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HomeMy WebLinkAbout03-0432SEAN BOYLE, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: - 03 -ya01 CROWN EQUIPMENT CORPORATION, : Defendant : JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS To the Prothonotary: Please issue a writ of summons in the above captioned action. Writ of Summons shall be issued and forwarded to Karl E. Rominger, Esquire, 155 South Hanover Street, Carlisle, Pennsylvania 17013. Date: January 29, 2003'--- ---- -- Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Supreme Court ID# 81924 (717) 241-6070 WRIT OF SUMMONS To The Above Named Defendant: Crown Equipment Corporation 44 South Washington Street New Bremen, OH 45869 (419) 629-2311 YOU ARE NOTIFIED THAT THE ABOV N - EE COMMENCED AN ACTION AGAINST YOU. Date: //014/0 L V Cl) p I _ V I c c.. 2 , '- ^?: IL SEAN BOYLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW NO: - 0344-2- L62 CROWN EQUIPMENT CORPORATION, : Defendant : JURY TRIAL DEMANDED AFFIDAVIT OF SERVICE I, Karl E. Rominger, Attorney for the Plaintiff did execute service upon Defendant, Crown Equipment Corporation by forwarding the Writ of Summons to a private process server in Ohio for service upon the Corporation. Proof of service is attached in the form of a notarized Affidavit of process server, Jesse R. Mays. Which is incorporated herein as if fully set out. Respectfully submitted, ROMINGER & BAYLEY Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, P.A 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff Date: February 12, 2003 AFFIDAVIT OF SERVICE Commonwealth of Pennsylvania Case Number: 03-432 Plaintiff: Sean Boyle vs. Defendant: Crown Equipment Corporation For: Karl Rominger Rom inger & Bayley Law Offices County of Cumberland In The Court Of Comm Court Received by ROMINGER LEGAL on the 31 st day of January, 2003 at 6:53 pm to be served Crown Eguipment Corporation 44 South Washington Street New Bremen, Ohio 45869. I, being duly sworn, depose and say that on the day of Irc-Bf-U0f,2 Y: 20 at _ ?oP.m., executed service by delivering a true copy of the Writ of Summons in accordance with state statutes in the manner marked below: () PUBLIC AGENCY: By serving the within-named agency. () SUBSTITUTE SERVICE: By serving CORPORATE SERVICE: By serving ?t 120WAI 7- Co as- as 7oN/ST as /U ti - () OTHER SERVICE: As described in the Comments below by serving () NON SERVICE: For the reason detailed in the Comments below. COMMENTS: of as Aged Sex M© Race W#17-6 Height St rr Weight12-0 _ Hair zawAv Glasses I certify that I have no interest in the above action, am of legal age and have proper authority in the jurisdiction in which this service was made. Subscr' ed fi?yfn rn to before me on the G day P aESS SERVER # _4 Of ?q 2-0a by the affiant who is ppointed in accordance pe ally me. with State Statutes ' IV ROMINGER LEGAL 155 S. Hanover St. ROBERT D. BOERGER P.O. Box 1148 ?xNooWy?P? , Stake of 0No Carlisle, PA 17013 s 10-29.01 (717) 960-9260 Our Job Serial Number: 2003000012 Copyright ®1992-21m1 Database Services, Inc. - Process Servers Toolbox V5.5f n rte; ?? ? ? X77 ` Campbell Campbell Edwards & Conroy, PC William J. Conroy, Esquire Thomas M. Hinchey, Esquire Tiffany M. Alexander, Esquire Attorney I.D. No. 36433/46628/88681 690 Lee Road Suite 300 Wayne, PA 19087 (610) 964-1900 Attorneys for Defendant, Crown Equipment Corporation SEAN BOYLE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, _v_ CIVIL ACTION - LAW CROWN EQUIPMENT CORPORATION Defendant. NO. 03-432 JURY TRIAL DEMANDED ENTRY OF APPEARANCE AND DEMAND FOR)R JURY TRIAL TO THE PROTHONOTARY: Kindly enter our appearance as counsel on behalf of defendant, Crown Equipment Corporation, in the above-captioned matter. Defendant Crown Equipment Corporation hereby demands a jury of twelve. Wil iam J. Conroy, quire Attorney for Defendant, Crown Equipment Corporation Dated: Z D F? (?f C'J CA ?? -n _ s .? -_ c..-. T... -.- : _ , ? ? I J ?,, -;=r - ?.?, - _ ?, ,,, , -. _ , ,. ?s = Campbell Campbell Edwards & Conroy, PC William J. Conroy, Esquire Thomas M. Hinchey, Esquire Tiffany M. Alexander, Esquire Attorney I.D. No. 36433/46628/88681 690 Lee Road Suite 300 Wayne, PA 19087 (610) 964-1900 SEAN BOYLE Attorneys for Defendant, Crown Equipment Corporation COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, -v- CWIL ACTION - LAW CROWN EQUIPMENT CORPORATION Defendant. NO. 03-432 JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: Please enter a Rule upon plaintiff to file a Complaint within 20 days hereof or suffer the entry of a Judgment Non Pros. Dated: 1 21 Dj-) William J. Conro , Esquire Attorney for Defendant, Crown Equipment Corporation Campbell Campbell Edwards & Conroy, PC William J. Conroy, Esquire Thomas M. Hinchey, Esquire Tiffany M. Alexander, Esquire Attorney I.D. No. 3 643 3/4662 8/8 8 68 1 690 Lee Road Suite 300 Wayne, PA 19087 (610) 964-1900 SEAN BOYLE Plaintiff, -V- CROWN EQUIPMENT CORPORATION Defendant. Attorneys for Defendant, Crown Equipment Corporation COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW NO. 03-432 JURY TRIAL DEMANDED RULE TO FILE COMPLAINT' AND NOW, this y of 4a 2004, a Rule is hereby granted upon Plaintiff to file a Complaint herein within 20 days after service hereof or suffer the entry of a Judgment of Non Pros. CERTIFICATE OF SERVICE I, Tiffany M. Alexander, Esquire, verify that the foregoing Praecipe For Rule To File Complaint was served on July 21, 2004 by first class mail and addressed as follows: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Willi J. Conroy, Es uire Attorney for Defendant Crown Equipment Corporation _ m -rr^ SEAN BOYLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW V. : NO. 03-432 CROWN EQUIPMENT CORPORATION, : JURY TRIAL DEMANDED Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following Complaint, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. SEAN BOYLE, Plaintiff V. CROWN EQUIPMENT CORPORATION Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 03-432 COMPLAINT AND NOW, comes Sean Boyle, by and through his privately retained counsel, Karl E. Rominger, Esquire and in support of his Complaint avers as follows: 1. Plaintiff is an adult individual residing at 4549 Rollo Court, Cumberland County, Mechanicsburg, PA 17055. 2. Defendant is a corporation organized and existing under the laws of the Commonwealth of Ohio with offices located at Crown Equipment Corporation, 44 South Washington Street, New Bremen, OH 45869, which sells products in Pennsylvania. 3. On or about January 31, 2001, Defendant was injured at his place of employment, when a lift truck manufactured by defendant was driven into his leg. 4. His leg was crushed, and he sustained disabling injury, not limited to torn muscle and tissue, and crushed bones and ligaments, as well as shock and nervousness to the system, and extensive pain and suffering. 5. As a result of the injuries he has lost wages and earning capacity, and will suffer future economic and medical damages. COUNT L PRODUCT LIAEIILTTY 6. Previous paragraphs are incorporated by reference. 7. Upon information and belief, the accident of January 31, 2001, wherein plaintiff was injured, was caused by the defective nature of the 3000 series lift truck or other similar model manufactured and sold by Crown which was in operation and did crush Plaintiff's leg. 8. The defects which rendered the vehicle unreasonably dangerous for its intended use at the time it left Defendant's care, custody, and control', were as follows; A. The vehicle lacked adequate sounding mechanism to alert people situated as plaintiff was, as to the approach of the vehicle, and / or the vehicle can and would function at a time when those audible wamings were not functioning or working properly, and / or lacked a mechanism to prevent operation when those audible warning sounds were not in operation or working adequately. B. The vehicle lacked sufficient permanent safety warnings both in writing or pictorial, to warn operators against operating the vehicle in a manner which caused plaintiffs injury. C. The vehicle lacked a safety mechanism or device, which would cause the vehicle to stop or otherwise prevent it from pushing with force upon an object when it was improperly backed into a person or object, which by way of example, and not to exclude other such means, could have been a pressure sensitive skirting or other safety cut off mechanism. D. Other defects which may be evident through the course of discovery and / or trial. 9. For the foregoing reasons, and as a result of the defective nature of the truck, plaintiff is liable pursuant to § 402A of the Restatement (Second) of Torts. Wherefore Plaintiff demands judgment in excess of the statutory limit for compulsory arbitration in an amount to be determined at trial, as well as costs of this suit and any other relief the court deems just. COUNT II. NEGLIGENCE 10. Previous paragraphs are incorporated by reference. 11. Defendant was negligent in failing to discover or address the defects or should have known that such defects existed as specified in paragraph 8. 12. As a direct result of said negligence, Plaintiff was injured as described above. Wherefore Plaintiff demands judgment in excess of the statutory limit for compulsory arbitration in an amount to be determined at trial, as well as costs of this suit and any other relief the court deems just. COUNT IM BREACH OF WARRANTY 13. Previous paragraphs are incorporated by reference. 14. At the time the vehicle was sold it was explicitly and implicity warranted as safe for the purposes it was sold. 15. Defendant breached said warranties, both express and implied, by providing plaintiff's employer with a defective devise, which was defective as more fully described above, and said vehicle was not adequate or suitable for the uses for which it was intended. 16. As a direct result plaintiff was injured as more fully described above. Wherefore Plaintiff demands judgment in excess of the statutory limit for compulsory arbitration in an amount to be determined at trial, as well as costs of this suit and any other relief the court deems just. Dated: August 27, 2004 Respectfully submitted, ROMINGER, BAYLEY & WHARE -karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendant SEAN BOYLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW V. : NO. 03-432 CROWN EQUIPMENT CORPORATION, : JURY TRIAL DEMANDED Defendant CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of the Complaint upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Tiffany M. Alexander, Esquire CAMPBELL CAMPBELL EDWARDS & CONROY, P.C. 690 Lee Road, Suite 300 Wayne, PA 19087 Dated: August 27, 2004 Respectfully submitted, ROMINGER, BAYLEY & WHARE Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendant ? o r ? CCJ Mn Campbell Campbell Edwards & Conroy, PC William J. Conroy, Esquire Thomas M. Hinchey, Esquire Tiffany M. Alexander, Esquire Attorney I.D. No. 36433/46628/88681 690 Lee Road Suite 300 Wayne, PA 19087 (610) 964-1900 Attorneys for Defendant, Crown Equipment Corporation SEAN BOYLE Plaintiff, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW -v- CROWN EQUIPMENT CORPORATION NO. 03-432 JURY TRIAL DEMANDED Defendant. NOTICE OF REMOVAL TO THE PROTHONOTARY OF THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY: Pursuant to 28 U.S.C.A. §§ 1332, 1441 and 1446 (e), defendant, Crown Equipment Corporation, files herewith a certified copy of the Notice of Removal, which was filed in the United States District Court for the Middle District of Pennsylvania. bmitted: Respectfully suAyr By: ?V - Tiffany lexander, Esquire CAMPBELL CAMPBELL EDWARDS & CONROY, P.C. 690 Lee Road, Suite 300 Wayne, PA 19087 610-964-1900 610-964-1981 (facsimile) Attorney ID: PA88681 UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA SEAN BOYLE ?r T (? el i Plaintiff, No. _ V. CROWN EQUIPMENT CORPORATION JURY OF TWELVE (12) DEMANDED Defendant. FILED SCRANTON Iona NOTICE OF REMOVAL SEP 10 TO THE HONORABLE JUDGES OF THE SAID PER p uTk? DISTRICT COURT OF THE UNITED STATES: Petitioner Crown Equipment Corporation, defendant in the above-captioned action, respectfully requests that this matter be transferred from the Court of Common Pleas of Pennsylvania, Cumberland County, to the United States District Court for the Middle District of Pennsylvania and respectfully represents as follows: This matter is a civil action which was filed and is now pending in the Court of Common Pleas of Cumberland County, docketed at Civil Action Law, No. 03-432 2. The action was instituted in the Cumberland County Court of Common Pleas on January 29, 2003 by Writ of Summons. The Writ was served on defendant Crown Equipment Corporation on or about February 5, 2003. A copy of the Writ is attached hereto and marked as Exhibit "A" 3. Upon receiving no response to numerous attempts to discuss this case with Plaintiff s counsel, and having no information concerning the nature and extent of this action, or the damages claimed, Crown filed a Pmecipe and Rule to File A Complaint with the Cumberland County Court of Common Pleas on July 23, 2004, a copy of which is attached hereto as Exhibit "B". 4. No Complaint having been filed within the requisite time, Crown sent a Notice Pursuant to Rule 237.4 to Plaintiffs counsel, requiring that a Complaint be filed within ten (10) days, a copy of which is attached hereto as Exhibit "C" 5. On August 27, 2004, Plaintiff filed a Complaint with the Cumberland County Court of Common Pleas, a copy of which is attached hereto as Exhibit "D". 6. In this lawsuit, plaintiff seeks money damages from Crown as a result of personal injuries and damages allegedly resulting from an incident on or about January 31, 2001. See, Exhibit "D", paragraph 3. Plaintiff, Sean Boyle, seeks damages in excess of the Cumberland County arbitration limits ($25,000) plus costs. More specifically, the Complaint seeks recovery for personal injuries including, but not limited to, the following: (1) disabling leg crush injury, not limited to torn muscle and tissue, crushed bones and ligaments, (2) shock and nervousness; (3) extensive pain and suffering, and (4) past and future lost wages, impairment of earning capacity, and medical expenses. See, Exhibit "D", Paragraphs 4 and 5. 8. Plaintiff and defendant are citizens of different states. Specifically, the citizenship of the parties is as follows: A. Plaintiff: Plaintiff resides at 4549 Rollo Court, Cumberland County, Mechanisburg, Pa. 17055 See, Exhibit "D". B. Petitioner Crown Equipment Corporation is incorporated under the laws of the State of Ohio and has its principal place of business at offices at 44 South Washington Street, New Bremen, Ohio. 9. Until the Complaint was filed, Crown was not put on notice of federal jurisdiction. Specifically, the Writ of Summons did not disclose the state of plaintiff's residence, the type of injury or damages claimed, nor the amount in controversy. Simply put, the Writ did not inform Crown or the Court to "a substantial degree of specificity that all of the elements of federal jurisdiction are present". See Penmont Nebefit Svc. V. Castellano et.al. 2004 WL 1551745 (E.D.Pa. 2004) citing Foster v. Mutual Fire. Marine & Inland Ins. Co., 986 F.2d 48,49 (3d. Cir. 1993). 10. As such, this notice of removal is timely as it is being filed within thirty (30) days after Crown was first put on notice of federal jurisdiction. Penmont at 1. 11. Complete diversity of citizenship exists. As a result of the claimed injuries and damages, Crown avers that the amount in controversy exceeds $75,000 exclusive of interests and costs. Accordingly, Crown respectfully requests that this action be removed from the Cumberland County Court of Common Pleas to the United States District Court for the Middle District of Pennsylvania pursuant to 28 U. S.C.A. §§I332(a)(1) and 144I(a). WREREFORE, petitioner Crown Equipment Corporation respectfully requests that this action be removed from the Cumberland County Court of Common Pleas to this court and respectfully requests an Order of Removal. Respectfully submitted, By: W`1 iff exander, Esquire CAMPBE CAMPBELL EDWARDS & CONROY, P.C. 690 Lee Road, Suite 300 Wayne, PA 19087 610-964-1900 610-964-1981 (facsimile) Attorney ID: PA98681 Date: Tpi1QK?,f 7 aDJ VERIFICATION I, Tiffany M. Alexander, Esquire state that I am an attorney for defendant Crown Equipment Corporation and state that the facts set forth in the foregoing Notice of Removal are true and correct to the best of my knowledge, information and belief; and further, that the statements made therein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. By: Tiffaily Al xander, Esquire CAMPBELL MPBELL EDWARDS & CONROY, P.C. 690 Lee Road, Suite 300 Wayne, PA 19087 610-964-1900 610-964-1981 (facsimile) Attorney ID: PA88681 Date: %6 d', CERTIFICATE OF SERVICE Tiffany M. Alexander, Esquire, hereby certifies that a true and correct copy of the Notice of Removal for Defendant Crown Equipment Corporation has been served by the United States first class mail, postage prepaid and addressed as follows: Karl E. Rominger, Esquire ROMINGER BAYLEY & WHARE 155 South Hanover Street Carlisle, PA 17013 By: 7' ' Tiffan ander, Esquire CAMPBELL PBELL EDWARDS & CONROY, P.C. 690 Lee Road, Suite 300 Wayne, PA 19087 610-964-1900 610-964-1981 (facsimile) Attorney ID: PA88681 Date: J ?'1K 1?10 A64 !?? N O -n -r. ;TS Sri CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SEAN BOYLE COURT OF COMMON PLEAS TERM, -VS- CROWN EQUIPMENT CORPORATION CASE NO: 03-432 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. certifies that f (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 12/01/2004 MCSan behalf of ?? ALEXAN E? Attorney for DEFENDANT DE11-531330 7 1 0 62 -L O 1 C O M M O N W E A L T H OP P E N N S Y'L VAN T A COUNTY OP C U M B E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -VS- CROWN EQUIPMENT CORPORATION TERM, CASE NO: 03-432 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUM KNTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 GIANT DISTRIBUTION CENTER OTHER DANIEL DEARDORFF, ESQ. OTHER RICHARD E. FREEBURN, ESQ. OTHER TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/11/2004 CC: TIFFANY M. ALEXANDER, ESQ. - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-284089 7 1 0 6 2- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE File No. 03-432 vs. CROWN EQUIPMENT CORPORATION : SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO Custodian of Records for GIANT DISTRIBUTION CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street, Suite 800. Philadelphia, PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER, ESO. ADDRESS: 690 LEE ROAD SUITE 300 WAYNE. PA 19087 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant DEC0 12004 Date: "U. (? T aoinq Seal of the Court BY HE COURT: Prothonotary/Clerk, Civil Divi eputy 71062-01 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: GIANT DISTRIBUTION CENTER 1621 INDUSTRIAL DRIVE CARLISLE, PA 17013 RE: 71062 SEAN BOYLE *******SEE ATTACHED******* Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security #: 193-68-5461 Date of Birth: 11-08-1968 SU10-533388 7 1 0 6 2- L 0 1 Please obtain a complete copy of the entire personnel employment fle of Seam Boyle ' including but not limited to any and all notes, reports, medical records, attendance records, wage records, personnel training records, records of any disciplinary action taken against Mr. Boyle and any and all records concerning the investigation of his accident of January 31, 2001, including the maintenance and service records pertaining to the Crown forklift involved in the accident and any and all videos or photographs taken of the -- accident scene, the warehouse and the accident. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE TERM, -VS- CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 12/01/2004 TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT DE11-531331 7 1 0 6 2- L 0 2 C O M M O N W E A L 7H OP P E N N S Y L VAN 2 A COUNTY Op C U M B E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -VS - CROWN EQUIPMENT CORPORATION TERM, CASE NO: 03-432 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 GIANT DISTRIBUTION CENTER OTHER DANIEL DEARDORFF, ESQ. OTHER RICHARD E. FREEBURN, ESQ. OTHER TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or :by contacting our local MCS office. DATE: 11/11/2004 CC: TIFFANY M. ALEXANDER, ESQ. - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02•-284089 7 1 0 6 2- C O 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE VS. CROWN EQUIPMENT CORPORATION File No. - 03-432 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for DANIEL DEARDORFF, ESQ. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group, Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER. ES ADDRESS: 690-LEE-OAa TELEPHONE: _(215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant DEC 0 1 2004 Date: A?xj ,91_ n!!?)y Seal of the Court BY E COURT: I- Prothonotary/Clerk, Civil Divis' Deputy 71062-02 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: DANIEL DEARDORFF, ESQ. 10 E. HIGH STREET CARLISLE, PA 17013 RE: 71062 SEAN BOYLE A COMPLETE COPY OF THE ENTIRE NON-PRIVILEGED PORTION OF YOUR FILE IN WHICH YOUR OFFICE REPRESENTED GIANT FOOD DISTRIBUTION IN THE CASE OF BOYLE-VS-GIANT FOOD DISTRIBUTION; BUREAU CLAIM# 2256457 Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security #: 193-68-5461 Date of Birth: 11-08-1968 SU10-533390 7 1 0 6 2- L 0 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SEAN BOYLE -VS- CROWN EQUIPMENT CORPORATION COURT OF COMMON PLEAS TERM, CASE NO: 03-432 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical. to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 12/01/2004 TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT DE11-531332 7 1 0 6 2- L 0 3 C O M M O N W E A =H H Or P E N N S Y L VAN T A COUNTY Or C U M B E R L AND IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -VS- CROWN EQUIPMENT CORPORATION TERM, CASE NO: 03-432 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUKKNTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 GIANT DISTRIBUTION CENTER OTHER DANIEL DEARDORFF, ESQ. OTHER RICHARD E. FREEBURN, ESQ. OTHER TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 11/11/2004 CC: TIFFANY M. ALEXANDER, ESQ. - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02--284089 71-062-COI- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE vs. CROWN EQUIPMENT CORPORATION File No. _ 03-432 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE; 4009.22 TO Custodian of Records for RICHARD E. FREEBURN. ESQ. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: * * * * SEE ATTACHED RIDER * * * * at The MCS Group, Inc., 1601 Market Street, Suite 800, Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER. ES ADDRESS: 690 LEE ROAD TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant /?? DEC 01 2004 Date: ?l joo . 4_ d'00y Seal of the Court BY E COURT: Prothonotary/Clerk, Civil Divi 10-t2 A Deputy 71062-03 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RICHARD E. FREEBURN, ESQ. 4415 N. FRONT STREET HARRISBURG, PA RE: 71062 SEAN BOYLE A COMPLETE COPY OF THE ENTIRE NON-PRIVILEGED PORTION OF YOUR OFFICE FILE IN WHICH YOUR OFFICE REPRESENTED SEAN BOYLE WITH REGARDS TO THE ACCIDENT IN 1/31/01 AT THE GIANT FOOD DISTRIBUTION CENTER LOCATED AT 1621 INDUSTRIAL DRIVE, CARLISLE, PA 17013 Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security #: 193-68-5461 Date of Birth: 11-08-1968 SU10-533392 7 1 0 6 2- 1,0 3 C:j .. c y ra-? '7 . ' i t C_d7 y4 } L C..'i 4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS Sean Boyle TERM, v. CASE NO: 03-432 Crown Equipment Corporation CERTIFICATE PREREQUISITE TO SERVICE OF A. SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 James I. Nelson, Esguire. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoena is sought to be served. (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate. (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: A116-7195- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS SeanBoyle TERM, V, CASE TfO: 03432 Crown Equipment Corporation NOTICE OF INTENT TO SERVE A SUBPOENA TO ]PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT' TO RULE 4009.21 Giant Distribution Center TO: Tiffany M. Alexander, Esquire I, James I. Nelson, Esquire, intend to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty (20) day notice period is waived or if no objection is made, then the subpoena may be served. If no objection is made the subpoena may be served. DATE: 119-4717,0054 Nelson, Esquire ,for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE MATTER OF: COURT OF COMMON PLEAS Sean Boyle TERM, V. CASE NO: 03-432 Crown Equipment Corporation OBJECTIONS TO SUBPOENA PURSUANT TO RULE 4009.21 objects to the proposed subpoena that is attached to these objections for the following reasons: DATE: Attorney for Defendant - COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Sean Boyle, VS. NO: 03-432 Plaintiff Crown Equipment Corporation, Defendant SUBPOENA TO PRODUCE DOCUME14TS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 To: Giant Distribution Center Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: the serial number for the Crown truck/lift involved in the Plaintiffs accident at 155 South Hanover Street, Carlisle, Pennsylvania 17013. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: James I. Nelson, Esquire Rominger, Bayley & Whare 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID #91144 Date: i 7. ?(.CXS % S al of the Court BY THE COURT, J Prothonotary/Clerk, Civil Division 6-ILL K' '/ i 41t _ ; ? , _ :; _? ;; "; , , <?; CI CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SEAN BOYLE -VS - COURT OF COMMON PLEAS TERM, CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. DATE: 03/07(2005 MCS o behalf ?,,Yo?Jf?,LC? TIFF 'M. A"/LEXAND R, ESQ. / Attorney f r DEFENDANT DE11-547430 7 1 0 6 2- L 0 4 C O M M O N W E AL T H OF P E N N S Y L VAN T. A COUNTY 0F CUMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -VS - TERM, CASE NO: 03-432 CROWN EQUIPMENT CORPORATION NOTICE TO PRODUCE DOCUKENTS 4009- [ Note: see enclosed list of locations 1 TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 CC: TIFFANY M. ALEXANDER, ESQ. - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 71-062-COI- >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.0 BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M,D. EMPLOYMENT OTHER OTHER MEDICAL RECORDS & HOSPITAL HILL X-RAY ONLY WORKER COMPENSATION RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-292361 73-062-COI- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE vs. CROWN EQUIPMENT CORPORATION File No. 03-432 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for JMR FOODS. INC. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group_ Inc.. 1601 Market Street_ Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER. ES ADDRESS: 690 LEE ROAD WAYNE. PA 19087 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant 500? L 0 bVW MAR 0 7 2005 Date: 4 Seal of the Court BY THE COURT: ProthonotarylClerk , Civil id d Deputy 71062-04 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: JMR FOODS, INC. 105 SO. SPORTING HILL RD. MECHANICSBURG, PA 17055 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING, BUT NOT LIMITED TO, ANY AND ALL NOTES, DOCUMENTS, REPORTS, WORKERS COMPENSATION CLAIM RECORDS, PERSONNEL TRAINING RECORDS, AND RECORDS OF ANY DISCIPLINARY ACTION TAKEN. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all employment records, applications, files, memoranda, compensation, time and attendance records, personnel records, payroll and salary reports and all medical records as an employee, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security #: 193-68-5461 Date of Birth: 11-08-1968 SU10-548166 7 1 0 6 2- L 0 4 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE TERM, -vs- CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/07/2005 TIFFANY M. ALEXANDER, ES Attorney for DEFENDANT DE11-547431 7 1 0 6 2- L 0 5 COMMONWEALTH OP P E N N S Y L VAN T A COUNTY OP C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -VS- CROWN EQUIPMENT CORPORATION INTENT TO SERVE A { Note: see enclosed list of locations ) TERM, CASE NO: 03-432 TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 CC: TIFFANY M_ ALEXANDER, ESQ. - 5415-19 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 73-062-COI- >>> LOCATION LIST <<< PAGE- 1 LOCATION NAME RECORDS REQUESTED JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.0 BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M.D. EMPLOYMENT OTHER OTHER MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY WORKER COMPENSATION RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-292361 7 1 0 6 2- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE VS. CROWN EQUIPMENT CORPORATION File No. 03-432 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for SAFECO INS. COMPANY (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc., 1601 Market Street. Suite 800. Philadelphia PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER ES ADDRESS: 690 LEE ROAD SUITE 300 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 0 7 2665 Date: ?' rS Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Divi Deputy 71062-05 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: SAFECO INS. COMPANY PO BOX 461 ST. LOUIS, MO 63166 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. SEE ATTAC14ED Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security k: 193-68-5461 Date of Birth: 11-08-1968 SU10-548168 7 1 0 6 2- L 0 S Please obtain a complete copy of the entire contents of the ciaim gale of Sean Boyle H,ho -,yas employed by JTgR Foods including but not limited to any and all notes, doc€ menu, rpoorts, medical records, attendance records, wage records, workers cempeusation claim records, personnel training records and records of auN, ;bbscirrlinary action taken against bar. Boyle. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE TERM, -vs- CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/07/2005 TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT DE11-547432 71062-1,06 C O M M O N W E A L T H OF' P E NN S Y L VANS A COUNT-sr OP CUMBER LAN I3 IN THE MATTER OF: SEAN BOYLE -VS- COURT OF COMMON PLEAS TERM, CASE NO: 03-432 CROWN EQUIPMENT CORPORATION SERVE A PURSUANT TO ( Note: see enclosed list of locations ) TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 CC:-TIFFANY M. ALEXANDER, ESQ. - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 7 1 0 6 2- C 0 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.0 BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M.D. EMPLOYMENT OTHER OTHER MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY WORKER COMPENSATION RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-292361 7 1 0 6 2- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE VS. CROWN EQUIPMENT CORPORATION File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER. ES ADDRESS: 690 LEE ROAD WAYNE. PA 19087 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 0 7 HG55 Date: - 'P ao'-n?5 Sea] of the Court BY THE COURT: ProthonotarylClerl Civ9Divi Deputy 71062-06 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR OSHA US DEPARTMENT OF LABOR 49 N. PROGRESS AVE. HARRISBURG, PA 17109 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. *****SEE ATTACHED***** Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security #: 193-68-5461 Date of Birth: 11-08-1968 SU10-548170 7 1 0 6 2- L 0 6 Please obtain under the Freedom of Information Act, a complete copy of the entire contents of the OSHA investigation file pertaining to the investigation of three (3) accidents involving Sean Boyle which occurred at the Giant Food Distribution Warehouse located at 1621 Industrial Drive in Carlisle, Pennsylvania on January 31, 2001, August 30, 2000, November 30, 2000 including but not limited to copies of any and all citations issued by OSHA to Giant Food Distribution for this and/or any other accident occurring at that facility. CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE TERM, -VS- CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/07/2005 TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT DE11-547433 7 1 0 6 2- 1, 0 7 C O M M O N W E A L T H OP P E NN S Y L VAN T A COUNTY OP C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -vs- TERM, CASE NO: 03-432 CROWN EQUIPMENT CORPORATION SERVE A TO PRODUCE ) RULE 4009.21 [ Note: see enclosed list of locations ) TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 CC: TIFFANY M. ALEXANDER, ESQ. - 5415-18 Any questions regarding this matter, contact MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 7 1 0 6 2- CO It >>> LOCATION LIST <<< ON NAME JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.O. BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M.D. RECORDS EMPLOYMENT OTHER OTHER MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY WORKER COMPENSATION RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) PAGE: 1 DE02-292361 7 1 0 6 2- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE vs. CROWN EQUIPMENT CORPORATION File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** E ATTACHED RIDER **** at The MCS Group. Inc 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER. ESO. ADDRESS: 690 LEE ROAD SUITE 300 WAYNE. PA 19087 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 0 7 2 5 Date : ??ClS Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Divi Deputy 71062-07 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL 246 PARKER STREET CARLISLE, PA 17013 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire hospital medical billing file including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/ prescription records, nurse's notes, doctor's comments, dietary restrictions, and all patient consent or refusal of treatment, procedures, tests, and/or medication, lab and diagnostic test results, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care, treatment, admission, discharge, or emergency care pertaining to: Dates Requested: up to and including the present. Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security #: 193-68-5461 Date of Birth: 11-08-1968 SUIO-548172 7 1 0 6 2- 1, 0 7 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE TERM, -vs- CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/07/2005 TIFFANY M. ALEXANDER, Attorney for DEFENDANT DE11-547434 71-062-1,08 C O M M O N W E A L T H OP P E NN S Y L VAN I A COUNTY OP C UMBER LAN O IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -VS- CROWN EQUIPMENT CORPORATION TO SERVE A SUBPOENA TO [ Note: see enclosed list of locations l TERM, CASE NO: 03-432 TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena- If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 CC: TIFFANY M. ALEXANDER, ESQ. - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 7 1 0 6 2- C 0 1 >>> LOCATION LIST <<< JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.0 BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M.D. PAGE: I RE EMPLOYMENT OTHER OTHER MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY WORKER COMPENSATION RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-292361 7 1 0 6 2- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE vs. CROWN EQUIPMENT CORPORATION File No. 03-432 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE HOSPITAL (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The M Group. Inc . 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER. ESO. ADDRESS: 690 LEE ROAD SUITE 300 WAYNE. PA 19087 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 0 7 KJ5 Date: ?C LN Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Div t n 6 Deputy 71062-08 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: CARLISLE HOSPITAL 246 PARKER STREET CARLISLE, PA 17013 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Any and all x-ray films and reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security !f: 193-68-5461 Date of Birth: 11-08-1968 SU10-548174 7 1 0 6 2- L 0 8 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE TERM, -VS- CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, ESQ, certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/07/2005 TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT DE11-547435 710 62 -L O 9 C O M M O N W E A L,T H OF' P E NN S Y L VAN 2 A COUNT Y OP C UMBER LAN O IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -VS- CROWN EQUIPMENT CORPORATION TERM, CASE NO: 03-432 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ] TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 CC: TIFFANY M. ALEXANDER, ESQ_ - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 -71-062-COI- >>> LOCATION LIST <<< JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.O. BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M.D. EMPLOYMENT OTHER OTHER MEDICAL RECORDS 6 HOSPITAL BILL X-RAY ONLY WORKER COMPENSATION RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) PAGE: I DE02-292361 7 1 0 6 2- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE VS. CROWN EQUIPMENT CORPORATION File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for MAC RISK MANAGEMENT (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc- 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER. ES ADDRESS: 690 LEE ROAD TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 0 7 2Gu5 Date: . J'a P, ae?Y?\r Seal of the Court BY THE COURT: Prothonotary/Clerk, 71062-09 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: MAC RISK MANAGEMENT PO BOX 9227 BOSTON, MA 02209 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. INCLUDING, BUT NOT LIMITED TO, ALL FILE INVESTIGATION MATERIALS, MEDICAL RECORDS, MEDICAL BILLS AND PHOTOGRAPHS. (WORKERS COMPENSATION CLAIM FILE NUMBER = WC00115001) Please call for prior approval for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire workers compensation file, including but not limited to medical reports and/or records, claims and all correspondence, documentation supporting plaintiff's claim, payments including dates of payments, payee and reasons for payments, including any and all such items as may be stored in a computer database or otherwise in electronic form, pertaining to: Dates Requested: up to and including the present. Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security N: 193-68-5461 Date of Birth: 11-08-1968 SUIO-548176 7 1 0 6 2- 1,0 9 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE TERM, -VS- CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/07/2005 TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT DE11-547436 7 1 0 6 2- L 1 0 C O M M O N W E A L T H OP P E NN S Y L VANS A C O UN T Y OP C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -vs- TERM, CASE NO: 03-432 CROWN EQUIPMENT CORPORATION SERVE A TO PRODUCE DOCUMENTS AND 4 [ Note: see enclosed list of locations ] TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice- You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 CC: TIFFANY M. ALEXANDER, ESQ. - 5415-18 Any questions regarding this matter, contact MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 '72-062-C:03- >>> LOCATION LIST <<< RECORDS PAGE: 1 JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.0 BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M.D. EMPLOYMENT OTHER OTHER MEDICAL RECORDS 6 HOSPITAL BILL X-RAY ONLY WORKER COMPENSATION RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-292361 7 1 0 6 2- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE VS. CROWN EQUIPMENT CORPORATION File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for ALEXANDER SPRING REHAB. INC. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group, Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER. ES ADDRESS: 690 LEE ROAD TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAP. 0 ru5 Date: :'-'p . Seal of the Court BY THE COURT: ProthonotaryfClerk, Civil Dive n eputy 71062-10 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: ALEXANDER SPRING REHAB, INC. 27 BROOKWOOD AVENUE CARLISLE, PA 17013 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : SEAN BOYLE 158 E. LOLTPHER STREET„ Social Security #: 193-68-5461 Date of Birth: 11-08-1968 SU10-548178 7 1 0 6 2- 1,1 0 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SEAN BOYLE -vs- COURT OF COMMON PLEAS TERM, CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/07/2005 TIFFANY M. ALEXANDER, Attorney for DEFENDANT DE11-547437 7 1 0 6 2- 1, 1 1 COMMONWEALTH OP P E N N S Y L VAN Ilk COUNTY OF, C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -VS- CROWN EQUIPMENT CORPORATION TERM, CASE NO: 03-432 NOTICE OF INTMgT TO SERVE A SUBPOENA TO PRODUCE DOCUbONTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 ( Note: see enclosed list of locations ) TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 CC: TIFFANY M. ALEXANDER, ESQ. - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 7 1 0 6 2- C O 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.O. BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M.D. EMPLOYMENT OTHER OTHER MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY WORKER COMPENSATION RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-292361 73-062-COI- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE VS. CROWN EQUIPMENT CORPORATION File No. 03-432 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for APPALACHIAN ORTHOPEDIC CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER. ES ADDRESS: 690 LEE ROAD SUITE 300 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant MAR 0 Date: )? ?[Y3? Seal of the Court BY THE COUR4C?ivil Prothonotary/Clon Deputy 71062-11 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: APPALACHIAN ORTHOPEDIC CENTER I DUNWOODY DR. CARLISLE, PA 17013 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : SEAN BOYLE 158 E. LOUTIRER STREET„ Social Security N: 193-68-5461 Date of Birth: 11-08-1968 SU10-548180 7 1 0 6 2- L,1 1 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE TERM, -VS- CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, ES certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/07/2005 TIFFANY M. ALEXANDER, Attorney for DEFENDANT DE11-547438 71062-L,3-2 C O M M O N W E A T =H H OP P E NN S Y L VAN T A COUNTY OF, C UM B E R L AND IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -v5- CROWN EQUIPMENT CORPORATION SERVE A SUBPOENA TO ( Note: see enclosed list of locations ) TERM, CASE NO: 03-432 TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M_ ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 CC: TIFFANY M. ALEXANDER, ESQ. - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 7 1 0 6 2- C O 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.O. BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M.D. EMPLOYMENT OTHER OTHER MEDICAL RECORDS & X-RAY ONLY WORKER COMPENSATI MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, MEDICAL, BILLING, HOSPITAL HILL )N RECORDS AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) AND X-RAY(S) DE02-292361 7 1 0 6 2- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE VS. CROWN EQUIPMENT CORPORATION File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for THOMAS J GREEN M D (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** E ATTACHED RIDER **** at The MCC Group. Inc 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER. ES ADDRESS: 690 LEE ROAD TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant VAR 0 7 Nu'5 Date: P Seal of the Court BY P T E COURT: Prothonotary/Clerk, Civil ivisi? / -6eputy ?- 71062-12 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: THOMAS J. GREEN, M.D. 1 DUNWOODY DR. CARLISLE, PA 17013 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security f/: 193-68-5461 Date of Birth: 11-08-1%8 SU10-548182 7 1 0 6 2- L 1 2 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE TERM, -VS - CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, E certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/07/2005 TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT DE11-547439 7 1 0 6 2- I, 1 3 C O M M O N W E AL T H OP P E NN S Y L VAN T A COUNTY OF' C UMBER LAN D IN THE MATTER OF: SEAN BOYLE -VS- CROWN EQUIPMENT CORPORATION )F INTENT TO SERVE A COURT OF COMMON PLEAS TERM, CASE NO: 03-432 ( Note: see enclosed list of locations ) T0: KARL E. ROMINGER, ESQ_, PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 CC: TIFFANY M. ALEXANDER, ESQ. - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 7 1 0 6 2- C O 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.O. BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M.D. EMPLOYMENT OTHER OTHER MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY WORKER COMPENSATION RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-292361 7 1 0 6 2- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE VS. CROWN EQUIPMENT CORPORATION File No. 03-432 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for WALTER C PEPPELMAN. JR.. D .O. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc., 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER. ESO. ADDRESS: 690 LEE ROAD SUITE 300 WAYNE. PA 19087 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant z' MAR., 0 r u5 Date: ? , Seal of the Court BY HE COURT: Prothonotary/Clerk, Civil Di on 2 Deputy 71062-13 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR WALTER C. PEPPELMAN, JR., D.O. 805 SIR THOMAS COURT SUITE 3 HARRISBURG, PA 17109 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security #: 193-68-5461 Date of Birth: 11-08-1968 SU10-548184 7 1 0 6 2- L 1 3 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE TERM, -VS- CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/07/2005 TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT DE11-547440 71062-1,14 C O M M O N W E A L T H OE P E NN S Y L VAN T A COUNTY OP C UMBER LAN D IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -VS- CROWN EQUIPMENT CORPORATION TERM, CASE NO: 03-432 TO PRODUCE DOCUMENTS .2 [ Note: see enclosed list of locations ) TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena- If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 CC: TIFFANY M. ALEXANDER, ESQ. - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 7 1 0 6 2- C 0 1 >>> LOCATION LIST <<< JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.0 BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M.D. PAGE: I EMPLOYMENT OTHER OTHER MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY WORKER COMPENSATION RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DR02-292361 73-0452-COI- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE vs. CROWN EQUIPMENT CORPORATION File No. SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO Custodian of Records for B ,LVE.DERE MEDICAL CENTER (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group Inc. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER, ESQ. ADDRESS: 690 LEE ROAD SUITE 300 WAYNE. PA 19087 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant Date: Seal of the Court BY T E COURT: Prothonotary/Clerk, Civil Divi Io Deputy 71062-14 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BELVEDERE MEDICAL CENTER 850 WALNUT BOTTOM ROAD CARLISLE, PA 17013 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security #: 193-68-5461 Date of Birth: 11-08-1968 SU10-548186 71062-1,14 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE TERM, -VS- CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/07/2005 TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT DE11-547441 7 1 0 6 2- L 1 5 C O M M O N W E A L T H O Y P E N N S Y L VAN T A COUNT Y OP C U M 13E R L AN D IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -VS- CROWN EQUIPMENT CORPORATION SERVE A SUBPOENUI TO TERM, CASE NO: 03-432 2 ( Note: see enclosed list of locations TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice- You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 CC: TIFFANY M. ALEXANDER, ESQ. - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET 1800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 7 1 0 6 2- C 0 1 >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.O. BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M.D. EMPLOYMENT OTHER OTHER MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY WORKER COMPENSATION RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-292361 7 1 0 6 2- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE VS. CROWN EQUIPMENT CORPORATION File No. 03-432 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for CARLISLE IMAGING ASSOCIATES (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc., 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER. ES ADDRESS: 690 LEE ROAD TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant tMAR O ri,? Gu: Date: ocGx?? Seal of the Court BY THE COURT: Prothonotary/Clerk, Civil Div, ? aL o ? / ?/G2!ul. Deputy C 71062-15 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR CARLISLE IMAGING ASSOCIATES P.O. BOX 100-101 NOBLE BLVD., STE 104 CARLISLE, PA 17013 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security #: 193-68-5461 Date of Birth: I1-08-1968 SU10-548188 7 1 0 6 2- L 1 5 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE TERM, -VS - CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4005.22 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/07/2005 TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT DE11-547442 7 1 0 6 2- L 1 6 COMMONWEALTH OF, P E N N S Y L VANS A COUNT Y OF' C U M B E R L -AND IN THE MATTER OF: COURT OF COMMON PLEAS SEAN BOYLE -VS- CROWN EQUIPMENT CORPORATION TERM, CASE NO: 03-432 NOTICE OF INTENT TO SERVE A SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 [ Note: see enclosed list of locations ) TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M_ ALEXANDER, ESQ_ intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14(2005 CC: TIFFANY M. ALEXANDER, ESQ_ - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 7 1 0 6 2- C O 1 >>> LOCATION LIST <<< LO RECORDS PAGE: 1 JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.O. BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M.D. EMPLOYMENT OTHER OTHER MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY WORKER COMPENSATION RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-292361 7 1 0 6 2- C 0 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE VS. CROWN EQUIPMENT CORPORATION File No. 03-432 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for BROOKW OOD FAMILY MEDICINE (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Group. Inc.. 1601 Market Street. Suite 800. Philadelphia. PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M. ALEXANDER. ES ADDRESS: 690 LEE ROAD WAYNE. PA 19087 TELEPHONE: j2151246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant V1AR 0 7 2035 Date: ? c? Seal of the Court BY T E COURT: Prothonotary/Clerk, Civil Divisi6d Deputy 71062-16 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: BROOKWOOD FAMILY MEDICINE 49 BROOKWOOD AVE. CARLISLE, PA 17013 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present, Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security k: 193-68-5461 Date of Birth: 11-08-1968 SU10-548190 7 1 0 6 2- L 1 6 CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 IN THE MATTER OF: SEAN BOYLE -VS- COURT OF COMMON PLEAS TERM, CASE NO: 03-432 CROWN EQUIPMENT CORPORATION As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. certifies that (1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty days prior to the date on which the subpoena is sought to be served, (2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate, (3) No objection to the subpoena has been received, and (4) The subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. MCS on behalf of DATE: 03/07/2005 TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT DE11-547443 7-'L 0 G2 -1,1 7 COMMONWEALTH OP P E NN S Y L VANS A COUNT Y OP C UMBER LAN D IN THE MATTER OF: SEAN BOYLE -VS- CROWN EQUIPMENT CORPORATION SERVE A SUBPOENA TO [ Note: see enclosed list of locations ) COURT OF COMMON PLEAS TERM, CASE NO: 03-432 TO: KARL E. ROMINGER, ESQ., PLAINTIFF COUNSEL MCS on behalf of TIFFANY M. ALEXANDER, ESQ. intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned an objection to the subpoena. If the twenty day notice period is waived or if no objection is made, then the subpoena may be served. Complete copies of any reproduced records may be ordered at your expense by completing the attached counsel card and returning same to MCS or by contacting our local MCS office. DATE: 02/14/2005 CC: TIFFANY M. ALEXANDER, ESQ. - 5415-18 MCS on behalf of TIFFANY M. ALEXANDER, ESQ. Attorney for DEFENDANT Any questions regarding this matter, contact THE MCS GROUP INC. 1601 MARKET STREET #800 PHILADELPHIA, PA 19103 (215) 246-0900 DE02-292361 7a-062--C01- >>> LOCATION LIST <<< PAGE: 1 LOCATION NAME RECORDS REQUESTED JMR FOODS, INC. SAFECO INS. COMPANY OSHA CARLISLE HOSPITAL CARLISLE HOSPITAL MAC RISK MANAGEMENT ALEXANDER SPRING REHAB, INC. APPALACHIAN ORTHOPEDIC CENTER THOMAS J. GREEN, M.D. WALTER C. PEPPELMAN, JR., D.0 BELVEDERE MEDICAL CENTER CARLISLE IMAGING ASSOCIATES BROOKWOOD FAMILY MEDICINE RODNEY HOUGH, M.D. EMPLOYMENT OTHER OTHER MEDICAL RECORDS & HOSPITAL BILL X-RAY ONLY WORKER COMPENSATION RECORDS MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) MEDICAL, BILLING, AND X-RAY(S) DE02-292361 73-062--COI- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SEAN BOYLE File No. 03-432 vs. CROWN EQUIPMENT CORPORATION SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Custodian of Records for RODNEY HOUGH M.D. (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: **** SEE ATTACHED RIDER **** at The MCS Grouo Inc 1601 Market Street Suite 800 Philadelphia- PA 19103 You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek, in advance, the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: NAME: TIFFANY M ALEXANDER ESO ADDRESS: 690 LEE ROAD SUITE 300 WAYNE. PA 19087 TELEPHONE: (215) 246-0900 SUPREME COURT ID #: ATTORNEY FOR: Defendant BY TgE COURT: Prothonotary/Clerk, Civil MAR ,5 0 i Ll;u,i Date: Seal of the Court 71062-17 EXPLANATION OF REQUIRED RECORDS TO: CUSTODIAN OF RECORDS FOR: RODNEY HOUGH, M.D. 49 BROOKWOOD AVENUE CARLISLE, PA 17013 RE: 71062 SEAN BOYLE Prior approval is required for fees in excess of $100.00 for hospitals, $50.00 for all other providers. Entire medical, billing, and diagnostic file, including but not limited to any and all records, correspondence to and from the consulting and/or treating physicians, files, memoranda, handwritten notes, history and physical reports, medication/prescription records, medical billing and payment records, x-ray films and tests with subsequent reports, including any and all such items as may be stored in a computer database or otherwise in electronic form, relating to any examination, consultation, diagnosis, care or treatment pertaining to: Dates Requested: up to and including the present. Subject : SEAN BOYLE 158 E. LOUTHER STREET„ Social Security #: 193-68-5461 Date of Birth: 11-08-1968 SU10-548192 7 1 0 6 2- L 1 7 Curtis R. Long Prothonotary office of the Protbonotarp . Cumberranb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 03- 442,2_ CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573