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Home My WebLink About98-03330 u\".- \t~ "~ ;'~ "!j ';:l'~ ..'/:~ .,)'5 .':~: - ;\', . . ~ II) 3 . ... :t ~ '. -, "'00_-1.;. "J ...': , J'\ lit ~ , , , <I -0 ~ ~ '\ ". " '" '~;jl., ,~, .~~ "< ;~ " \ , \ - j !l ,,;,:/1 i~fti:t ,_..,iJf,v -",,,~,, :~'l-if - t ~ r -' . . .') ~, ~ ()-.. a ~~ " I I JAMES H. TURBAN and TRACY L. TURBAN, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. NO. 98.3330 CIVIL TERM ALICIA MURAWSKI, RONALD M. MURAWSKI and SHEILA MURAWSKI, Defendants CIVIL ACTION. LAW JURY TRIAL DEMANDED ANSWER 1. - 26. Paragraphs 3. - 5. are admitted; it is further admitted that the accident giving rise to the instant Civil Action occurred on July 17, 1996, at approximately 12:40 p.m., on Market Street, Lemoyne, Cumberland County, Pennsylvania; it is further admitted that at that time and place, Defendant, Alicia Murawski Bubb, was operating a 1989 Chevrolet Berretta, Pennsylvania License Plate No. AJK8512 owned by her parents, Ronald and Sheila Murawski; however, the Defendant was operating the motor vehicle in a westbound direction on Market Street, not in an eastbound direction as alleged in the Complaint; it is further admitted that at that time and place, the Defendant's vehicle came in contact with the rear of the motor vehicle being operated by Plaintiff, James H. Turban; the remaining averments contained in the Plaintiffs Complaint are denied pursuant to Pa. R.C.P. 1029(e); it is specifically denied that the Defendants, Ronald and Sheila Murawski, were in any way negligent or that they negligently entrusted their vehicle to their daughter; on the i .';. ' "" C@ -- r~ i-; \-::-, c-: lJj , c.) ~':t: ,~ ,'... 'I. :._J ,-' , '~.J , -- I '.-;") ,-, elf" ;~~ l..r.."-- :.-~:! l . -- ~ .~ :.'; Ll.-". . c...... "--') ..,'- L':". 0:; ~::5 0 0'1 (,) @J , . , I ~ " fl ';j ...- 0' f::: V>~ r 1~ "-, -:z ~ is ,-.:. ::").::" ~- '" UJQ ()-:;.) ~ U(. ) d__ '. :::L \i> u: . (J.- :.~;2 ~ u.. La.:\'- C['\-', '.f') : '[.''j h ~ f fVJ 0" 'I;:: '\) ('.. LUI.I ,.,~ -;;1' -.Jl1 ' '.lJL~ -- Cl 0::-- ::3 (":10... '- "~ -,- ,-- -J "0.; ,"- ~ ". co :::J ~~ 0 ,1'\ U ct: ~ .. J j' , I Q) d 'H 'M 'tl - :J: ,.., lO E' lO,.., . 1-11 III C::'M i CO Q) 'tl'M o Q) Eo< c::.c:: o::.c:: = :J: 0 ,.., lO UJ ... lO ;1. ~. ,.., . . IS ..:l ~ 'M c:: c:: 'M'tl > lO lO ; .>: c:: I 'M .0.0 III lO il () 1-11-1 :J: c:: .j.l.. r- ::l ::l lO'M 0 "~:T < 0 E-<E-< 1-1'>: 'M M ::l III r/J .j.J M . . ::;: :J:'M () "" ~ !:l M :I:..:l lO'>: ..:e l~tIl~. ~ , lO 1-1 III <Xl III >< 'M ::l :J: ,.., '" Q) () ()::;: lO 'M ~ 00 ,.., E lO 'M 1-1 >. ~::l Po. !: ~ lO 1-1 ,.., . ::l 'M I .-,Eo< ..:e::;:::;: ()I ... J" .." " '-' JAMES H. TURBAN and TRACY L. TURBAN, his wife, Plaintiffs v. ALICIA MURAWSKI, RONALD M. MURAWSKI and SHEILA MURAWSKi, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 98-3330 CIVIL TERM : CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY: Please enter the undersigned's appearance on behalf of the Defendants with regard to the above-captioned matter. Respectfully submitted, '- NEALON & GO c~~ By: James G. Nealon, Esquire Atty.I.D.#46457 30'1 Market Street -- 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 >- .. ) '. '. ., -, ,.., I J. I C .. () . , i~i~ " .. '.1_ .. () , .'. c." ~)'l ~~ .. 1.1:. : . , - :,1,. (.'1 () J r:;1 () [~~ j 1 ) 1 1 1 I I 1 I I 1 I I 1 I I I 1 ) 1 I l J 1 I I I i , ] I 1 ) J I 1 I _:j "'j ..:::'" '.':.:: ',,;HEJ:. IFF" ... !i:__ i 'j;' i ,':l',} r~ 'Joy ',);-'(1 CASE rlO: lCI'JU-I/'-:'L.i01 J. COIHIClNHEALTII OF F'E:tllL;','LVAli LA: COUrlTY OF ClIIHIEF:LI,lIl:' TlIflBMI J MjE~~.1:LET AI. VS. MURAHSKI ALICIA ET AI. R. Thomas I\lino , Stloriii, who baing dl1ly sworn ~ccording to law, says, that he macie a d]_lio.~n~~ ~;'2arch ;)nd inquiry lor thf~' hoilhin named defendant, to lIit: !'IURAW_SI.:r ~IIEIL,~__________ but was unable to locaLe deputized the sherIff of Her In his ballillick. He th(?reiorE.' r:LEAfiFIi;:LQ_____. County. Pennsylvania. to serve the '"iUnn \'IRIT OF c;Ul'lJ'PJN:3 On lOth, 19'38 this office was in receipt of July -' the attached return f~om CLEARFIELD County, Pennsylvania. Sherif:f's Costs: Dod<etinq Out of County Surcharge So answe~s: ~ ~, SnerlIi 5.00 .0el 6.00 glL.0~ MILSPAW & BESHORE 07/10/199>3 ::::n a;: :u~:~r::~o 19 'If A.D. before flH? ~ Q.~ --- ..v_ __ _' ... yrot onotar1~ I , I I I I J I I I I 1 I I I I , :!:LL j. ;' I',: (,1\::.;[ !Ii:): 1 i::'-;i'.l 'c'I,'~~ :t_, ; CCIi'il'ICltnIE'\LTH '-'I' ;'Dltl,.':',,'!;d:; (',: COU1:TY i:Jr (_Ul'!:-'~:L':_.;\t;~-J I!dJil.:hn__-.1 I\JJX=; 11 t:_~ V::'i. nlUU~~.~_~~t;L_6.kI:~I~. ..~_I_"..'\:" R. ThOITi;:;l::;; i\.l ~L.!.l5~~_, ':~;::;;: ~ 1 ;: i. ',:h:, ~": .Llie; d';J I '/ ;'.'.i'~,I;:!: Q"::I~-,:;~'rd.ln~; to la,1,,', B<.l)'3, t,fi0r, r':":' :n;]d,:' ;J ,jlJ..L~l(;'nt .':"'dl'C:h aLd Inqui: >' fur lh;_',' .'.l'.:l.;."n named dCJfl:?ncian t~. l~ ,) 'I,' 1.:.: : _-1n,~.f:~A~Litl._j~L_.L~.~~J,1~.~ ------~,--~._~---_._._-_._---- -.--. -.-..-.....+ -.--.,.--" ---~--_.._--,-- .._--. -----..----...-. ----.-.-..----- _.-~ .---......---.".--. .---------..---.- but "'<1,; unab1>? t..c' 10cd+"c' ........_.._.lig::.....___ ,in hIS "'Jlll,'c: ieI-. E..;.:- therc'.flJ!'"',:' deputized the Sh~21'ifi oi ____~-=.l~l!CA~::;TEB---,-.--.----- r~~O::llnty. P':!nn~lyl\:3.l1i'3. to serve th\:! 'n' i thin _SU_r~::';TI'CUTl;~__~(LRII_.QE~5JLtE:tQ!L'2._._._-_.----.--- ---~-----_._--~-_._--_.._..---,...._._.._,..,-_.._------.-....---.-.-----...---...-..--.--------.--- D n ...J1.V (1 U S 'r~~._,_.__:ltt~J__._.L?~1.:;.,____._, ._~---_.~--' t~lt;;,; ':,1.11C~) -V:,],..? ~ '" ...:..,i L-CIC~::'ipt. of the attached return iron; LAi{C/l...~_I.t~E________,__ C'JUfl i:. /'. Peons}' 1 vania. Sheriff's Costs: So C4nswec's;~ ~-~ ;\~ 1 nom;;f~';; J\J.~nE.', ::,hE'r.1IJ.: Dock".2tinq Out oi CCI~lnt y Surcharge Dep. Lancaster Co 16. !Zl0 '';:.J. ~7JO f:,. Q)fZi 4:. =:t?i S'/:J. -.2u r;IL~;F'i~\4 t BESHGHE C,,g.l 134 / 1 r:!~le, Sworn and zU~5cribed to b~fore me this 41(;::._ d"y of ~,-~Y ______. 1':1 9'L- A. D. q~~ {L ~I_~-'-__"'_' r-r()tl'l(Jnot.;~l~ y .":---'--..--.-..-.---.-,' . ...-........... . . ...... CJ !.!J ". a 6\ ~...: (.1....._': I:J6' r~J -- .--. ., ~': 'r.,C) ~-) 1.1... () '.,1, C. . ~b ",/ -I -., ===) o:J 0, :;c.-; . ~.". ,. ,,1 ~::( ... --I (f) " "r- ., ~ ()';~J. \. ,::" .. c;;..: -1-' '. ,-.,...~._,;....'\ .'\ ' (.'if 1 '. '. \, c:.'" ;" ".' t,"; JUL IG 3 10 PH I SU r L .'; I", "I I" .', :'1' L ; ,'~. II ,., JAMES H. TURBAN and TRACY L TURBAN, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 98-3330 CIVIL TERM ALICIA MURAWSKI, RONALD M. MURAWSKI and SHEILA MURAWSKI, Defendants CIVIL ACTION - LAW : JURY TRIAL DEMANDED NOTICE OF PRAECIPE TO ENTER JUDGMENT OF NON PROS TO: Neil A. Grover, Esquire MILSPAW & BESHORE P.O. Box 946 Harrisburg, PA 17108 DATE OF NOTICE: December 18.1998 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO FILE A COMPLAINT IN THIS CASE. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE. A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR RIGHT TO SUE THE DEFENDANT AND THEREBY LOSE PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Thomas E. Cheffins, Court Administrator One Courthouse Square, 41h Floor Carlisle, PA 17013 (717)240-6200 Respectfully submitted. James G. Nealon. III, Esquire Atty.I.D.#46457 301 Market Street - 9th Floor P.O. Box 865 Harrisburg, PA 17108-0865 (717) 232-9900 '- 0' '.- . Cr; - to_.; .-L :~~~ ~ ~ 1,-- c-: ("-, UI~-:- ~'~(--' :r:: 'J4; l._._-.. 0.. :.\ ~'~~ . ... (r't : (,J '(n c.,:;' , N ,"J<; Wl_. ct ::~~ '-' I;J(;] l.... ~ ~:~ (l.. 1'--- C. W,. (() ~:.1 U (J"\ U 5. Defendant Sheila Murawski is an adult individual whose last known address is 502 Mary Street, Houtzdale, Clearfield County, Pennsylvania 16651. 6. In the early afternoon of July 17, 1996, Plaintiff James H. Turban was occupying a motor vehicle that was at a complete and proper stop behind turning traffic in the east bound lane on Market Street in or near Camp Hill, Cumberland County, Pennsylvania. 7. At that date and time, Defendant Alicia Murawski, aJk/a Alicia Bubb (hereinafter Defendant-driver) was traveling east on Market Street in or near Camp Hill, Cumberland County, Pennsylvania. 8. At that date and time, Defendant-driver was operating a motor vehicle identified as a red, )989 Chevrolet Berretta, Pennsylvania license plate number AJK8512. 9. The vehicle operated by Defendant-driver was owned by Defendants Ronald M. and Sheila Murawski. 10. The vehicle operated by Defendant-driver was titled and registered to Defendants Ronald M. and Sheila Murawski. 11. Defendants Ronald M. and Sheila Murawski are the parents of Defendant-driver. 12. At approximately )2:40 p.m., the vehicle operated by the Defendant-driver struck the rear of the vehicle occupied by Plaintiff James H. Turban. 13. The conduct of the Defendant-driver in allowing her vehicle to strike the properly stopped vehicle of Plaintiff James H. Turban was negligent, careless, reckless and dangerous. 2 14. As a direct and approximate result of the negligent, careless, reckless and dangerous conduct of the Defendant-driver, Plaintiff James H. Turban suffered injuries requiring extended medical care and treatment. 15. As a direct and proximate result of the injuries received as a result of the collision of July 17, 1996, the Plaintiff James H. Turban suffered physical, emotional and mental pain and anguish, as well as a loss oflife's pleasures. 16. As a direct and proximate result of the individual and collective negligent, reckless, careless and dangerous conduct of the Defendants, Plaintiff James H. Turban has suffered and will continue to suffer financial losses and suffer physically and emotionally into the future. COUNT I-NEGLIGENCE 17. Paragraphs I through ) 6 are incorporated herein by reference as if set forth in full. 18. Defendant Alicia Murawski, aIkIa Alicia Bubb, owed a duty to the Plaintiff James H. Turban while she was operating a motor vehicle on July 17, ) 996. )9. More specifically, the personal injuries suffered by Plaintiff James H. Turban as a result of this motor vehicle accident were a direct and proximate result of the negligent, careless, reckless, dangerous and indifferent acts or failures to act of Defendant Alicia Murawski, aIkIa Alicia Bubb, which included but are not limited to the following: a. Failing to keep proper and adequate control of the motor vehicle that she was driving; 3 b. Failing to take due and proper cognizance of the conditions and layout of the roadway upon which she was driving; c. Driving her vehicle at a rate of speed in excess of that at which she could maintain proper and adequate control of the vehicle. d. Operating a vehicle in a manner which was careless and recklessly indifferent to the rights, safety and position ofthe Plaintiff; e. Operating a vehicle in a manner which endangered persons and property, and in violation of the Motor Vehicle Code of the Commonwealth of Pennsylvania; f. Operating a vehicle without due regard for the assured cleared distance ahead; g. Driving a vehicle at a rate of speed excessive to the ascertainable conditions of the roadway; h. Permitting her vehicle to strike the rear of the vehicle occupied by the Plaintiff; i. Failing to apply her brakes; j. Failing to apply her brakes in time to avoid the collision; k. Negligently applying her brakes; 1. Failing to observe the Plaintiff's vehicle on the highway; m. Failing to operate her vehicle in accordance with existing traffic conditions and traffic controls; and n. Failing to keep a reasonable lookout for other vehicles lawfully on the road. 4 20. As a result of the force of the impact caused by the negligent, careless, reckless, dangerous and indifferent acts and failures to act of the Defendant-driver, Plaintiff James H. Turban suffered physical injuries, including but not limited to injuries to his neck and right arm, with pain and stiffhess between his shoulders and with severe headaches and kinesalgia. WHEREFORE, Plaintiffs respectfully request that judgment be entered in their favor and against Defendant Alicia Murawski, a/kJa Alicia Bubb, in an amount in excess of $25,000.00 with interest thereon, costs associated with suit, and any attorney's fees allowed by law, if any. COUNTll-NEGLIGENTENTRUSTMENT 21. Paragraphs 1 through 20 are incorporated herein by reference as if set forth in full. 22. On the date and time at issue, the Defendant-driver was operating a motor vehicle owned by the remaining Defendants with their permission. 23. As the parents of the Defendant-driver, Defendants Ronald M. and Sheila Murawski, knew or should have known that when they allowed her to use of their motor vehicle or otherwise supplied it to their daughter for her personal use, their daughter had a tendency for carelessness or recklessness in the operation of some or all motor vehicles; that their daughter was occasionally inattentive when operating a motor vehicle; .that their daughter was unfamiliar with the specific vehicle at issue; and/or that their daughter had the propensity for reckless conduct in the operation of motor vehicles. . 24. The injuries suffered by Plaintiff James H. Turban complained of herein also were the direct and proximate result of Defendants Ronald M. and Sheila Murawski negligently entrusting their daughter with the motor vehicle at issue. 5 AND NOW, thjS~Y of March, 1999, I hereby certify that I have served the foregoing Order on the following by depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Neil A. Grover, Esquire Milspaw & Beshore 130 State Street P.O. Box 946 Harrisburg, PA 17108 . =\ ~ ~~ James G. Nealon, III, Esquire JAMES H. TURBAN and TRACY L. TURBAN, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 98.3330 CIVIL TERM ALICIA MURAWSKI, RONALD M. MURAWSKI and SHEILA MURAWSKI, Defendants CIVIL ACTION. LAW : JURY TRIAL DEMANDED 1. On January 27, 1999, Defendants filed a Motion to Compel Answers to Interrogatories and Response to Request for Production of Documents. 2. By Order dated February 3, 1999, the Honorable J. Wesley Oler, Jr., issued a Rule upon Plaintiffs to show cause why the relief requested should not be granted. A true and correct copy of this Order is attached hereto and incorporated herein by reference as Exhibit "A." 3. The notation of the Deputy Prothonotary indicates that copies were mailed to all counsel on Feburary 4, 1999. 4. By letter dated February 10,1999, counsel for Defendant caused to be served upon counsel for the Plaintiff a second copy of the February 3, 1999 Order. A true and correct copy of this correspondence is attached hereto and incorporated herein by reference as Exhibit "B." 5. To date, no response has been filed to the February 3,1999 Order. < ~ ~ . ( NEALON & GOVER , AT,TORN~YS AT LAW JOI MARIo:ET STREET. 9'" FLOOR 1',0. BOX S.5 HARRISBURG, PENNSYl.VANIA nos 71;.132.9900 FA.X: 717.2J6.9119 1.1 NORTH CHERRY U='E YORio:, PI'NNSYl.\'A='IA nOI 717.S_~~."S~S (COIlIIESPO:-:D TO 1l.\RRISIIl'RG\ August 26, 1998 Neil A. Grover, Esquire 130 State Street P.O, Box 946 Harrisburg, PA 17108 RE: Turban v. Murawski Dear Neil: Enclosed herewith please find the following: 1. Interrogatories propounded by Defendants to be answered by Plaintiffs - first set; and 2. Defendants' Request for Production of Documents Very truly yours, =! ~~?~' NEALON & GOVER7 ~ JGN/jab JAMES G. NEALON 1II . MATTHEW R. GOVER. BRJA.."l W. PERRY. CHRISTOPHER J. KNlGl-IT A PROFESSIONAL CORPORATION ,. ;,..,.,....._-...__.._..,.~"..._,.~.. J. 1. Please set forth your full legal name. ANSWER: '. '. 12. Have you ever suffered any injuries in any accident, either prior or subsequent to the incident referred to in the Complaint? If so, provide: (a) the date, time and place of the accident; (b) a detailed description of the manner in which the accident occurred; (c) the names and addresses of all physicians, hospitals or health care providers who rendered any treatment to you; (d) the nature of any injuries sustained; (e) the extent of recovery; and (f) the nature of any compensation received. ANSWER: 16. Have you sustained any loss of wages, financial loss or diminution in earning capacity as a result of the incident complained of? If so, describe the nature and amount of such loss or losses. ANSWER: '. 32. Have you ever applied for insurance and/or no-fault benefits as a result of the injuries sustained in this accident? If so, state: (a) the name and address of the insurance carrier to whom you have applied: (b) the adjuster or claims person handling the file: (c) the applicable claim(s) number; (d) whether any part of your claim has been rejected. ANSWER: ..... ',", ,",,', '",'" ...~. -.~ ...."- '. REQUEST FOR PRODUCTION OF DOCUMENTS I. The entire contents of any investigation file(s) and any other documentary material in your possession which support or relate to the allegations contained in Plaintiff's Complaint (excluding references to mental impressions, conclusions or opinions representing strategy or tactics and privileged communications from and to counsel). 2. Any and all statements concerning the action, as defined by Rule 4003.4, from all witnesses including any statements from the parties herein, or their respective agents, servants or employees. 3. All photographs taken or diagrams prepared of the scene of the accident or any instrumentality involved therein. 4. Any and all documents containing the names and home and business addresses of all individuals contacted as potential witnesses. 5. Reports of any and all experts who will testify at trial. 6. Any and all medical records, physician's reports and bills, hospital records or abstracts of same which relate in any way to the injuries allegedly sustained by Plaintiff, as well as the treatment of any similar injuries prior or subsequent to the occurrence in question. : ~~-.-;;;~, :,;,~;.~;.:'~::;~';:;..::::;:;;.~~~.;:..;, , December 18,1998 Neil A. Grover, Esquire 130 State Street P.O. Box 946 Harrisburg, PA 17108 RE: Turban v. Murawski Dear Neil: This case has been dragging on for quite some time. On August 26, 1998, I served upon you a Rule to File A Complaint. While you requested a reasonable extension of time, I think that "reasonableness" has now expired. Enclosed herewith, please find a copy of Notice of Praecipe to Enter Judgment of Non Pros which I have filed with the Court. I am not in a position to grant anymore extensions. Also, on August 26, 1998, I sent to you initial discovery requests. To date, I have not received any responses. Please advise as to when I might expect responses so that we can avoid the filing of a Motion to Compel Discovery. Finally, we have canceled depositions twice at your request. Please have your office contact my office immediately to reschedule the depositions. Thank you. ~~"" =\ ~am"GN~~/# NEALON & GOVER JGN/slf Enclosure NEW MATIER 6. Plaintiffs' counsel communicated with defense counsel on February 24, 1999, via fax and regular mail regarding the forthcoming discovery responses and other issues. A copy of that letter is attached hereto as Exhibit 1. 7. Plaintiff's counsel then timely served Answers to Interrogatories and a Responses to the Request for Production of Documents, including all non-medical documents, on defense counsel via United States mail on March 2, 1999. This is the same date of the Defendant's present Petition was mailed to the Court. The letter advised that additional copies of the medical records __ all or most of which had been previously provided to Allstate Insurance, the Defendant's auto insurance carrier -- were being copied again by an outside service and would be promptly forthcoming. A copy of that cover letter is attached as Exhibit 2. For the sake of economy, Plaintiffs have not attached the actual discovery responses and documents to this Answer, but will promptly make the same available to the Court if the substance becomes an issue or if otherwise requested. 8. Plaintiffs' counsel served the additional documents referenced in his March 2, 1999, letter this morning, along with some corrective responses to the Interrogatories. Counsel attempted to hand deliver those documents at @ 5:20 p.m. on March 3, 1999, but the office building where defense counsel is located was closed, so all the papers are dated March 3, 1999. A copy of that cover letter is attached as Exhibit 3. Again, Plaintiffs have not included the actual discovery responses and documents, but will make these available if the Court so requires. 2 JAMES H. TURBAN and TRACY L. TURBAN, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. NO. 98.3330 CIVIL TERM ALICIA MURAWSKI, RONALD M. MURAWSKI and SHEILA MURAWSKI, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Michael Woods, M.D. Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9'" Floor, Harrisburg, PA 17101. 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 G. Nealon, III, Esquire 301 Market Street, 91h Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: t, AfIr. 'f1 A~~ Seal of the Court JAMES H. TURBAN and TRACY L. TURBAN, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. NO. 98-3330 CIVIL TERM ALICIA MURAWSKI, RONALD M. MURAWSKI and SHEILA MURAWSKI, Defendants CIVIL ACTION. LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: James Tyndall, M.D. Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9'h Floor, Harrisburg, PA 17101. 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 G. Nealon, III, Esquire 301 Market Street, 9'h Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: t.Aff9t1 4..z.'" (PROTHONs;m RY Seal of the Court NEALON & GOVER ATTORNEYS AT LAW . 301 MARKET STREET. 9"' FLOOR P.O. BOX 865 HARRISBURG, PENNSYLVANIA 17108 7170232-9900 FAX: 717.236.9119 IS NORTH CHERRY LANE YORK, PENNSYLVANIA 17401 717-852.7888 (CORRESPOND TO HARRISBURG) April 20, 1999 Martin Gildea, D.C. 2515 Gettysburg Road Camp Hill, PA 17011 In Re: James H. Turban Social Security #: 207-56-1266 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. \ Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, B~e';;:a:eg~ NEALON & GOVER BJB/bjb Enclosures JAMES G. NEALON III . MATTHEW R. GOVER. BRIAN W. PERRY . CHRISTOPH:E~ J. KNIGHf A PROFESSIONAL CORPORATION JAMES H. TURBAN and TRACY L. TURBAN, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. NO. 98.3330 CIVIL TERM ALICIA MURAWSKI, RONALD M. MURAWSKI and SHEILA MURAWSKI, Defendants CIVIL ACTION. LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Martin Gildea, D.C. Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover. 301 Market Street, 9"' Floor, Harrisburg, PA 17101. 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 G. Nealon, III, Esquire 301 Market Street, 9th Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED:~Affq1 4~ Seal of the Court 1,'-"0 .. JAMES H. TURBAN and TRACY L. TURBAN, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. NO. 98.3330 CIVIL TERM ALICIA MURAWSKI, RONALD M. MURAWSKI and SHEILA MURAWSKI, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: John P. StraUs Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9111 Floor, Harrisburg, PA 17101. 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 G. Nealon, III, Esquire 301 Market Street, 9th Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED:~ Seal of the Court ~ ')c ~NOT RY EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: John P. Stratis ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present James H. Turban 207-56-1266 12/12/62 NEALON & GOVER ATTORNEYS AT LAW 301 MARKET STREET. 9"' FLOOR P.O. BOX 865 HARRISBURG, PENNSYLVANIA 17108 717.232.9900 FAX: 717.236.9119 IS NORTH CHERRY LANE YORK, PENNSYLVANIA 17401 717.852.7888 (CORRESPOND TO HARRISBURG) April 20, 1999 Harrisburg Hospital 111 South Front Street Harrisburg, PA 17101 In Re: James H. Turban Social Security #: 207-56-1266 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, BJB/bjb Enclosures ~~~f)~ Barbara Baker, Paralegal NEALON & GOVER JAMES G. NEALON ill . MATTIiEW R: GOVER. BRIAN W. PERRY. CHRISTOPHER J. KNIGHT A PROFF.SSIONAL CORPORATION EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Harrisburg Hospital ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present James H. Turban 207-56-1266 12/12/62 ~.,."..,~--., NEALON & GOVER ATTORNEYS AT LAW 301 MARKET STREET. ,.. FLOOR P.O. BOX 865 HARRISBURG, PENNSYLVANIA 17108 717.232-9900 FAX: 717.236-'11' IS NORTH CHERRY LANE YORK, PENNSYLVANIA 17401 717.852.7888 (CORRESPOND TO HARRISBURG) April 20, 1999 Osteopathic Hospital 4300 londonderry Road Harrisburg, PA 17109 In Re: James H. Turban Social Security #: 207-56-1266 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, ()o--W,^-^~ ~ Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures JAMES G. NEALON III . MATTHEW R. GOVER. BRIAN W. PERRY . 'iHRISTOP~R J. KNIGHT A PROFESSIONAL CORPORATION JAMES H. TURBAN and TRACY L. TURBAN, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. NO. 98-3330 CIVIL TERM ALICIA MURAWSKI, RONALD M. MURAWSKI and SHEILA MURAWSKI, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: OsteopathIc Hospital Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street, 9'h Floor, Harrisburg, PA 17101. 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 compiy with it. This Subpoena was issued at the request of the fOllowing person: James G. Nealon, III, Esquire 301 Market Street, 9'h Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED: ~Af~ ~~ Seal of the Court ,....,\...".,-.,.,.~...,..,.,~; . . NEALON & GOVER ATTORNEYS AT LAW 301 MARKET STREET. 9"' FLOOR P.O. BOX 865 HARRISBURG, PENNSYLVANIA 17108 717-2.32.9900 FAX,717.236.9119 IS NORTH CHERRY LANE YORK, PENNSYLVANIA 17401 717.852.7888 (CORRESPOND TO HARRISBURG) April 20, 1999 Susquehanna Surgeons 532 North Front Street Wormleysburg, Pa 17043 In Re: James H. Turban Social Security #: 207-56-1266 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of. preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, ~~~~v)~-0CJ Barbara Baker, Paralegal NEALON & GOVER SJS/bjb Enclosures JAMES G. NEALON ill . MATTHEW R. GOVER. BRIAN W. PERRY' CHRISTOPHER J. KNIGHI' A PROFESSIONAL CORPORATION EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Susquehanna Surgeons ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present James H. Turban 207 -56-1266 12/12/62 JAMES H. TURBAN and TRACY L. TURBAN, hIs wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. NO. 98.3330 CIVIL TERM CIVIL ACTION. LAW ALICIA MURAWSKI, RONALD M. MURAWSKI and SHEILA MURAWSKI, Defendants : JURY TRIAL DEMANDED NOTICE TO: Susquehanna Surgeons You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Susquehanna Surgeons, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian .. ..' ~- .,.' ....."~.,,'~...':",..~..;.,.~~~~ JAMES H. TURBAN and TRACY L. TURBAN, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. NO. 98.3330 CIVIL TERM CIVIL ACTION - LAW ALICIA MURAWSKI, RONALD M. MURAWSKI and SHEILA MURAWSKI, Defendants : JURY TRIAL DEMANDED NOTICE TO: Daniel S. Bowerman, D.C. You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Daniel S. Bowerman, D.C., certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian .. ". .::" ,:~,.\':i"",' ;:. :~:'~',::,:.::' < '::'''.''/::'\''<' :..:.':_:;:.'.';-.,>':~': ::',':::'": ~:; :,:'i:,." :',:'" ..",<>.. . ::. "". .~., '~~,"'~,' ,(:/.~~ :' ",::, ';. ': _ .~ ...'......;.,..,....~~ '-.' NEALON & GOVER ATTORNEYS AT LAW 301 MARKET STREET. 9"' FLOOR P.O. BOX 965 HARRISBURG, PENNSYLVANIA 17108 717-232-9900 FA.'I(: 717.236.9119 IS NORTH CHERRY LANE YORK, PENNSYLVANIA 17401 717.852.7888 (CORRESPOND TO HARRISBURG) April 20, 1999 Rehab Medical Associates 5124 East Trindle Road Mechanicsburg, PA 17055 In Re: James H. Turban Social Security #: 207-56-1266 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the SUbpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, ~~~ 0~ Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures JAMES G. NEALON III . MATTIiEW R. GOVER. BRIAN W. PERRY. CHRISTOPHEIl- J. KNIGHT A PROFESSIONAL CORPORATION EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For: Rehab Medical Associates ANY AND ALL MEDICAL RECORDS, OFFICE NOTES, CORRESPONDENCE, MEMORANDUM, INSURANCE FORMS, PROGRESS NOTES, REPORTS OR OTHER DOCUMENTS RELATING TO ANY EXAMINATION, CONSULTATION, CARE OR TREATMENT. DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present James H. Turban 207-56-1266 12/12/62 ------ """""'.,,:,;~,~:.:.,;_..,:"~;,~ .,~;>!':'.:,:~~i EXPLANATION OF REQUIRED RECORDS TO: Custodian of Records For; CS&E Entire personnel file, including but not limited to applications for employment, correspondence, memorandum, health records, payroll records or other documents pertaining to: DATES REQUESTED: SUBJECT: SOCIAL SECURITY #: DATE OF BIRTH: Up to and Including the Present James H. Turban 207-56-1265 12/12/62 NEALON & GOVER 301 MARKET STREET. 9"' FLOOR P.O. BOX 865 HARRISBURG, PENNSYLVANIA 17108 717.232.9900 FAX: 717.236.9119 ATTORNEYS AT LAW 15 NORTH CHERRY LANE YORK, PENNSYLVANIA 17401 717.852.7888 (CORRESPOND TO HARRISBURG) April 20, 1999 Non-Claustrophobic MRI Services 4349 Carlisle Pike Camp Hill, PA 17011 In Re: James H. Turban Social Security #: 207-56.1266 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, I am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. 8J8/bjb Enclosures Sincerely, (';~~ ~~ Barbara Baker, Paralegal NEALON & GOVER - JAMES G. NEAtON III. MATTHEW R. GOVER. BRIAN W. PERRY. CHRlSTOPf:IERJ. KNIGHT A PROFESsiONAL CORPORATION '" ~ JAMES H. TURBAN and TRACY L. TURBAN, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. NO. 98.3330 CIVIL TERM ALICIA MURAWSKI, RONALD M. MURAWSKI and SHEILA MURAWSKI, Defendants CIVIL ACTION - LAW : JURY TRIAL DEMANDED NOTICE TO: Orthopedic Institute of PA You are required to complete the following Certificate of Compliance when producing documents or things pursuant to the Subpoena. CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUMENTS OR THINGS PURSUANT TO RULE 4009.23 I, Records Custodian for Orthopedic Institute ofPA, certify to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the Subpoena issued on have been produced. DATE: Records Custodian JAMES H. TURBAN and TRACY L. TURBAN, his wife, Plaintiffs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. NO. 98-3330 CIVIL TERM ALICIA MURAWSKI, RONALD M. MURAWSKI and SHEILA MURAWSKI, Defendants CIVIL ACTION - LAW : JURY TRIAL DEMANDED SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: James Corrigan, D.O. Within twenty (20) days after service of this Subpoena, you are ordered by the Court to produce the following documents or things: SEE ATTACHED at the offices of Nealon & Gover, 301 Market Street,9'h Floor, Harrisburg. PA 17101. 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 G. Nealon, III, Esquire 301 Market Street, 9'h Floor Harrisburg, PA 17101 717-232-9900 Attorney for Defendant BY THE COURT: DATED:~~ Seal of the Court f:; . r;" II \ . ' NEALON & GOVER ATTORNEYS AT LAW 301 MARKET STREET. 9"' FLOOR P.O. BOX 865 HARRISBURG, PENNSYLVANIA 17108 717.232-9900 FAX. 717.236.9119 15 NORTH CHERRY LANE YORK, PENNSYLVANIA 17401 717.852.7888 (CORRESPOND TO HARRlSBURG) April 20,1999 Holy Spirit Hospital 503 North 21'1 Street Camp Hill, PA 17011 In Re: James H. Turban Social Security #: 207-56-1266 Dear Records Custodian: You are being served with a Notice and Subpoena for you to bring the records referred to in the Subpoena for examination by the undersigned at the time and place indicated. In serving upon you the Notice and Subpoena, i am proceeding under applicable Pennsylvania Rules of Civil Procedure. A copy of the Subpoena and a Notice of Intent to Service the Subpoena was served upon the attorney for the Plaintiff more than 20 days ago. No objections to the Subpoena have been filed. If you would prefer, you may in advance of the deposition date send us photocopies of the records. With such photocopies, please include your statement for the cost of preparing the same, which we will promptly pay. In addition, you must complete the enclosed Certificate of Compliance. Upon receipt of such photocopies and the completed Certificate of Compliance by this office, your appearance will be canceled and the Subpoena withdrawn. Your cooperation in this matter is appreciated. Should there be any questions, please telephone the undersigned at the above number. Sincerely, ~~~~~~ Barbara Baker, Paralegal NEALON & GOVER BJB/bjb Enclosures JAMES G. NEALON ill . MATTHEW R. GOVER. BRIAN W. PERRY. CHRlSTOPHER J. KNIGHT A PROFESSIONAL CORPORATION CERTIFICATE OF SERVICE AND NOW, this 20th day of April, 1999, I hereby certify that I have served the foregoing Certificate Prerequisite to Service of a SUbpoena on the following by ,,"' depositing a true and correct copy of same in the United States mails, postage prepaid, addressed to: Neil Grover, Esquire 130 State Street P.O. Box 946 Harrisburg, PA 17108 ~~~ G 1J~~/)j Ja es G. Nealon, III, Esquire ' 6;;1