEARANCE Kindly enter our appearance on behalf of Defendant, Mary Strickland, in the above- captioned. Respectfully submitted, McKissock & Hoffman, P.C. By: .? B. g , I . D .:6818 La en Burnette, Esquire I.D. No.: 92412 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Dated: U? ,attorneys for Defendant, Mary Strickland .» CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Entry of Appearance upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 (Counsel for Plaintiff) McKissock & Hoffman, P.C. Dated: By: B. g a squire " `-? I. o.: 36818 L ren M. Burnette, Esquire I.D. No.: 92412 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Attorneys for Defendant, Mary Strickland ? o rr N 17? c3 r : C7 _ . n ,A JEFFREY HOLLENBACH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-1145 MARY STRICKLAND, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED STIPULATION AND NOW, comes John F. Yaninek, as counsel for the Plaintiff, and Lauren M. Burnette, as counsel for Defendant, and hereby stipulates to the following: 1. The language "including but not limited to" as contained in ¶11 of Plaintiffs' Complaint is hereby STRICKEN. Respectfully submitted, By: Anderson, Converse & Fennick, P.C. Bohn F. Yknil f ek, Esquire Attorney I.a.?lo.: 55741 Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 (717) 232-5000 McKissocK& Hoffman, P.C. By: Attorneys for Plaintiff Dated: 5,1) C/0--7 1B. Craig Black, Esquire Attorney I.D. No.: 36818 Lauren M. Burnette, Esquire Attorney I.D. No.: 92412 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Attorneys for Defendant, Mary Strickland Dated: 3 30 D .. CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Stipulation upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 North Front Street Harrisburg, PA 17110 (Counsel for Plaintiff) McKissock & Hoffman, P.C. By: 1 4 ?#_ B. Craig lack, Esquire Attorney I.D. No.: 36818 Lauren M. Burnette, Esquire Attorney I.D. No.: 92412 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Dated: 3 30 0 -? Attorneys for Defendant, Mary Strickland C'> r-4 O ?-{ •% w?? _ ?'ArJ - +? JEFFREY HOLLENBACH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-1145 MARY STRICKLAND, CIVIL ACTION - LAW Defendant JURY TRIAL DEMANDED To: Jeffrey Hollenbach c/o John F. Yaninek, Esquire Mette, Evans & Woodside 3401 North Front Street Harrisburg, PA 17110 You are hereby notified to plead to the enclosed New Matter pursuant to Pa.R.C.P. 1030 within 20 days from service hereof. DEFENDANT'S ANSWER AND NEW MATTER TO PLAINTIFF'S COMPLAINT AND NOW comes Defendant, Mary Strickland, by and through her attorneys, McKissock & Hoffman, P.C., who respectfully files the instant Answer and New Matter to Plaintiff's Complaint, and in support thereof avers as follows: 1. Denied. After reasonable investigation, Defendant is without sufficient knowledge and information to form a belief as to the truth of the averments in ¶1 of Plaintiff's Complaint, and as such, the same averments are denied. 2. Admitted. 3. Admitted in part, denied in part. The averments in ¶3 are admitted only to the extent that Plaintiff's reference to "the accident" relate to the contact between Plaintiff's vehicle and Defendant's vehicle which occurred near the intersection of South Third Street and Hummel Avenue in Lemoyne, Cumberland County, Pennsylvania. To the extent that Plaintiff's reference to "the accident" relates to any other events, said allegations are denied. 4. After reasonable investigation, Defendant is without sufficient knowledge and information to form a belief as to the truth of the averments in ¶4 of Plaintiff's Complaint, and as such the same averments are denied. 5. Admitted. 6. Admitted in part, denied in part. It is admitted that contact occurred between Plaintiff's vehicle and Defendant's vehicle. Plaintiff's characterization that Defendant failed to "timely notice" Plaintiff's vehicle is denied. By way of further response, Plaintiff's characterization that Defendant's vehicle "violently crashed" into Plaintiff's vehicle is specifically denied. 7. Admitted in part, denied in part. It is admitted that Defendant attempted to retrieve a fallen coffee cup in her vehicle. It is further admitted that contact occurred between Plaintiff's vehicle and Defendant's vehicle. Defendant specifically denies advising the West Shore Regional Police Department that she "violently crashed into the rear of the vehicle operated by Plaintiff', and as such, said averment is specifically denied. By way of further response, any characterization of the contact between the parties' vehicles as a "violent crash" is specifically denied. 8. The averments in 18 of Plaintiff's Complaint contain conclusions of law to which no response is required. To the extent a response is required, the same averments are denied and strict proof thereof is demanded at the time of trial. 9. After reasonable investigation, Defendant is without sufficient knowledge and information to form a belief as to the truth of the averments in ¶9 of Plaintiff's Complaint, and as such the same averments are denied. By way of further response, the averments in $9 of Plaintiff's Complaint contain conclusions of law to which no response is required. To the extent a response is required, the same averments are denied and strict proof thereof is demanded at the time of trial. 2 10. The averments in ¶10 of Plaintiff's Complaint, including all subparts, contain conclusions of law to which no response is required. To the extent a response is required, the same averments are denied, and strict proof thereof is demanded at the time of trial. 11. The averments in ¶11 of Plaintiff's Complaint, including all subparts, contain conclusions of law to which no response is required. To the extent a response is required, the same averments are denied in accordance with Pa.R.C.P. 1029(e), and strict proof thereof is demanded at the time of trial. 12. The averments in 112 of Plaintiff's Complaint, including all subparts, contain conclusions of law to which no response is required. To the extent a response is required, the same averments are denied, and strict proof thereof is demanded at the time of trial. WHEREFORE, Defendant Mary Strickland respectfully request that this Honorable Court enter judgment in her favor and dismiss Plaintiff's Complaint with prejudice, and further award her all such further relief as is just and proper. NEW MATTER 13. Paragraphs 1 through 12 are hereby incorporated by reference as though more fully set forth herein. 14. To the extent that facts developed during the course of discovery may implicate, Plaintiff's claims are barred, in whole or in part, by the provisions of Pennsylvania Motor Vehicle Responsibility Law. 15. To the extent that facts developed during the course of discovery may implicate, Plaintiff's injuries and losses, if any, were caused by persons or events outside the control of the Defendant. 16. To the extent that facts developed during the course of discovery may implicate, Plaintiff is barred by the doctrine of laches and/or unclean hands from the relief requested. 3 17. To the extent that facts developed during the course of discovery may implicate, Plaintiff is barred and/or limited by the provisions of the Pennsylvania Comparative Negligence Act, 42 P.C.S.A. § 4102. 18. To the extent that facts developed during the course of discovery may implicate, Plaintiff was contributorily negligent and/or assumed the risk of injury. 19. To the extent that facts developed during the course of discovery may implicate, the negligent acts and/or omissions of other individuals or entities constitutes an intervening or superseding cause of the injuries alleged to have been sustained by the Plaintiff. 20. Plaintiff's alleged injuries were caused by the acts and/or omissions of a person or persons other than Defendant. 21. Defendant operated her vehicle in such a manner as to comply with all pertinent provisions of the Pennsylvania Motor Vehicle Code and in a non-negligent and responsible manner at all times relevant to the incident giving rise to Plaintiff's Complaint. 22. Defendant hereby invokes the defense of the sudden emergency doctrine. 4 WHEREFORE, Defendant Mary Strickland respectfully requests that this Honorable Court enter judgment in her favor and against Plaintiff, and further award her all such further relief as is just and proper. Respectfully submitted, M Kissock & Hoffman, P.C. By: Craig Black, Esquire I.D. No.: 36818 Lauren M. Burnette, Esquire I.D. No.: 92412 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Dated: 3 12-1) 0:7 Attorneys for Defendant Mary Strickland 5 VERIFICATION I, Mary Strickland, hereby verify that the statements in Defendant's Answer and New Matter to Plaintiff's Complaint are true and correct to the best of my information, knowledge and belief. I understand that the statements are made subject to the penalties of Pa.C.S. § 4904, relating to the unsworn falsification to authorities. Mary Strickland 6 CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Answer and New Matter upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first-class postage prepaid, addressed as follows: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 (Counsel for Plaintiff) McKissock & Hoffman, P.C. By: 1 VN ) B. Craig Black, Esquire I.D. No.: 36818 Lauren M. Burnette, Esquire I.D. No.: 92412 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 (717) 540-3400 Dated: 312 I O :T Attorneys for Defendant 7 in r- JEFFREY HOLLENBACH, Plaintiff V. MARY STRICKLAND, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 07-1145 CIVIL ACTION - LAW JURY TRIAL DEMANDED PLAINTIFF'S ANSWER TO DEFENDANT'S NEW MATTER 13. Paragraphs 1 through 12 of Plaintiff's Complaint are incorporated herein by reference thereto as if set forth at length. 14. Denied. This paragraph states legal conclusions to which no response is required. 15. Denied. This paragraph states legal conclusions to which no response is required. 16. Denied. This paragraph states legal conclusions to which no response is required. 17. Denied. This paragraph states legal conclusions to which no response is required. 18. Denied. This paragraph states legal conclusions to which no response is required. 19. Denied. This paragraph states legal conclusions to which no response is required. 20. Denied. This paragraph states legal conclusions to which no response is required. 21. Denied. This paragraph states legal conclusions to which no response is required. 22. Denied. This paragraph states legal conclusions to which no response is required. 468827v1 WHEREFORE, Plaintiff Jeffrey Hollenbach requests ruling in his favor and against Defendant in an amount in excess of $50,000 along with costs and other relief that the Court deems just. By: Date: METTE, EVANS & WOODSIDE J . Yaninek,`Fgsquire Ct. I.D. No. 55741 Z0.1 North Front Street P. O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - Phone (717) 236-1816 - Fax Attorneys for Plaintiff Jeffrey Hollenbach 2 VERIFICATION I, JOHN F. YANINEK, ESQUIRE, counsel for Plaintiff, Jeffrey Hollenbach, hereby verify that the facts set forth in the foregoing document are true and correct to the best of my knowledge, information and belief. I base my knowledge, information, and belief solely upon the information provided by my client. I understand that any false statements made herein are subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. -7 <?? 4-2,4 DATE: V .S? J F. YAN K, ESQUIRE V- Ct. I.D. N N55741 CERTIFICATE OF SERVICE I certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail at Harrisburg, Pennsylvania, with first-class postage, prepaid, as follows: B. Craig Black, Esquire McKissock & Hoffinan, P.C. 2040 Linglestown Road, Ste. 302 Harrisburg, PA 17110 Respectfully submitted, METTE, EVANS & WOODSIDE By: Jo F. Yani k Esquire S . Ct. I.D. No. 55741 3401 North Front Street P. O. Box 5950 Harrisburg, PA 17110-0950 (717) 232-5000 - Phone (717) 236-1816 - Fax Attorneys for Plaintiff Jeffrey Hollenbach Date: r"'D ? G7 C_? `- ?g-b, f? ;?31r?_-. -nii. . _ d _` ?? _.? 4._ - '? --i C`? ? ? 1'Yl {:y *?? SHERIFF'S RETURN - REGULAR CASE NO: 2007-01145 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HOLLENBACH JEFFREY VS STRICKLAND MARY MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon STRICKLAND MARY the DEFENDANT , at 1730:00 HOURS, on the 6th day of March 2007 at 76 GREENWOOD CIRCLE WORMLEYSBURG, PA 17043 by handing to MARY STRICKLAND a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 ?-/ Service 15.36 Postage .39°` Surcharge 10.00 R. Thomas Kline .00 43.751 03/07/2007 4, METTE EVANS WOODSIDE A0 Sworn and Subscibed to ? By: before me this day Deputy Sheriff' of A. D. S JEFFREY HOLLENBACH, IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. MARY STRICKLAND Docket No.: 07-1145 Defendant WITHDRAWAL OF APPEARANCE Kindly withdraw my appearance on behalf of Defendant, Mary Strickland in the above-captioned matter. Respectfully submitted, McKissock & Hoffman, P.C. BY: B. Cra' lack, Esquir I. D. .: 36818 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 717-540-3400 Dated: 3 .,e Attorney for Defendant, Mary Strickland -.. CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Withdrawal of Appearance upon the following person(s) in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first class postage pre-paid, addressed as follows: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff McKissock & Hoffman, P.C. BY: ?+? B. Cra' ac , s ire I.D. .. 36818 2040 Linglestown Road Suite 302 Harrisburg, PA 17110 717-540-3400 Dated: z&l Attorney for Defendant, Mary Strickland "Tl t ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Defendant, Mary Strickland in the JEFFREY HOLLENBACH, Plaintiff V1. MARY STRICKLAND Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Docket No.: 07-1145 above-captioned matter. Respectfully submitted, THE CHARTWELL LAW OFFICES, LLP BY: Dated: n _ el- B. g 131 s I. o.: 36618 1 17 Mumma Road, Suite 100 Wormleysburg, PA 17110 717-909-5170 Attorney for Defendant. Mary Strickland 4 CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Entry of Appearance upon the following person(s) in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first class postage pre-paid, addressed as follows: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff THE CHARTWELL LAW OFFICES, LLP BY: `r B. Crai lack, sqU" iii 1. D. .36818 1017 Mumma Road, Suite 100 Wormleysburg, PA 17043 717-909-5170 Dated: Attorney for Defendant, Mary Strickland ? . . JEFFREY HOLLENBACH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. MARY STRICKLAND : Docket No.: 07-1145 Defendant CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendants, certify that: (1) a notice of intent to serve the subpoenas, with copies of the subpoenas attached thereto, was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoenas are sought to be served, (2) a copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, (3) no objection to the subpoenas have been received, and (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. THE CHARTWELL LAW OFFICES, LLP Date: Zro zrao8 BY: i sq A o ey for Defendants JEFFREY HOLLENBACH, IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. MARY STRICKLAND : Docket No.: 07-1145 Defendant NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff Defendant, Mary Strickland intends to serve subpoenas identical to that attached to this notice to the deponent listed below, requesting records be produced at The Chartwell Law Offices, LLP, 1017 Mumma Road, Suite 100, Wormleysburg, PA 17043. 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 subpoenas. If no objection is made the subpoenas may be served. Custodian of Records, Mark Schneier, D.C. Custodian of Records, The Cleveland Clinic Custodian of Records, Neurological Surgery, Ltd. Custodian of Records, Mark Kostow, D.C. THE CHARTWELL LAW OFFICES, LLP BY: ,. B. r c 3q?\ ,* BI ID o . 36818 1017 Mumma Road, Suite 100 Wormleysburg, PA 17043 717-909-5170 Date: /,T?....8 Attorney for Defendant, Mary Strickland C3 `•' R crr JEFFREY HOLLENBACH, : IN THE COURT OF n r COMMON PLEAS o' Plaintiff : OF CUMBERLAND COPNTY,:;-- PENNSYLVANIA rv kJ CIVIL ACTION - LAW V. MARY STRICKLAND : Docket No.: 07-1145 --? Defendant CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendants, certify that: (1) a notice of intent to serve the subpoenas, with copies of the subpoenas attached thereto, was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoenas are sought to be served, (2) a copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, (3) no objection to the subpoenas have been received, and (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. THE CHARTWELL LAW OFFICES, LLP Date: 2oio BY: B. ig lac t, sq At ey for Defendants I.D. No.: 36818 30 North Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 JEFFREY HOLLENBACH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. MARY STRICKLAND : Docket No.: 07-1145 Defendant NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff Defendant, Mary Strickland intends to serve subpoenas identical to that attached to this notice to the deponent listed below, requesting records be produced at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. 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 subpoenas. If no objection is made the subpoenas may be served. Susquehanna Chiropractic Barton Medical Associates (employment) Menno Haven Physician Services (employment) THE CHARTWELL LAW OFFICES, LLP BY: / B. C 'g lack, Esquire ID .: 36818 1017 Mumma Road, Suite 100 Wormleysburg, PA 17043 L 717-909-5170 Date: ?T Attorney for Defendant, Mary Strickland COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, Plaintiff CIVIL ACTION - LAW V. MARY STRICKLAND Defendant Docket No.: 07-1145 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Susquehanna Chiropractic, 423 Limekiln Drive, Chambersburg„ PA 17201 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records pertaining to Jeffrey Hollenbach. Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland BY THE COURT: Date: Seal of the Court Prothonotary, Civil Division Deputy ADDENDUM TO SUBPOENA Including but not liming to office records, including notes, correspondence, admissions, discharge, medical bills, memoranda, radiology reports, history notes, and any other information relating to any examination or treatment rendered, regardless of treatment date or condition treated. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PATIENTS. Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/1962 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, Plaintiff CIVIL ACTION - LAW V. MARY STRICKLAND Defendant Docket No.: 07-1145 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Barton Medical Associates 435 Phoenix Drive, Chambersburg, PA 17201 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all employment records pertaining to Jeffrey Hollenbach. Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third St., Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland BY THE COURT: Prothonotary, Civil Division Date: Seal of the Court Deputy ADDENDUM TO SUBPOENA Including but not liming to entire personnel file including applications, disciplinary reports, performance reviews, workers' compensation claim information, attendance, payroll, and termination information. Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/62 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, Plaintiff CIVIL ACTION - LAW V. MARY STRICKLAND Defendant Docket No.: 07-1145 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Menno Haven Physician Services. 2075 Scotland Avenue, Chambersburg, PA 17201 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all employment records pertaining to Jeffrey Hollenbach. Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third St., Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland BY THE COURT: Date: Prothonotary, Civil Division Seal of the Court Deputy ADDENDUM TO SUBPOENA Including but not liming to entire personnel file including applications, disciplinary reports, performance reviews, workers' compensation claim information, attendance, payroll, and termination information. Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/62 JEFFREY HOLLENBACH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vi. MARY STRICKLAND : Docket No.: 07-1145 Defendant CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Certificate Prerequisite to Service of Subpoenas upon the following person(s) in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first class postage pre-paid, addressed as follows: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff THE CHARTWELL LAW OFFICES, LLP BY: B. Cra' lac z, Esquire I.D. 16V. 36818 30 North Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 Dated: 2^0-0 Attorney for Defendant, Mary Strickland FILED-t)?= : 2010 JAN 26 AN 9: 36 JEFFREY HOLLENBACH, V. MARY STRICKLAND, Plaintiff Defendant IN THE COURT OF CgMM PL E CUMBERLAND COUN 1^ V i1?,If,`V?IA No. 07-1145 CIVIL ACTION - LAW TRIAL DEMANDED PRAECIPE FOR CHANGE OF ADDRESS TO THE PROTHONOTARY: Kindly change the mailing address for the undersigned, counsel for Defendant, Mary Strickland, to the following: B. Craig Black, Esquire The Chartwell Law Offices, LLP 30 North Third Street Suite 1050 Harrisburg, PA. 17101 Date: THE CHARTWELL LAW OFFICES, LLP By: B. Cr ' Black, squire Att ey I.D. # 36818 CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Praecipe upon the following person(s) in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first class postage pre-paid, addressed as follows: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff THE CHARTWELL LAW OFFICES, LLP Date: By: . C g Black, Esquire JEFFREY HOLLENBACH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. C: ?? "? MARY STRICKLAND : Docket No.: 07-1145 y Defendant cT,> N -y CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PUR TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendants, certify that: (1) a notice of intent to serve the subpoenas, with copies of the subpoenas attached thereto, was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoenas are sought to be served, (2) a copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, (3) no objection to the subpoenas have been received, and (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. THE CHARTWELL LAW OFFICES, LLP Date: 4%, ,6 z,Wv BY: JB"ig / Blac , squ y for Defendants I.D. No.: 36818 30 North Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 JEFFREY HOLLENBACH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. MARY STRICKLAND : Docket No.: 07-1145 Defendant NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff Defendant, Mary Strickland intends to serve subpoenas identical to that attached to this notice to the custodian of records for the deponents listed below, requesting records be produced at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. 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 subpoenas. If no objection is made the subpoenas may be served. University Dynamic MR1 Frederick Lieberman, M.D. Chambersburg Hospital Peak Performance Physical Therapy Richard Magill, M.D. Neurological Surgery, Ltd. THE CHARTWELL LAW OFFICES, LLP BY: B. ra ac , sq ID 6818 30 rth third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 Date: i9 Zoe Attorney for Defendant, Mary Strickland i3?47 ADDENDUM TO SUBPOENA Including but not liming to medical records, notes, correspondence, admissions, discharge, medical bills, radiology reports, diagnostic study films and any other information relating to any examination or treatment rendered, regardless of treatment date or condition treated. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PATIENTS. Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/1962 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, V. CIVIL ACTION - LAW MARY STRICKLAND Docket No.: 07-1145 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Frederick Lieberman, M.D., Attn: Records Custodian 1521 Locust St 2"d floor Philadelphia PA 19102 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records pertaining to Jeffrey Hollenbach Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland Date: aLpa?hD S al of the Court Plaintiff B COURT: tho tary, Civil Division Deputy ADDENDUM TO SUBPOENA Including but not liming to medical records, notes, correspondence, admissions, discharge, medical bills, radiology reports, diagnostic study films and any other information relating to any examination or treatment rendered, regardless of treatment date or condition treated. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PATIENTS. Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/1962 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, V. MARY STRICKLAND Plaintiff CIVIL ACTION - LAW Defendant Docket No.: 07-1145 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Chambersburg Hospital, Attn: Records Custodian 112 N 70' St Chambersburg PA 17201 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records pertaining to Jeffrey Hollenbach Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland Date: 8/45bD Se oft Court BY THE CO lonotary, <CFv'iI Division Deputy ADDENDUM TO SUBPOENA Including but not liming to medical records, notes, correspondence, admissions, discharge, medical bills, radiology reports, diagnostic study films (including, but not limited to November 2009 MRI films) and any other information relating to any examination or treatment rendered, regardless of treatment date or condition treated. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PATIENTS. Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/1962 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, V. MARY STRICKLAND Plaintiff CIVIL ACTION - LAW Defendant Docket No.: 07-1145 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Peak Performance Physical Therapy. Attn: Records Custodian 1580 Buchanan Trail West Greencastle. PA 17225 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records pertaining to Jeffrey Hollenbach Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland Date: - 0 Se oft a court BY THE CO 1*4, rothonoCiv Division Deputy ADDENDUM TO SUBPOENA Including but not liming to medical records, notes, correspondence, admissions, discharge, medical bills, radiology reports, diagnostic study films and any other information relating to any examination or treatment rendered, regardless of treatment date or condition treated. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PATIENTS. Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/1962 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, V. MARY STRICKLAND Plaintiff CIVIL ACTION - LAW Defendant Docket No.: 07-1145 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Richard Magill, M.D., Attn: Records Custodian 2151 Linglestown Road Suite 110, Harrisburg PA 17110 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records pertaining to Jeffrey Hollenbach Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland Date: -aluxbo Se k of A e Court BY THE C T: rothonotary , ivil Division Deputy ADDENDUM TO SUBPOENA Including but not liming to medical records, notes, correspondence, admissions, discharge, medical bills, radiology reports, diagnostic study films and any other information relating to any examination or treatment rendered, for all dates of treatment and all medical conditions. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PATIENTS. Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/1962 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, CIVIL ACTION - LAW Plaintiff V. MARY STRICKLAND Defendant Docket No.: 07-1145 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Neurological Surgery, Ltd., Attn: Records Custodian, 920 Century Dr., Mechanicsburg, PA 17055 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records pertaining to Jeffrey Hollenbach. Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland Date: 319S/10 eal of he Court BY T E C JW Prothonot ry, Civil Division Deputy ADDENDUM TO SUBPOENA Including but not liming to medical records, notes, correspondence, admissions, discharge, medical bills, radiology reports, diagnostic study films and any other information relating to any examination or treatment rendered, for treatment dated August 1, 2007 to the present only. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PATIENTS. Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/1962 JEFFREY HOLLENBACH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vi. : MARY STRICKLAND : Docket No.: 07-1145 Defendant CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Certificate Prerequisite to Service of Subpoenas upon the following person(s) in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first class postage pre-paid, addressed as follows: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff THE CHARTWELL LAW OFFICES, LLP BY: `yam B. Craig Bla , Esquire I.D. No.: 36818 30 North Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 Dated: c3 t? Attorney for Defendant, Mary Strickland ., JEFFREY HOLLE BACH, : IN THE COURT OF ~ o :COMMON PLEAS ~- ~ ~' Plaintiff : OF CUMBERLAND COPY, ~_' ~ ~, PENNSYLVANIA 4f _ f..__ -~ r - ~ y;! CIVIL ACTION -LAW °,_;: T ,. ~. , ~ ~, 1 V. =~ ~ p~ ~ ~, t~ .~ --- z3 MARY STRICKLA D :Docket No.: 07-1145 -~ '~ Defendant CERTIFICATE REREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequ site to service of subpoenas for documents and things pursuant to Rule 4009.22, Defen ants, certify that: (1) a notice of intent to serve the subpoenas, with copies of the subpoenas attached thereto, wa mailed or delivered to each party at least twenty (20) days prior to the date on which th subpoenas are sought to be served, (2} a copy of this certificate, (3) no obj (4) the subpo~ attached to the notice notice of intent, including the proposed subpoenas, is attached to to the subpoenas have been received, and s which will be served are identical to the subpoenas which are intent to serve the subpoenas. THE CHARTWELL LAW OFFICES, LLP Date: s ~,,o ~ ,~-- BY: ,C ' B. Cr g Black, Esquire Att ey for Defendants I. o.: 36818 30 North Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 JEFFREY HOLLENBA v. MARY STRICKLAND IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, :PENNSYLVANIA CIVIL ACTION -LAW Docket No.: 07-1145 Defendant NOTICE OF INTENT TC~ SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS TO: John F. Yaninek, Es uire Mette, Evans & Wo dsid 3401 N. Front Stree Harrisburg, PA 171 0 Counsel for Plainti Defendant, Mary S ickland intends to serve subpoenas identical to that attached to this notice to the custodian of record for the deponents listed below, requesting records be produced at The Chartwell Law Offices, L P, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You have twenty (20) days from the to listed below in which to file of record and serve upon the undersigned an objection to the subpoen If no objection is made the subpoenas may be served. Johns Hopkins f North American Date: _ ~° -S; aoia Spine Institute THE CHARTWELL LAW OFFICES, LLP i BY: ,y / e B. Cr ' Black, sq ID .36818 30 North Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 Attorney for Defendant, Mary Strickland COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY v. MARY STRICK Plaintiff CIVIL ACTION -LAW . Docket No.: 07-1 i 45 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Within twent~(20) days after service of this subpoena, you are ordered by the court to produce the following documents things: addendum. at The Chartwell Lave{ Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many del ver or mail legible copies of the documents or produce things requested by this subpoena, together wit the certificate of compliance, to the party making this request at the address listed above. You have the ri ht to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to p oduce the documents or things required by this subpoena within twenty (20) days aRer its service, the party ser ing this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WA ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: , NAME: B. Cr ig Black, Esquire ADDRESS: The C artwell Law Offices, LLP 30 N. hird Street, Suite 1050 Harris urg, PA 17101 TELEPHONE: 717-9 9-5170 SUPREME COURT I :36818 ATTORNEY FOR: De ndant, Mary Strickland BY THE COURT: Date: i Seal of the Court Prothonotary, Civil Division Deputy ADDENDUM TO SUBPOENA Including but not limin to medical records, notes, correspondence, admissions, discharge, medical bills, radiology r ports, diagnostic study films and any other information relating to any examination or treatmen rendered, for treatment dated September 20,19b2 to the present. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PATIENTS. Patient: Jeff ey Hollenbach Social Security No.: 173 38-5705 Date of Birth: 9/2 /1962 JEFFREY HOLLEN v. MARY STRICKLAN COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Plaintiff CIVIL ACTION -LAW Docket No.: 07-1145 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: North Americ n Lasersco is S ine Institute ATTN: RECORDS CUSTODIAN One Elizabeth P1F Dayton. OH 45408 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents o things: addendum. at The Chartwell LawlOffices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101 You many deli er or mail legible copies of the documents or produce things requested by this subpoena, together with a certificate of compliance, to the party making this request at the address listed above. You have the rig t to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to pr duce the documents or things required by this subpoena within twenty (20) days after its service, the party ser ing this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WA~ ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Cr. ADDRESS: The C 30 N. TELEPHONE: 717 SUPREME COURT I ATTORNEY FOR: C ..Black, Esquire rtwell Law Offices, LLP gird Street, Suite 1050 irg, PA 17101 -5170 36818 idant, Mary Strickland BY THE COURT: Date: Prothonotary, Civil Division Deputy ADDENDUM TO SUBPOENA Including but not limin to medical records, notes, correspondence, admissions, discharge, medical bills, radiology r ports, diagnostic study films and any other information relating to any examination or treatment rendered, for treatment dated September 20,1962 to the present. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PATIENTS. Patient: Jeff ey Hollenbach Social Security No.: 173 8-5705 Date of Birth: 9/2 /1962 JEFFREY HO CIVIL ACTION -LAW vi. MARY CH, : IN THE COURT OF :COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, :PENNSYLVANIA Docket No.: 07-1145 Defendant CERTIFICATE OF SERVICE I hereby cert' y that I am this day serving a copy of the foregoing Certificate Prerequisite to Se ice of Subpoenas upon the following person(s) in the manner indicated below, whi~h service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by epositing a copy of same in the United States Mail, first class postage pre-paid, add ssed as follows: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff THE CHARTWELL LAW OFFICES, LLP BY: _ B. ac , squire - I.D. N .• 36818 30 Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 Dated: Attorney for Defendant, Mary Strickland THOMAS, THOMAS &HAFER, LLP John F. Yaninek, Esquire Identification Number: 55741 P.O. Box 999 Harrisburg, PA 17108-0999 717/441-3952 kmcnamara@tthlaw.com Attorneys for Plaintiff JEFFREY HOLLENBACH, Plaintiff v. MARY STRICKLAND, Defendant ~'tt_~C-OFf ICE CE Z~-IE ~?C~IrC~tOTARY ~:~~ a~ r,~~ ~ ~ ~y 2~ G9 IJ~Ir PC)i--~ `~i. ,: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1145 CIVIL TERM JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF APPEARANCE AND CHANGE OF ADDRESS TO THE PROTHONOTARY: Kindly substitute the appearance of Thomas, Thomas & Hafer, LLP, for Mette, Evans & Woodside, and change the address for the undersigned, counsel for Plaintiff, to the following: John F. Yaninek, Esquire Thomas, Thomas & Hafer, LLP 305 North Front Street P.O. Box 999 Harrisburg, PA 17108-0999 Respectfully submitted, THOMAS, THOMAS &HAFER, LLP B J F. Yani ,Esquire Attorneys for Plaintiff 870842-1 CERTIFICATE OF SERVICE I, Gwen M. Cleck, employee of the law firm of Thomas, Thomas & Hafer, LLP, hereby certify that I have served a true and correct copy of the foregoing document on the following persons by placing same in the United States mail, postage prepaid, on the ~g day of ~~~7p 1"" , 2010: B. Craig Black, Esquire The Chartwell Law Offices, LLP 30 North Third Street Suite 1050 Harrisburg, PA 17101 THOMAS, THOMAS ~ HAFER, LLP By: N~, Gwen M. Cleck s~osa2-~ JEFFREY HOLLENBACH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA C.'N CIVIL ACTION - LAWS c V. ?'r-- .. R MARY STRICKLAND : Docket No.: 07-1145 Defendant = Z CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 4009.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendants, certify that: (1) a notice of intent to serve the subpoenas, with copies of the subpoenas attached thereto, was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoenas are sought to be served, (2) a copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, (3) no objection to the subpoenas have been received, and (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. THE CHARTWELL LAW OFFICES, LLP Date: BY: n B. C ig Black, Esqu Attey for Defendants I.D. No.: 36818 30 North Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 7 .?,r- -z! 8 JEFFREY HOLLENBACH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. MARY STRICKLAND : Docket No.: 07-1145 Defendant NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff Defendant, Mary Strickland intends to serve subpoenas identical to that attached to this notice to the custodian of records for the deponents listed below, requesting records be produced at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. 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 subpoenas. If no objection is made the subpoenas may be served. Beebe Medical Center Geisinger Medical Center THE CHARTWELL LAW OFFICES, LLP BY: B. Cr ' lac c, sq ID 6818 30 Vefth Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 Date:U Attorney for Defendant, Mary Strickland r COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, V. MARY STRICKLAND Plaintiff CIVIL ACTION - LAW Defendant Docket No.: 07-1145 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: G_ eisineer Medical Center, ATTN• RECORDS CUSTODIAN, 100 North Academy Avenue, Danville, PA 17822 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records pertaining to Jeffrey Hollenbach. Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland BY THE COURT: Date: Seal of the Court Prothonotary, Civil Division Deputy ADDENDUM TO SUBPOENA Including but not liming to medical records, notes, correspondence, admissions, discharge, medical bills, radiology reports, diagnostic study films and any other information relating to any examination or treatment rendered, for treatment dated September 20, 1962 to the present. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PATIENTS. Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/1962 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, V. CIVIL ACTION - LAW MARY STRICKLAND Docket No.: 07-1145 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Beebe Medical Center ATTN: MEDICAL RECORDS-DEPT., 424 Savannah Road Lewes DE 19958 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records pertaining to Jeffrey Hollenbach Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101 You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. . If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland BY THE COURT: Date: Seal of the Court Prothonotary, Civil Division Plaintiff Deputy ADDENDUM TO SUBPOENA Including but not liming to medical records, notes, correspondence, admissions, discharge, medical bills, radiology reports, diagnostic study films and any other information relating to any examination or treatment rendered, for treatment dated September 20, 1962 to the present. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PATIENTS. Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/1962 JEFFREY HOLLENBACH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vi. MARY STRICKLAND : Docket No.: 07-1145 Defendant CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Certificate Prerequisite to Service of Subpoenas upon the following person(s) in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first class postage pre-paid, addressed as follows: John F. Yaninek, Esquire Mette, Evans & Woodside 3401 N. Front Street Harrisburg, PA 17110 Counsel for Plaintiff THE CHARTWELL LAW OFFICES, LLP BY: B. Cra' lack, Esquire I.D. o.: 6818 30 Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 Dated: 421A?Ylo Attorney for Defendant, Mary Strickland JEFFREY HOLLENBACH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND CO UNTY, PENNSYLVANIA CIVIL ACTION - LAW 3 v. : rnrn z ? Z, - MARY STRICKLAND : Docket No.: 07-1145 r -<> Defendant s a? N C= -*r m 0 ..o 3„ ? rv z CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENA PURSUAIV TZ RULE 4009.22 As a prerequisite to service of subpoena for documents and things pursuant to Rule 4009.22, Defendants, certify that: (1) a notice of intent to serve the subpoena, with a copy of the subpoena attached thereto, was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoenas are sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. THE CHARTWELL LAW OFFICES, LLP Date: 2-$ i BY: B. C ig Black, Esqui A ey for Defendants I. No.: 36818 30 North Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 z rn -v rn MC) ca s° CD-q o ri ?n? JEFFREY HOLLENBACH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. MARY STRICKLAND : Docket No.: 07-1145 Defendant NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: John F. Yaninek, Esquire Thomas Thomas & Hafer 305 North Front Street P.O.Box 999 Harrisburg PA 17108-099 Counsel for Plaintiff Defendant, Mary Strickland intends to serve a subpoena identical to that attached to this notice to the custodian of records for the deponent listed below, requesting records be produced at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. 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. Geisinger Wyoming Valley Medical Center THE CHARTWELL LAW OFFICES, LLP BY: .? ?? B. ' Black, Esquire ID 36818 Cr 30 orth Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 Date: ,u ,?;? Attorney for Defendant, Mary Strickland COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, V. MARY STRICKLAND Plaintiff CIVIL ACTION - LAW Defendant Docket No.: 07-1145 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Geisinger Wyoming Valley Medical Center, ATTN: RECORDS CUSTODIAN 1000E Mountain Blvd, Wilkes-Barre, PA 18711 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records and medical bills pertaining to Jeffrey Hollenbach Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland BY THE COURT: Date: Seal of the Court Prothonotary, Civil Division Deputy ADDENDUM TO SUBPOENA Including but not liming to medical records, notes, correspondence, admissions, discharge, medical bills, radiology reports, diagnostic study films and any other information relating to any examination or treatment rendered, for treatment dated September 20, 1962 to the present. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PATIENTS. Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/1962 JEFFREY HOLLENBACH, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vi. MARY STRICKLAND : Docket No.: 07-1145 Defendant CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Certificate Prerequisite to Service of Subpoenas upon the following person(s) in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, first class postage pre-paid, addressed as follows: John F. Yaninek, Esquire Thomas Thomas & Hafer, LLP 305 North Front Street P.O.Box 999 Harrisburg PA 17108-0999 THE CHARTWELL LAW OFFICES, LLP BY: B. Craig lack, Esquire I.D. No.: 36818 30 North Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 Dated: Attorney for Defendant, Mary Strickland JEFFREY HOLLENBACH, : IN THE COURT OF :COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, :PENNSYLVANIA CIVIL ACTION -LAW v. MARY STRICKLAND :Docket No.: 07-1145 Defendant CERTIFICATE PREREQUISITE TO SERVICE OF SUBPOENAS PURSUANT TO RULE 409.22 As a prerequisite to service of subpoenas for documents and things pursuant to Rule 4009.22, Defendant, certifies that: (1) a notice of intent to serve the subpoenas, with a copy of the subpoenas attached thereto, was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoenas are sought to be served, (2) a copy of the notice of intent, including the proposed subpoenas, is attached to this certificate, (3) no objections to the subpoenas have been received, and (4) the subpoenas which will be served are identical to the subpoenas which are attached to the notice of intent to serve the subpoenas. THE CHARTWELL LAW OFFICES, LLP J ~ c.-, Date: ~ 3~, ~~~. BY: ~ rn~ ~''~ ~ ' ~n r*t B. ac , squi ~ z ~+ - *~ -v ~ .~, Atto a for Defendants ~~ F, LD .: 36818 <v 30 orth Third Street, Suite 1050 zo ~ Harrisburg, PA 17101 y~ 717-909-5170 ~ w JEFFREY HOLLENBACH, v. MARY STRICKLAND IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, :PENNSYLVANIA Defendant CIVIL ACTION -LAW Docket No.: 07-1145 NOTICE OF INTENT TO SERVE SUBPOENAS TO PRODUCE DOCUMENTS AND FOR DISCOVERY PURSUANT TO RULE 4009.21 TO: Gerald C. Kramer, Esquire Schmidt Kramer, P.C. 209 State Street Harrisburg, PA 17101 Counsel for Plaintiff Defendant, Mary Strickland intends to serve subpoenas identical to those attached to this n tice to the custodian of records for the deponents listed below, requesting records be produced at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You ave twenty (20) days from the date listed below in which to file of record and serve upon the undersi ed an objection to the subpoenas. If no objections are made the subpoenas may be served. Ravi Kalamanchi, MD Advanced Pain Management Peak Performance Physical Therapy New Bridge Spine and Pain Center Parkway Neuroscience and Spine Institute THE CHARTWELL LAW OFFICES, LLP BY: -~-, / B. Crai ac c, s ID N .: 6818 30 North Third Street, Suite 1050 Harrisburg, PA 17101 717-909-5170 Date: $ ~ Z Attorney for Defendant, Mary Strickland COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, v. MARY STRICKLAND Docket No.: 07-1145 Defendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Ravi Yalamanchi MD ATTN: RECORDS CUSTODIAN 141 Thomas Johnson Drive Suite 200 Frederick MD 21702 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days , its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME:. B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland Plaintiff CIVIL ACTION -LAW BY THE COURT: Date: Seal of the Court Prothonotary, Civil Division Deputy ADDENDUM TO SUBPOENA Including but not liming to medical records, notes, correspondence, admissions, discharge, medical bills, radiology reports, diagnostic study films and any other information relating to examination or treatment rendered, for treatment dated September 20,1962 to the present. PLEASE PROVIDE RECORDS FROM ALt OFFICES AT WHICH YOU TREAT PA Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20 f 1962 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, v. MARY STRICKLAND Plaintiff CIVIL ACTION -LAW Defendant Docket No.: 07-1145 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Advanced Pain M 190. Frederick ~MD 21702 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland BY THE COURT: Date: Seal of the Court Prothonotary, Civil Division Deputy ADDENDUM TO SUBPOENA Including but not liming to medical records, notes, correspondence, admissions, discharge, medical bills, radiology reports, diagnostic study films and any other information relating to examination or treatment rendered, for treatment dated September 20,1962 to the present. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT P Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/1962 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, Plaintiff CIVIL ACTION -LAW v. MARY STRICKLAND Defendant Docket No.: 07-I 145 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Peak Performance Physical Therapy, Attn: Records Custodian, 1580 Buchanan Trail East, Greencastle. PA 17225 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records pertaining,to Jeffrey Hollenbach dated April 1, ZO10 to present only. Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days its service, the party serving this subpoena may seek a court order compelling you to comply with it. TH15 SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland BY THE COURT: Date: Seal of the Court Prothonotary, Civil Division Deputy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, Plaintiff CIVIL ACT10N -LAW v. MARY STRICKLAND Defendant Docket No.: 07-1145 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 400922 TO: New Bridge Spine and ] Suite 196, Frederick, MD 21702 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical records and medical bills Qertaining to Jeffrey Hollenbach. Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. if you fail to produce the documents or things required by this subpoena within twenty (20) days its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland BY THE COURT: Date: Seal of the Court Prothonotary, Civil Division Deputy T ADDENDUM TO SUBPOENA Including but not liming to office records, including notes, correspondence, admissions, discharge, medical bills, memoranda, radiology reports, history notes, and any other information relating to any examination or treatment rendered, regardless of treatment date or condition treated. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PATIENTS. Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/1962 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JEFFREY HOLLENBACH, Plaintiff CIVIL ACTION -LAW v. MARY STRICKLAND Defendant Docket No.: 07-1145 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Parkway Neuroscience an~ Suite 100. Hagerstown. MD 21740 Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Any and all medical recordspertaining to 3effrey Hollenbach. Please see attached addendum. at The Chartwell Law Offices, LLP, 30 North Third Street, Suite 1050, Harrisburg, PA 17101. You many deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: B. Craig Black, Esquire ADDRESS: The Chartwell Law Offices, LLP 30 N. Third Street, Suite 1050 Harrisburg, PA 17101 TELEPHONE: 717-909-5170 SUPREME COURT ID#: 36818 ATTORNEY FOR: Defendant, Mary Strickland BY THE COURT: Date: Seal of the Court Prothonotary, Civil Division Deputy ADDENDUM TO SUBPOENA Including but not liming to medical records, notes, correspondence, admissions, discharge, medical bills, radiology reports, diagnostic study films and any other information relating to , examination or treatment rendered, for all dates of treatment regardless of condition treated. PLEASE PROVIDE RECORDS FROM ALL OFFICES AT WHICH YOU TREAT PA' Patient: Jeffrey Hollenbach Social Security No.: 173-38-5705 Date of Birth: 9/20/1962 FILED-- F ft,' SCHMIDT KRAMER PC fOj_ HE °ROTH0[g0TAj�,r BY: Gerard C. Kramer, ESQUIRE I.D. No. 44715 2G13 HAY 23 PM (; 18 209 State Street CUMB�RLti�d� COUNTY Harrisburg, PA 17101 ' PENNSYLVANIA L A ND (717) 232-6300.(t) (717) 232-6467 (fl gkramer(@schmidtkramer.com Attorneys for Plaintiff(s) JEFFREY HOLLENBACH, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff, V. No. 07-1145 MARY STRICKLAND, CIVIL ACTION - LAW Defendant. JURY TRIAL DEMANDED PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Please mark the above-captioned action settled, discontinued and ended with prejudice. Respectfully submitted, SCHMIDT KRAMER PC By Gerard C. Kramer, Esquire I.D. No. 44715 209 State Street Harrisburg, PA 17101 (717) 232-6300 Date: /�� v/ Attorney for Plaintiff(s)